Tackling Extreme Heat: Recommendations for Strengthening Massachusetts Policy

Insights from Fossil Fuel Replacement Case Studies

Client: Berkshire Environmental Action Team

Authors: Jordan Burt, Elisabeth Seliga, Tanya Stasio, PhD, Lila McNamee, and Elizabeth A. Stanton, PhD

December 2024

On behalf of the Berkshire Environmental Action Team, Researcher Jordan Burt, Assistant Researcher Elisabeth Seliga, Researcher Tanya Stasio, PhD, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD, prepared a report that reviews case studies of fossil-fuel plant conversions to clean energy resources across the country and discusses the replacement of existing peaker plants in Massachusetts to achieve statewide climate goals. The report identifies three key takeaways for the Commonwealth:

1. Fossil-fuel sites can be desirable locations for clean energy siting

2. Reducing reliance on fossil-fuel generation can help lessen the burden of environmental and health impacts on already overburdened communities

3. Fossil-fuel plant conversions are a tool that can be used to achieve state and local greenhouse gas emission limits.

Michigan City Generating Station Closure: Environmental Implications and Community Benefits

Client: Just Transition Northwest Indiana (JTNWI)

Authors: Bryndis Woods, PhD, Deja Garraway, Lila McNamee, Sumera Patel, Elizabeth A. Stanton, PhD

December 2024

On behalf of Just Transition Northwest Indiana (JTNWI), AEC assessed the retirement of Michigan City Generating Station (MCGS)—a 93-year-old coal-fired power plant located on the southern shore of Lake Michigan in Michigan City, Indiana. AEC's report presents the environmental and community impacts of MCGS' retirement, outlines opportunities for just and equitable redevelopment of the MCGS site, presents eight related case studies of coal plant redevelopment efforts, and makes five recommendations for a just transition for Michigan City to ensure that the communities most impacted by MCGS’ operations benefit from redevelopment.

Assessing the Net Emissions Benefit for a Clean Energy Facility in Wareham, Massachusetts

Client: New Leaf Energy, Inc.

Authors: Joshua Castigliego and Sumera Patel

November 2024

On behalf of New Leaf Energy, Inc., Senior Researcher Joshua R. Castigliego and Assistant Researcher Sumera Patel conducted analysis estimating the net change in carbon dioxide (CO2) emissions resulting from New Leaf Energy’s proposed clean energy facility on Maple Springs Road in Wareham, Massachusetts. This proposed facility will house solar photovoltaics (PV) and an energy storage system (ESS) (collectively referred to as “PV+ESS facility”) and require 32.7 acres of land to be cleared of trees to make way for its development.

AEC estimated net emission savings of this proposed PV+ESS facility as the sum of “positive” CO2 emissions savings (i.e., reduced emissions) from the electric grid due to renewable energy generation and “negative” CO2 emissions (i.e., increased emissions) due to land-use conversion from forestland to grassland. Combined, these two effects result in substantial net emissions savings (i.e., reduced emissions) resulting from the proposed New Leaf Energy facility: AEC’s analysis shows that the facility’s grid emissions reductions would be roughly 4.4 times greater than its added emissions due to site development.

Link to White Paper

Evergy Integrated Resource Plans in Missouri and Kansas

Authors: Tyler Comings and Joshua Castigliego

October 2024

Principal Economist Tyler Comings and Senior Researcher Joshua Castigliego co-wrote comments on Evergy's Integrated Resource Plan (IRP) that were filed with the commissions in Kansas and Missouri. AEC's comments showed that Evergy did not fully address greenhouse gas compliance costs at its coal and gas generators. AEC also showed that Evergy overstated the costs of clean energy replacement options, and unfairly favored gas replacement.

Link to MO Comments

Link to KS Comments

Link to Advisory Filing

Cost of Capital for Worker’s Comp in Massachusetts

Author: Tyler Comings

April 2024

Principal Economist Tyler Comings prepared an advisory filing for the State Review Board (SRB) of the Massachusetts Division of Insurance. Mr. Comings estimated the cost of capital and asset rate of return for the industry for use in regulated rates of workers' compensation insurance.

Link to Expert Report

Xcel MN Resource Plan

Author: Tyler Comings

August 2024

Principal Economist Tyler Comings contributed to both comments (with Clean Energy Organizations) as well as an expert report (with Chelsea Hotaling at Energy Futures Group) that addressed the Xcel MN resource plan. Mr. Comings contributions focused on the cost of new resources and he helped develop an alternative portfolio.

Link to CEO Comments

Link to Answer Testimony

Tri-State Energy Resource Plan

Author: Tyler Comings

May 2024

Principal Economist Tyler Comings filed testimony before the Colorado Public Utilities Commission on Tri-State Generation and Transmission’s resource plan. Mr. Comings discussed how Tri-State failed to justify its planned gas plant investment, including by ignoring key costs and risks of carbon capture storage (CCS) at the plant. He also discussed how Tri-States proposed requests for proposals (RFPs) for its upcoming new resource procurement were too limited; and as a result provided recommended changes to expand the resource types that could bid.

