Francis H. Cummings
Project Experience and Qualifications (through 1999)
Energy Management and Efficiency
Energy Facility Financing and Development
Electric and Gas Utility Restructuring
Mr. Cummings served as Director of Policy at the Massachusetts Division of Energy Resources (DOER) from May of 1994 through April of 1998, and in this capacity contributed leadership and analytical direction to virtually all of DOER's activities with respect to electric and gas utility restructuring and deregulation, including:
- participation in regulatory proceedings: he drafted and reviewed DOER filings and testified in gas and electric regulatory proceedings, including the generic restructuring docket (D.P.U. 96-100), the 1998 DTE proceeding on Terms and Conditions for utilities and new suppliers, He provided the policy leadership to make the case for divestiture of generating plants to determine market value, mitigate transition costs & reduce vertical market power;
- negotiation support: he successfully negotiated for DOER the 1995 restructuring principles and participated in comprehensive settlement negotiations with Massachusetts Electric and Boston Edison, and led DOER's negotiations with stakeholders to develop proposed regulations on disclosure and labeling of competitive power "products;"
- technical, economic and policy analysis: he formulated, analyzed and recommended DOER policies for electric restructuring, including development of the Governor's 1996 generic restructuring plan, and policies to introduce gas transportation services for all customers and deregulate the LDC merchant function;
- market monitoring: he played a key role in hearings and negotiations that led to the plan for a New England ISO and its power exchange spot market and participated in the development of the disclosure regulations which will provide structure and data for future market monitoring.
In addition, Mr. Cummings directed or provided support to the work of other DOER staff in the following areas:
- legislative analysis and development: he drafted legislative language, provided policy assessment and worked closely with the Commissioner of Energy, other state officials and all the major stakeholders in Massachusetts throughout 1996 and 1997 as comprehensive restructuring legislation was initiated, debated and passed;
- energy procurement and municipal aggregation: he contributed to the development of DOER policies on aggregation through the regulatory and legislative process;
- energy program design and evaluation: he participated in planning sessions and provided policy direction for DOER's work to encourage customer choice pilot programs, to adapt utility demand-side management programs to the restructured industry, to develop approaches to evaluation of program impacts on generation service compared to regulated delivery service, and to develop a pilot program for municipal aggregation; and
- public information support: he reviewed drafts of public information and consumer education materials addressing electric restructuring and provided policy-related recommendations to the Director of Public Information.
Market Research on Power Project Development
Mr. Cummings conducted a review, comparison and screening of 45 natural gas combined cycle merchant plant development projects under development in New England in 1998 for an equity investor. For another private client in 1998, he developed and communicated policy positions to address potential barriers to entry of merchant power plants resulting from allocation of NEPOOL transmission expansion costs.
Renewable Resource Supply and Demand
Mr. Cummings prepared a report entitled "Impacts of Maine Portfolio Requirement on Supply and Demand for Renewable Resources" for submission to the Maine PUC in 1998.
Advice to U.S. EPA on Pollution Prevention Measurement
Mr. Cummings was appointed by the U.S. EPA in 1991 to the Pollution Prevention Measurements Subcommittee of the National Advisory Council for Environmental Policy and Technology (NACEPT). As an active member of this body, he advises EPA on policies and quantitative methodologies for collecting and interpreting data on industrial progress in reducing usage and release of toxic chemicals. In a related activity overlapping DSM and waste reduction, he organized a series of presentations on waste reduction and recycling at the 1991 Energy Opportunities Conference of the Northeast Sustainable Energy Association.
State Agency Market Data Analysis
DOER's legislative reporting responsibilities are in many ways analogous to the activities of state environmental agencies in reporting on trends and patterns in the waste management market. Mr. Cummings prepared the first Rhode Island Capacity Assurance Plan in 1989, including projections of hazardous waste generation and facility requirements and a summary of state policies affecting the need for waste management capacity. In additional engagements, he has analyzed industrial waste generation, waste reduction and environmental release data for the Northeast Waste Management Officials Association, the New Hampshire Department of Environmental Services, and the Rhode Island Department of Environmental Management.
