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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Source: National Grid
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
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
Client: the Nature Conservancy
Author: Bryndis Woods, PhD
March 2024
On behalf of the Nature Conservancy (TNC), AEC Principal Analyst Bryndis Woods, PhD provided equity and environmental justice guidance and support to TNC Northeast (and New York) Division’s government relations staff. As part of this work, AEC provided an equity and environmental justice organization library and a Diversity, Equity, Inclusion, and Justice (DEIJ) library that includes DEIJ Action Plans, Implementation Guides, Strategy Frameworks, and other related equity, environmental and social justice materials. Informed by the results of AEC’s engagement with TNC staff, Dr. Woods made nine recommendations to guide TNC staff to center and prioritize equity and justice in their work.
Client: Ameren 2023 Integrated Resource Plan
Author: Tyler Comings, Joshua R. Castigliego
March 2024
Senior Economist Tyler Comings and Researcher Joshua Castigliego co-wrote comments with Sierra Club on Ameren Missouri's 2023 Integrated Resource Plan (IRP) filed at the Missouri Public Service Commission. The comments focused on flaws in the IRP including the lack of a thorough evaluation of the coal units' futures, the understatement of new gas replacement costs and overstatement of clean energy costs.
Author: Joshua R. Castigliego
February 2024
On behalf of the Energy Justice Network, Researcher Joshua R. Castigliego provided expert comments in Docket No. EPA-HQ-OLEM-2023-0451 on the U.S. Environmental Protection Agency’s (EPA) Waste Reduction Model (WARM) Version 16 and its supporting documentation. In his comments, Mr. Castigliego reviewed and critiqued WARM’s methodology and assumptions regarding avoided emissions from the displacement of grid electricity through energy recovery at waste incineration facilities. Mr. Castigliego determined that WARM’s current methodology and assumptions are flawed and include errors that together appear to result in an overestimation of net emission reductions from waste incineration facilities.
His assessment highlights that WARM’s assumptions contain a critical error due to its failure to consider the sales of renewable energy credits (RECs), particularly as they relate to state renewable portfolio standards (RPS), in its estimation of emissions displaced by electric generation from waste incinerators. In addition, Mr. Castigliego identified additional critiques of WARM’s current methodology for estimating electric sector emission factors: (1) WARM’s emission factors for the electric sector are too simplistic and a poor proxy for marginal emissions; (2) avoided electric emissions are best estimated using the displacement of the marginal resource; (3) wind regularly serves as the marginal resource in some regions, meaning that emitting resources are not the only ones displaced; and (4) WARM’s regions do not align with the regions that correspond to electric sector operations and dispatch decisions.
Mr. Castigliego concludes that a majority of the flaws in WARM’s grid displacement assumptions center around the misalignment with how these emissions are addressed within the electric sector. To improve the accuracy of estimating avoided emissions from energy recovery in the waste management sector, EPA must better approximate what resources are most likely to be displaced by waste incinerators based on the characteristics of these facilities compared to other resources on the grid.
Author: Joshua R. Castigliego
December 2023
To support AEC’s emissions accounting work, Researcher Joshua R. Castigliego developed a spreadsheet-based tool—AEC's Emissions Measurement Inventory Tool (AEC-EMIT)—that provides users with an interface to build a greenhouse gas emissions inventory (and 20-year emissions projections) for a specific geographic region. Users can customize the tool by selecting greenhouse gases, sectors, subsectors, scenarios, sensitivities, and other information specific to their inventory. Users are also provided a dashboard to toggle select assumptions and parameters (e.g., global warming potentials, scenarios, and sensitivities, etc.). Summary tabs aggregate results across sectors and can be used to provide disaggregated sub-sector-specific results.
AEC-EMIT was utilized for AEC’s analysis on Puerto Rico’s 2019 and 2021 Greenhouse Gas Inventories Report.