Link to Cross-Answer Testimony

Duke Indiana Rate Case

Author: Tyler Comings

July 2024

Principal Economist Tyler Comings filed testimony on the cost of Duke Energy Indiana’s coal fleet before the Indiana Utility Regulatory Commission. Mr. Comings showed that the Edwardsport plant, which runs on gasified-coal and natural gas, is exorbitantly costly and that ceasing coal at the plant is likely the best option for ratepayers. He also recommended disallowances for some of the costs of running the plant and proposed a sub-docket for the Commission to further review capital costs at Duke’s coal fleet.

Best Practices in Electric Sector Load Forecasting

Authors: Elizabeth A. Stanton, PhD, Alicia Zhang, Sagal Alisalad, Bryndis Woods, PhD

November 2024

This Applied Economics Clinic (AEC) white paper examines best practices of annual and peak electric demand forecasting and provides additional examples for South Carolina. AEC asserts that conventional load forecasting methods must be updated to reflect the rapid transformation of demand trends and real-word conditions. To address these concerns, AEC recommends eight best practices to ensure thorough, transparent, and accurate load forecasts: model and data transparency; emerging policies and technologies; large industrial loads; non-energy constraints; forecasting innovation; uncertainty analysis and multiple future scenarios; post-modeling adjustments; and stakeholder review. Adopting contemporary best practices in load forecasting benefits consumers, utilities and regulators with lower costs, increased reliability, and improved facilitation of state-mandated decarbonization plans.

Energy Storage Equity: An Assessment of Three Massachusetts Programs

Client: Clean Energy Group

Authors: Tanya Stasio, PhD, Elisabeth Seliga, Bryndis Woods, PhD, and Elizabeth A. Stanton, PhD

September 2024

On behalf of the Clean Energy Group (CEG), Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga, Principal Analyst Bryndis Woods, PhD and Principal Economist Liz Stanton, PhD assessed equity provisions in three Massachusetts energy storage-incentivizing programs: the Solar Massachusetts Renewable Target (SMART) program, the Clean Peak Standard, and ConnectedSolutions. AEC finds that three energy programs assessed lack mandates, targets and reporting requirements to support the Commonwealth’s commitment to equitable access to clean and efficient energy. AEC makes eight recommendations to better align Massachusetts’ energy storage programs with its equity commitments, as well as to draw on lessons learned and best practices from similar programs in other states.

Testimony on Rhode Island Energy's 2024-2025 Last Resort Service Procurement Plan

Client: Conservation Law Foundation

Authors: Elizabeth A. Stanton, PhD

September 2024

On behalf of the Conservation Law Foundation, Principal Economist Elizabeth A. Stanton, PhD, submitted expert testimony before the State of Rhode Island Public Utilities Commission in response to the Narragansett Electric Company d/b/a Rhode Island Energy’s 2024-2025 Last Resort Service Procurement Plan. In her testimony, Dr. Stanton asserts that the methodology used to create the LRS Procurement Plan and rate design must be updated “to incorporate new policy goals and legislative directives to be considered by the Commission and Division and subsequently applied to Rhode Island Energy (‘RIE’).” To address these concerns, Dr. Stanton recommends the Commission initiate a process to evaluate competing interests and policies and reach a transparent decision to guide future LRS procurement and rate design.

Link to Rebuttal Testimony

Affordable Housing and Energy Resilience in Lynn, Massachusetts: Community Land Trusts and Microgrids

Client: Neighbor to Neighbor

Authors: Deja Garraway, Lila McNamee, Sumera Patel, and Elizabeth A. Stanton, PhD

July 2024

On behalf of Neighbor to Neighbor, Researcher Deja Garraway, Research Assistant Lila McNamee, Assistant Researcher Sumera Patel, and Principal Economist Liz Stanton, PhD prepared a report discussing the potential benefits of community land trusts and community microgrids in the City of Lynn, Massachusetts. In particular, AEC finds that community land trusts and microgrids provide an opportunity to improve affordable housing outcomes for low-to-moderate income communities in the City of Lynn by, for example, supporting more permanent affordable housing, encouraging community empowerment and counteracting gentrification-induced displacement.

