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Alabama Power’s Plant Miller: An Economic Assessment of Alternative Portfolios
July 2025
On behalf of the Southern Environmental Law Center, Senior Researcher Joshua R. Castigliego, Researcher Jordan Burt, PhD, and Principal Economist Tyler Comings prepared a report that evaluates four alternative portfolios to demonstrate that the continued business-as-usual (BAU) operation of Alabama Power’s James H. Miller Jr. Electric Generating Plant (also known as “Plant Miller”) is uneconomic and not in the best interest of customers.
One method of comparing alternative resource portfolios is to examine customer costs on a “levelized” basis—which normalizes total costs by total generation (in megawatt-hours or “MWh”) over an assumed time period. The levelized cost of energy (LCOE, in $ per MWh) provides insight into how each of the alternative portfolios compare to one another regardless of the total energy provided by each portfolio. Among its four modeled alternatives, AEC finds that replacing Plant Miller with clean energy and storage resources is cheaper on a levelized cost basis than keeping the plant operational into the 2040s.
Alabama Power should also continually evaluate the costs and risks of keeping the plant on-line by looking at viable alternatives. Although the alternative portfolios presented in this report are meant to be illustrative, the results of the analysis have demonstrated that the continued operation of Plant Miller (with or without carbon sequestration retrofits) is uneconomic, and Alabama Power would be able to provide customers with cost savings by investing further in clean energy resources. In order to determine the most cost-effective replacement of Plant Miller, Alabama Power should periodically conduct capacity expansion modeling that considers the retirement of Plant Miller in the context of the Company’s entire system.
Testimony on LG&E-KU’s Certificates of Public Convenience and Necessity and Site Compatibility Certificates
June 2025
Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Kentucky Public Service Commission to assess the load forecasting assumptions utilized in the 2025 request for approval for Certificates of Public Convenience and Necessity (CPCN) filed by Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E-KU) in Kentucky PSC Case No. 2025-00045. In her testimony, Dr. Stanton reviews the Companies’ 2025 CPCN Load Forecast and assesses the methodology, assumptions, and findings of their economic development growth forecast, particularly as they related to projected growth in data centers.
Dr. Stanton recommends that the Companies employ a short-term forecast of new data center and other large customer load based on concrete evidence that there is a high likelihood that such load will actually come online, while discounting or excluding possible large customer load that is merely speculative or has a low likelihood of materializing, and presents an alternative framework for using probability weighting to forecast future load growth from data centers.
Basin Electric's Coal Fleet: Risks to Continued Operation and Opportunities for Replacement
June 2025
On behalf of the Western Organization of Resource Councils, this AEC report evaluates the risks associated with continued operation of Basin Electric’s coal-fired plants and outlines opportunities for replacement with lower-cost clean energy resources. The continued operation of Basin Electric’s coal plants entails important risks to Basin Electric, its members and members’ ratepayers, including risks presented by:
1. Federal oversight: In 2019, Basin Electric became subject to Federal Energy Regulatory Commission (FERC) oversight, which means Basin Electric is facing greater scrutiny of whether continued operation of its coal plants is most prudent for its members and their ratepayers.
2. Competition in Southwest Power Pool (SPP): Basin Electric’s forthcoming full membership in the Southwest Power Pool (SPP) risks that Basin Electric’s coal plants will operate less often because more of its coal generation will compete in every hour of the day with every other resource in SPP’s marketplace.
3. Environmental regulations: There are cost risks for Basin Electric’s coal-fired power plants related to new emission and pollution control technologies to comply with federal environmental regulations including: the Regional Haze Rule, the coal ash waste rules, and carbon pollution standards.
AEC finds that Basin Electric can hedge against risks to its coal-fired resources by taking advantage of cost-saving opportunities to replace coal resources with cheaper wind and solar resources—resources which become even more cost-effective when coupled with federal incentives, funding, and financing streams targeted specifically at electric cooperatives to pursue them.
All-sector energy planning
Benefit-cost analysis
Capacity expansion modeling
Dispatch modeling
Economic impact analysis (including REMI and IMPLAN)
Economics of energy resources
Electricity system planning (including integrated resource plans)
Emissions accounting
Energy and capacity markets
Energy efficiency planning
Energy policy analysis
Energy-water nexus
Environmental regulations
Equity and consumer impact analysis
Pipeline economic analysis
Renewable energy
Utility cost of capital
Utility finance analysis
Valuation of externalities
Analysis
We provide in-depth analysis of the economics, environmental, and equity impacts of all types of energy resources and policies. Read more →
Modeling
Clinic staff regularly analyze a number of third-party power sector model inputs and outputs used to conduct resource planning analyses, forecast electricity market prices, predict emissions output, and evaluate the need for future electric and natural gas capacity. . Read more →
Testimony
We provide expert testimony in state and federal regulatory proceedings on a variety of issues. Read more →
Public Reports
We provide public-facing reports for our clients, including economic assessments of existing energy resources and economic and emission impacts of environmental regulations. Read more →
Contact | Address: Applied Economics Clinic, 6 Liberty Sq., PMB 98162, Boston, MA, 02109 | Email: info@aeclinic.org