Natural Gas Market Assessment
Mr. Cummings developed an economic methodology, and carried out a series of interviews with executives and engineers in key industries, for a U.S. DOE project to assess the level of manufacturing employment dependent upon firm natural gas supply. Mr. Cummings also performed financial and risk analysis of natural gas supply plans for 9 projects in 5 states from 1986 through the present, including assessment of U.S. and Canadian supply terms, the risks and costs of new pipeline projects, the regional and international availability and the financing implications of LNG fuel, and the alternative roles available to LDC's.
Cogeneration Project Development
One of the drivers of wholesale power market trends will be the construction of new facilities. Mr. Cummings understands the factors affecting the development of such facilities. He served as Project Manager for the 60 MW Southbridge Steam Limited Partnership gas combined cycle cogeneration plant in Massachusetts, including management of site selection, fuel acquisition, steam and power negotiations, equipment evaluation, environmental permitting, and financial evaluation. In addition, he participated in a private sector project development team which worked on 25 to 60 MW gas-fired combined-cycle cogeneration plants in three New England states.
Analysis of Barriers to Industrial Cogeneration
Mr. Cummings participated in a major study designed to determine the legislative and regulatory initiatives that could be taken by the federal government to stimulate industrial cogeneration development. He contributed to the following tasks: (1) identified the principal technical, eco-nomic, and regulatory constraints inhibiting cogeneration development; (2) analyzed the effect of these constraints on private-sector investment decision-making, and subsequently on market development; (3) defined over a dozen legislative, regulatory, and R&D actions that could be taken by the federal government; and (4) evaluated the benefits and costs for each government action. In conducting this study, Mr. Cummings and the other study team members interviewed over 60 industry representatives, electric utility executives, and state and federal regulators. This early DOE study was instrumental in stimulating energy tax credits, the PURPA law and increased competition in the power industry.
Proceedings on Load Forecasting
Mr. Cummings participated in a series of 1990 technical sessions held by both the Massachusetts DPU and the EFSC concerning the development of the Integrated Resource Management (IRM) regulations of both agencies, which included load forecasting for analysis of need. He also participated as an Interested Party in the 1991 Massachusetts Electric Company (MECo) IRM proceeding and reviewed the Company's IRM load forecast.
"The New England Energy Picture: A Background Paper"
Mr. Cummings was the author of a 1977 briefing paper which summarized the available data and key issues on New England energy sources and uses, energy prices, industrial energy use, and conservation programs. It also discussed the impact of energy pricing and supply on past and potential economic growth trends for key industries in New England. This paper was prepared for the New England Regional Office of the Federal Energy Administration, and was used as the basis of regional planning and public information workshops.
Power System Expansion Planning
Mr. Cummings is familiar with electric load forecasting and the use of energy computer modeling in state government. He managed a 1978 project for the Massachusetts Energy Facility Siting Council to develop an advanced planning information system to combine the use of site screening models, environmental impact models, and a linear programming model of regional site/technology alternatives with the use of conventional electric utility demand forecasting and supply planning models. This work was the basis for publication of the Mr. Cummings' December 1978 article in IEEE Spectrum "A Rational Approach to Power Plant Siting: A Technique that Integrates Economic, Environmental and Site-Specific Data Could Result in Better Decisions."
Energy Management and Efficiency
Massachusetts Energy Efficiency Policy
As Director of Policy at the Massachusetts Division of Energy Resources (DOER) from 1994 through 1998, Mr. Cummings served as DOER Director of Policy and provided policy input and direction for the work of the Energy Efficiency Team, and the work of Policy Unit staff on utility DSM, including:
- technical, economic and policy analysis: he formulated, analyzed and recommended DOER policies on DSM and market transformation;
- participation in regulatory proceedings: he reviewed and commented on drafts of filings to the DPU/DTE related to energy efficiency throughout the period 1994 - 1998;
- negotiation support: he was an active participant in DOER's negotiations with utilities and other parties to reach agreement of collaborative filings of five-year DSM plans, as well as DOER's negotiations on the DSM components of the comprehensive restructuring settlements;
- legislative analysis and development: he reviewed legislative language on utility DSM and the DOER role and participated in policy discussions on efficiency provisions throughout the legislative process;
- energy program design and evaluation: he developed and recommended approaches to the evaluation of DSM program cost-effectiveness, including the treatment of savings in generation service compared to regulated delivery service, as well as providing policy direction for DOER's work to adapt utility demand-side management programs to the restructured industry; and
- market monitoring: he provided recommendations on approaches to market monitoring in the context of DOER's newly legislated role with respect to efficiency services from utilities and from the market.