AEC offers four recommendations for Lynn communities to take ownership of their electric production, create long-term sustainable housing options, and provide homeownership opportunities for low- and moderate-income communities:

1. Promote awareness and knowledge of the community land trust and microgrid models,

2. Build capacity by providing funding to bring projects to scale,

3. Promote the development of affordable housing options with land acquisition, and

4. Foster long-term sustainability of community land trusts and microgrids.

Assessing Alternatives to the Proposed Chesterfield Energy Reliability Center (CERC)

Client: Southern Environmental Law Center (SELC)

Authors: Chirag T. Lala, Elisabeth Seliga, Joshua R. Castigliego, Elizabeth A. Stanton, PhD

July 2024

On behalf of the Southern Environmental Law Center (SELC), Researcher Chirag T. Lala, Assistant Researcher Elisabeth Seliga, Senior Researcher Joshua R. Castigliego, and Executive Director and Principal Economist Liz Stanton, PhD prepared a report that critiques the Virginia Electric and Power Company’s (d/b/a Dominion Energy Virginia) proposed Chesterfield Energy Reliability Center (CERC)—a 1,000-megawatt gas-fired combustion turbine facility—in Chesterfield, Virginia. AEC presents an assessment of an Alternative Portfolio—composed of solar, wind, and storage resources—that would provide the same energy and capacity needs as CERC, but at a lower cost. AEC finds that the midpoint of the range of likely levelized costs of the Alternative Portfolio is 52 percent less expensive than that of Dominion Energy Virginia’s proposed CERC: $263 million versus $544 million. The combination of solar, wind and storage meets CERC on peak capacity, beats CERC on annual generation, and would cost ratepayers just half of what Dominion Energy Virginia wants to spend on CERC. Notably, the Alternative Portfolio presented in this report includes neither energy efficiency nor demand response, both of which have the potential to lower costs still further. Investments in energy efficiency alone—made at levels similar to the annual investments common in numerous other states—could obviate the need for CERC by 2030 or sooner.

Illinois Adult Use Cannabis Industry Disparity Study

Client: Illinois Cannabis Regulation Oversight Office

Authors: Elizabeth A. Stanton, PhD, Bryndis Woods, PhD, Tanya Stasio, PhD, Jordan Burt, Deja Garraway, Nayantara Biswas, and Alannah Shute

July 2024

On behalf of the Illinois Cannabis Regulation Oversight Office, AEC assisted the Nerevu Group, LLC in preparing a disparity study to evaluate and assess existing discrimination within the State of Illinois cannabis industry. In particular, AEC staff reviewed public and private data sources to provide utilization, availability, and disparity analyses for the Illinois economy and the Illinois cannabis industry. AEC finds evidence of significant disparities in Illinois business ownership and wages across race/ethnicity and gender. Specifically, AEC finds that, compared to White men, racial and/or ethnic minorities and women are less likely to be business owners and have less access to capital through either hourly wages or bank loans.

To cultivate a more inclusive and equitable industry, Nerevu Group, LLC recommends broadening availability of financing for cannabis businesses, improved data management, consolidating of the Illinois regulatory structure, additional disparity studies, and more industry-state collaboration along with a set of administrative recommendations.

Comparing Electric Supply Rates in Massachusetts

Client: Green Energy Consumers Alliance (GECA)

Authors: Joshua R. Castigliego and Elisabeth Seliga

June 2024

On behalf of the Green Energy Consumers Alliance (GECA), Senior Researcher Joshua R. Castigliego and Assistant Researcher Elisabeth Seliga prepared a policy brief that presents a cost comparison of electric supply options offered to residential customers served by investor-owned utilities in Massachusetts. AEC’s analysis finds that residential customers are paying a premium for electric supply provided by Third-Party Competitive Suppliers compared to electricity provided by electric distribution companies and Municipal Aggregation programs. AEC also finds that previous estimates of cost premiums associated with Competitive Suppliers have underestimated the extent to which they raised average residential electric rates by not considering the cost savings associated with Municipal Aggregation programs, which often offer rates lower than both Competitive Supply and Utility Basic Service.

Link to Policy Brief

Link to Appendix

Testimony on Duke's Roxboro Certificate of Public Convenience and Necessity Request

Client: Southern Alliance for Clean Energy, Sierra Club, and Natural Resources Defense Council

Author: Elizabeth A. Stanton, PhD

June 2024

On behalf of the Southern Alliance for Clean Energy, Sierra Club, and Natural Resources Defense Council, Executive Director and Principal Economist, Elizabeth A. Stanton, PhD provided expert testimony before the North Carolina Utilities Commission in response to Duke Energy's petition to construct a 1,360 MW gas-fired combined-cycle electric generating facility in North Carolina. In her testimony, Dr. Stanton identified five concerns with the assumptions uses and information presented to justify the new facility:

Selective treatment of temporary technical challenges as extended barriers
Overestimation of the costs of renewables and storage
Underestimation of risks as costs to ratepayers
Noncompliance with the federal Clean Air Act
Exposure of ratepayers to costs from delayed plant construction

To address these concerns, Dr. Stanton makes several recommendations regarding the Commission’s determination of Duke’s certificate of public convenience and necessity request.

