LG&E-KU’s 2024 Integrated Resource Plan: An Assessment

Image credit: Bill McLaugh

Client: Mountain Association (MA), Kentuckians for the Commonwealth (KFTC), Kentucky Solar Energy Society (KYSES), and Metropolitan Housing Coalition (MHC)

Authors: Joshua R. Castigliego, Elizabeth A. Stanton, PhD

March 2025

On behalf of the Mountain Association (MA), Kentuckians for the Commonwealth (KFTC), Kentucky Solar Energy Society (KYSES), and Metropolitan Housing Coalition (MHC) (collectively, the “Joint Intervenors”), Senior Researcher Joshua R. Castigliego and Principal Economist Elizabeth A. Stanton, PhD prepared a white paper that sets out best practices for IRP modeling and reporting, and assesses the Louisville Gas and Electric Company (LG&E) and Kentucky Utilities Company (KU) (collectively, LG&E-KU) 2024 IRP filed on October 18, 2024 in Case No. 2024-00326 based on those criteria.

AEC’s best practices are organized into five categories: (A) Demand-Side Analysis; (B) Supply-Side Analysis; (C) Modeling Structure; (D) Selection of Recommended Plan; and (E) Stakeholder Input. Through its best-practices assessment, AEC finds that LG&E-KU’s 2024 IRP is missing critical components and includes errors in forecasting key assumptions, resulting in an overall flawed least-cost resource plan selection. LG&E-KU’s failure to follow IRP best practices results in resource decisions that are not properly informed (or justified) by comprehensive IRP modeling, leading to possible adverse effects on ratepayers. In particular, the flawed IRP findings may result in support for uneconomic resource additions in near-term CPCN applications.

Link to White Paper

Link to Joint Intervenors’ Comments

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Testimony on East Kentucky Power Cooperative Certificates of Public Convenience and Need

Client: Appalachian Citizens’ Law Center, Kentuckians for the Commonwealth, and Mountain Association

Authors: Liz Stanton, PhD

February 2025

Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Kentucky Public Service Commission (“the Commission”) in response to the 2024 request for approval of Certificates of Public Convenience and Need (“CPCN”) filed by East Kentucky Power Cooperative, Inc. (“EKPC”). In her testimony, Dr. Stanton assesses EKPC’s: annual and peak customer demand forecasts, with a focus on its Winter Peak; alternative supply resource options; modeling and resource selection methods; and rate impacts. Dr. Stanton’s review finds that EKPC has not adequately supported its winter peak demand forecast, failed to provide the modeling and analytical support needed to justify the CCGT, and failed to demonstrate that the CCGT is superior to other available alternatives such as battery storage, demand response, or peaking resources.

Link to Testimony

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A Community Assessment of Health Impacts from the Pittsfield Generating Facility on Local Communities

Client: Massachusetts Clean Peak Coalition

Authors: Jordan Burt, Elisabeth Seliga, Tanya Stasio, PhD, Lila McNamee, and Liz Stanton, PhD

February 2025

On behalf of the Massachusetts Clean Peak Coalition 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 summarizes the negative health impacts of fossil fuel-fired emissions on communities living near the Pittsfield Generating Facility. The report identifies three key takeaways:

1. As long as the Pittsfield Generating Facility is in operation, it has the potential to produce much higher greenhouse gas emissions and co-pollutants in any given year.

2. EJ and other vulnerable communities live in close proximity to the Pittsfield Generating Facility, increasing vulnerability to adverse health outcomes.

3. Replacing the fossil fuel-fired plant with clean energy resources can reduce emissions in the area.

Link to Report

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Duke KY IRP Comments

Client: Sierra Club

Authors: Tyler Comings, Joshua R. Castigliego, and Jordan Burt

January 2025

Principal Economist Tyler Comings, Senior Researcher Joshua Castigliego, and Researcher Jordan Burt co-wrote comments on the Duke Energy Kentucky 2024 Integrated Resource Plan (IRP). The comments focused on the utility's decision to co-fire a coal unit (East Bend Unit 2) with natural gas. We found that full conversion of the unit to gas was more cost-effective and reduced regulatory risk. 

Link to Comments

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Testimony on Alabama Power Company Petition for Certificate of Convenience and Necessity

Client: Energy Alabama and GASP

Authors: Elizabeth A. Stanton, PhD

January 2025

Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Alabama Public Service Commission (“Commission”) in response to Alabama Power Company’s proposed Lindsay Hill Generating Station (“Lindsay Hill”) purchase. In her testimony, Dr. Stanton addresses Alabama Power’s failure to satisfactorily consider alternative resources to its proposed purchase and determines that without consideration of alternative resources, it is not possible to conclude that the Lindsay Hill purchase is the lowest cost option. Dr. Stanton’s review of Alabama Power’s Lindsay Hill Certificate of Convenience and Necessity (“CCN”) Petition finds that the proposed purchase would decrease the Company’s resource diversity and increase its reliability risks. To address these concerns, Dr. Stanton recommends the Commission require Alabama Power to:

1. Include portfolio diversity risks in IRP and CCN cost modeling

2. Issue a new Capacity request for proposals (“RFP”) that does not exclude bids by alternative resources including battery storage and solar plus storage resources

3. Require that cost modeling be conducted for more than one resource (or more than two versions of the same resource) to be considered for CCN approval

4. Reissue RFPs when there are insufficient bids submitted to obtain proposals for a minimum of four resources and three resource types.

Link to Testimony

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Rooftop Coverage Alternatives: Assessing Benefits for Grove Hall

Client: Greater Grove Hall Main Streets (GGHMS)

Authors: Elisabeth Seliga, Sumera Patel, Joshua R. Castigliego

January 2025

On behalf of Greater Grove Hall Main Streets (GGHMS), Assistant Researcher Elisabeth Seliga, Assistant Researcher Sumera Patel, and Senior Researcher Joshua R. Castigliego prepared an issue brief examining a set of rooftop coverage alternatives (i.e., solar photovoltaic (PV), green, white, blue, and brown roofs) aimed at addressing the unique energy and environmental challenges faced by Boston’s Grove Hall community, highlighting the potential for a systems approach encompassing each rooftop coverage alternative to enhance energy efficiency and alleviate energy burden in a region characterized by urban heat island effects and a high share of environmental justice (EJ) populations. The issue brief provides actional recommendations for GGHMS to implement a combination of rooftop coverage alternatives to mitigate energy and environmental disparities, promote environmental resilience, and foster a healthier urban environment in Grove Hall.

Link to Issue Brief

Link to Works Cited

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Tackling Extreme Heat: Recommendations for Strengthening Massachusetts Policy

Client: A Better City

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

December 2024

On behalf of A Better City, Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga, Researcher Jordan Burt, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD prepared a policy brief and accompanying background report that (1) provides a discussion of extreme heat in Massachusetts and the disproportionate impact on low-income and Black, Indigenous, and People of Color (BIPOC) communities, (2) reviews policies to address extreme heat in the Commonwealth and across the United States, and (3) develops six recommendations for Massachusetts policymakers to address both short-term extreme heat emergency preparedness and long-term heat resiliency in the Commonwealth, supporting cooler neighborhoods, cooler buildings and homes, and cooler commutes.

Link to Policy Brief

Link to Background Report

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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.

Link to Report

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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. 

Link to Report

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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

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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

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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 Advisory Filing

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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 Expert Report

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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 Answer Testimony

Link to Cross-Answer Testimony

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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.

Link to Testimony

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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.

Link to Report

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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.

Link to Report

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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 Testimony

Link to Rebuttal Testimony

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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.

Link to Report

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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.

Link to Report

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