In addition, Mr. Cummings directed or provided support to the work of other DOER staff in the following:
- energy procurement and municipal aggregation: he contributed to the development of DOER policies on aggregation through the regulatory and legislative process;
- public information support: he reviewed drafts of public information and consumer education materials and provided policy-related recommendations to the Director of Public Information on key messages, definitions and exposition, including the role of energy efficiency as a factor in customer choice of electric suppliers.
Massachusetts Energy Plan
Mr. Cummings served as a consultant to the Massachusetts DOER in 1992 and 1993 to oversee and assist with the development of the state's Energy Plan. As part of this work, he prepared policy proposals and drafted plan materials on energy policy in all areas including energy efficiency, utility regulation, and transportation energy use. He also provided consulting assistance during 1993 and early 1994 for implementation of the Plan Actions on efficiency initiatives for municipal utilities and heating oil dealers.
Massachusetts Gas Utility DSM Program
For Bay State Gas Company of Westborough, Massachusetts in 1991, Mr. Cummings provided business planning and marketing assistance to an interdepartmental committee formed to develop a comprehensive new Demand Side Management Program for all firm customers. He also prepared planning and contractor procurement documents, helped develop a new DSM program for technical and financial assistance to industrial customers, assisted in the specification of procedures to govern the delivery of energy audits to small commercial and industrial customers, participated in program design meetings throughout a year-long development process, and researched the experience of other utilities with DSM cost recovery, revenue adjustment and regulatory incentives.
Rate Mechanisms for Utility DSM Cost Recovery and Incentives
Mr. Cummings assisted with the preparation of the Elizabethtown Gas Company's (ETG) February, 1992 "Demand Side Management (DSM) Resource Plan," under a subcontract with Energy Investment, Inc. This work involved a detailed review of the recently-adopted DSM rules of the New Jersey Board of Regulatory Commissioners (NJAC 14:12), which introduce a new system of incentives and planning procedures for both electric and gas utilities, including a "Standard Price Offer" based on avoided costs and a factor to moderate rate impact. Mr. Cummings participated in the development and drafting of the Rate Mechanism for cost recovery and incentives that ETG filed in February, and has more recently prepared responses for ETG to file with the Board in response to a series of interrogatories.
SBANE Environmental Efficiency and Assistance Program
For the Smaller Business Association of New England (SBANE) in 1992, Mr. Cummings, as a member of the Environmental Committee, prepared the first draft of the program funding proposal for this innovative new program and has been meeting with Massachusetts gas and electric utilities to solicit preliminary interest and sponsorship. This program is a private sector pilot project to coordinate and integrate the energy and environmental technical and financial assistance which is available to small businesses from utility DSM and economic development programs with related forms of assistance available from state energy and environmental agencies (including Massachusetts DOER).
Commercial & Industrial Customer Research
Mr. Cummings participated in the design and analysis of a detailed 1990 survey of commercial & industrial customers for Green Mountain Power Corporation, which included equipment saturation data, market share data for all fuels, and data on energy conservation measures implemented and available.
Electric Utility DSM Potential
For Fitchburg Gas & Electric Co. in 1989, Mr. Cummings allocated electric energy and load data to appliances and end uses for detailed customer subsectors within the residential, commercial, and industrial sectors, and estimated the technical potential for energy and summer and winter load reductions for each end use. CCI's market demand analysis model, CCENDUSE, was used to adapt and extrapolate regional and statewide data to a utility service territory for which limited market research data was available. The resulting report was submitted as an integral part of FG&E's 1989 Annual C&LM Report to the DPU.
Early Bidding for Maine Conservation Power Contract
Mr. Cummings developed the electric rate bid and financial projections for a 9 MW project, initiated by Swift River/Hafslund Company, to install commercial and industrial energy efficiency measures and certify the resulting savings for payments based on avoided cost by the utility. This project, one of the first DSM bids in the U.S., was awarded a contract by Central Maine Power Company in 1989.
Private Sector Energy Audit Development
Mr. Cummings served as General Manager of Resource Conservation Engineering of Cambridge, Massachusetts in 1976 to planning and manage the corporate startup of the first computerized energy audit service in the U.S. This firm was later renamed The Energy Bank, and the software development work initiated by Mr. Cummings evolved into the audit software later used by MassSave.