Home Heating in Massachusetts: What Influences Future Costs?

Client: Home Energy Efficiency Team (HEET)

Author: Tanya Stasio, PhD, Joshua R. Castigliego, Sumera Patel, and Elizabeth A. Stanton, PhD

March 2024

On behalf of the Home Energy Efficiency Team (HEET), Researchers Tanya Stasio and Joshua R. Castigliego, Assistant Researcher Sumera Patel, and Senior Economist Elizabeth A. Stanton prepared a white paper that estimates the average home heating costs faced by Massachusetts households using different heating technologies.

This March 2024 AEC white paper updates the home heating cost analysis conducted in AEC’s January 2021 white paper; both analyses present operating costs only, excluding the costs of purchasing or maintaining heating equipment. Updated analysis, based on the most recent data and cost projections, finds that heating with networked geothermal and ground-source heat pumps is less expensive than heating with gas-fired furnaces today and can be expected to remain so through 2050. Our findings regarding air-source heat pumps, however, point to more questions than answers: Changes in gas and electric prices over the past few years reversed our earlier findings, suggesting that notoriously uncertain forecasts of future fuel prices are of paramount importance in understanding the likely impacts of ASHP adoption on household finances.

Link to White Paper

Return to our Work

Testimony on National Grid’s 2023 Rate Case in Massachusetts

Client: Environmental Defense Fund (EDF) and Conservation Law Foundation (CLF)

Author: Joshua R. Castigliego

March 2024

On behalf of the Environmental Defense Fund (EDF) and Conservation Law Foundation (CLF), Researcher Joshua R. Castigliego provided expert testimony before the Massachusetts’ Department of Public Utilities (DPU) in response to National Grid’s petition to increase its base distribution rates and approve its proposed performance-based ratemaking (PBR) plan, referred to as its Comprehensive Performance and Investment Plan (CPIP). In his testimony, Mr. Castigliego specifically focused on the Company’s Infrastructure, Safety, Reliability, and Electrification (ISRE) Mechanism and performance incentive mechanisms (PIMs, including investment-based “IPIMs” and operating-based PIMs) included in its proposed CPIP. He also addressed National Grid’s proposed electrification pricing option and low-income discount rate proposal.

Based on these assessments, Mr. Castigliego found that the Company’s proposals on these topics were insufficient and should either be rejected or strengthened by DPU to better protect ratepayers and address the affordability challenges facing the National Grid’s customers. Mr. Castigliego also offered recommendations on these topics to better align National Grid’s proposals with the Commonwealth’s climate and clean energy goals and support a more equitable distribution of benefits resulting from the Company’s investments and programs

Link to Surrebuttal Testimony

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TVA’s Kingston Fossil Plant: An Economic Assessment of Replacement Alternatives

Client: Southern Environmental Law Center (SELC)

Author: Chirag T. Lala, Joshua R. Castigliego, Tyler Comings, Elisabeth Seliga

March 2024

On behalf of the Southern Environmental Law Center, Researchers Chirag T. Lala and Joshua R. Castigliego, Senior Economist Tyler Comings, and Assistant Researcher Elisabeth Seliga prepared a report that models the costs to consumers of alternatives for the soon-to-be retired Kingston Fossil Plant—a coal-fired power plant in Harriman, Tennessee that is owned and operated by the Tennessee Valley Authority (TVA). TVA’s Alternative A plan replaces Kingston with a gas-heavy portfolio that constructs gas combined cycle (CC) and combustion turbine (CT) plants, while Alternative B focuses on replacing Kingston with a clean energy portfolio that relies on solar and battery storage resources.

Among its four modeled alternatives, AEC finds the net present value costs of Alternative B—renewable and storage replacements that are self-built or procured through power purchase agreements—to be the lower cost option. This contradicts TVA’s claim that Alternative A is the lower cost option. In addition, it is not clear why TVA selected the amounts of solar and storage capacity in Alternative B. The storage capacity is exorbitant compared to the size of the Kingston plant and the solar capacity is made additional to a large amount of capacity TVA is already scheduled to build.

These irregularities are partly attributable to TVA’s failure to synchronize site specific resources assessments with an integrated planning process that provides a full range of plausible alternatives. AEC provides the following recommendations for TVA’s 2024 IRP:

Conduct an all-resource RFP that assesses the range of resources that could reasonably be constructed.
Consider the full set of resources that could facilitate decarbonization of TVA’s grid, including transmission and distribution, distributed energy resources, energy efficiency, demand response, and others.
Conduct optimization modelling on all potential resources instead of on pre-selected portfolios.
Ensure site-specific planning does not contradict TVA’s most recent IRP.
Ensure the IRP provides plausible schedules for the installation and decommissioning of capacity.
Use transparent assumptions and modeling inputs