State and Federal Demand Management Program Planning
Mr. Cummings developed energy conservation programs for the residential and commercial sectors for the first state energy plans of Connecticut and New Jersey during the 1970's. During this time, at Resource Planning Associates of Cambridge, Massachusetts, he also developed a "Demand Management Planning Process" and a prioritized research program for the Department of Energy, and assessed the economic feasibility and national capital requirements of available conservation measures.
Energy Facility Financing and Development
Competitive Renewable Project Development
Mr. Cummings is currently providing consulting assistance to several private clients to identify potential regulatory requirements for development of onsite renewable generation and to assess potential wholesale and retail markets for generation from hydropower and photovoltaic sources. This work includes the analysis of interconnection and licensing requirements for sale of electricity to on-site customers, and disclosure procedures for transactions in the NEPOOL and PJM region. Mr. Cummings also assisted a generating company to negotiate a power sale contract in 1998 with a retail electricity provider for the Pennsylvania retail market.
Massachusetts Energy Policy
As Director of Policy at the Massachusetts Division of Energy Resources (DOER) from 1994 through 1998, Mr. Cummings was responsible for development of policy to support on-site and distributed generation, including fuel cells and renewable energy sources, and generally to encourage the development of new efficient energy facilities. He provided policy guidance on DOER positions and participated in negotiations with stakeholders during the Renewables Collaborative process in 1997.
Combined Cycle Plant Development
Mr. Cummings provided project manager community representative on a consulting basis in the late 1980's for a private client developing a 60 MW cogeneration power project at an industrial facility in Massachusetts. He coordinated development activities with joint venture partners, conducted financial analysis, and led negotiations with the steam host, natural gas suppliers and investment bankers. Responsibilities also included identifying required permits, preparing a project description for public information, conducting meetings with Town Manager and other key municipal officials and staff members, providing ongoing liaison with municipal government and community and business leaders, and making a presentation to the Town Council.
Hydroelectric Financial and Market Analysis
Mr. Cummings has conducted financial planning and market analysis for small hydro power projects for three private clients of Cummings Consulting, Inc., including development of a computer model in 1991 to forecast detailed income statements and balance sheets for a multinational developer of both hydroelectric and demand-side management projects.
Renewable Power Financing
Mr. Cummings conducted financial structuring, risk analysis and cash flow projections for $80 million of renewable power project financing completed between 1981 and 1988, including ten hydroelectric and biomass power plants totaling 30,000 kilowatts of capacity. He negotiated loan agreements on power projects in New Hampshire and Maine. He performed due diligence, financial and risk analysis, and structuring of business terms for numerous potential acquisitions and equity investments in power plant projects and development companies. He also developed computer programs and worksheets to prepare proforma financial statements on development projects to prepare financial "go/no go" decisions, to negotiate deals for buying sites and selling power, and to structure financings and joint ventures.
Energy Facility Siting
Mr. Cummings developed a multidisciplinary team audit system in 1980 to incorporate solar energy, hydropower, biomass, water-source heat pump and conservation measures into the architectural planning for redevelopment of a historical Massachusetts mill complex. He also managed a pathbreaking, interdisciplinary project for the New England Regional Commission on "Siting Acceptable Facilities in New England," integrating the work of engineers, hydrogeologists, lawyers and social scientists to prepare several handbooks, including a list and explanation of criteria for site selection and a guidebook to negotiation and compensation techniques for dispute resolution.
Utility Bidding and Negotiation
Mr. Cummings prepared bids and negotiated contracts for sale of power from Swift River Company and Swift River/Hafslund projects, including hydro, biomass, waste, gas, and demand-side management. Electric utilities included New England Power, Commonwealth Electric, Boston Edison, Public Service of NH, Central Maine Power and others.
Biomass Plant Operations Optimization Modeling
Mr. Cummings developed a computer model to identify the most cost-effective mix of biomass fuel supplies of different moisture contents, particle sizes, fuel values and prices for a 15 MW biomass power plant, given assumed and measured boiler performance data, seasonal fuel availability and variation, on & off-peak power rates and hours, and a set of monthly and annual limits in the electric utility contract.
Click here for Mr. Cummings' resume.
For further information, please email Fran at fcummings@gmail.com, or call him at 978-985-1557. Thank you.
© 1998, 1999 Francis H. Cummings
