Massachusetts Building Sector Model and Policy Analysis

Client: Executive Office of Energy and Environmental Affairs

Author: Elizabeth A Stanton, PhD, Sagal Alisalad, Joshua R. Castigliego, Bryndis Woods, PhD, Tanya Stasio, PhD, Jordan Burt, PhD, and Elisabeth Seliga

August 2026

On behalf of the Massachusetts Executive Office of Energy and Environmental Affairs (MA EEA), AEC staff collaborated with Introba and Massachusetts Institute of Technology to develop the Massachusetts Building Energy Scenario Tool (MassBEST), a flexible modeling platform that integrates building-level energy modeling, adoption and propensity modeling, policy representation, and electric grid impact analysis to support the Commonwealth’s decarbonization decision-making. In this project, AEC designed a heuristic model of commercial clean technology adoption and addressed equity in the MassBEST model in response to the input of Massachusetts agency staff.

Return to Our Work

Testimony on Wisconsin Electric and Wisconsin Gas 2026 Rate Case

Client: Walnut Way Conservation Corporation

Author: Elizabeth A Stanton, PhD

August 2026

On behalf of Walnut Way Conservation Corp., Principal Economist Dr. Elizabeth A. Stanton prepared expert testimony before the Public Service Commission of Wisconsin in response to the Joint Application filed by Wisconsin Electric Power Company (Wisconsin Electric) and Wisconsin Gas LLC (Wisconsin Gas) (collectively, the “Joint Applicants”) seeking authority to increase electric, natural gas, and steam rates in Docket No. 5-UR-112. Dr. Stanton's testimony (1) evaluates the customer affordability impacts of the Joint Application, with a particular focus on household energy burden and the effect of proposed rate increases on Wisconsin Electric and Wisconsin Gas customers; (2) assesses whether the Joint Applicants have adequately accounted for customer affordability and equity considerations; and (3) provides recommendations for the Commission’s consideration.

Link to Testimony

Return to Our Work

Testimony on Puget Sound Energy 2026 Rate Case

Client: Earthjustice

Author: Elizabeth A Stanton, PhD

July 2026

On behalf of Earthjustice, Principal Economist Elizabeth A. Stanton, PhD prepared expert testimony on Puget Sound Energy’s (PSE’s) 2026 Rate Case in the context of Washington State’s clean energy regulations that require increasing shares of non-emitting electric generation over time. Specifically, Dr. Stanton finds:

• PSE is not planning to meet the Washington Clean Energy Transformation Act (CETA) greenhouse gas neutrality requirements for 2030

• PSE’s proposal to acquire a seventeen-year Tolling Agreement with TransAlta that converts the Centralia coal-fired plant to gas-fired generation is in misalignment with CETA

• PSE failed to carry its burden of proof showing that the TransAlta Tolling Agreement is prudent. In particular, the Centralia gas-fired plant would be uneconomic to run in six out of seventeen years of the agreement.

• PSE failed to adequately compare the financial cost of meeting expected capacity needs with one or more clean energy resources with the TransAlta Tolling Agreement, despite having received several economic bids for wind, solar, and solar plus storage in their 2024 All-Source Request for Proposals.

On this basis, Dr. Stanton recommends that the Washington Transportation and Utilities Commission disallow the TransAlta Tolling Agreement.

Link to Testimony

Link to News Coverage

Return to Our Work

New Hampshire Energy Burden Assessment

Client: 350 New Hampshire

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

July 2026

On behalf of 350 New Hampshire, Researcher Jordan Burt, PhD, Senior Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga, and Principal Economist Elizabeth A. Stanton, PhD, prepared a report that assesses disparities in energy burden across New Hampshire’s households. AEC’s analysis found that, on average, low-income household in New Hampshire spend 7 percent of their income on energy costs compared to just 3 percent for non-low-income households. In addition, AEC finds that low-income renters faced higher energy burdens on average than non-low-income renters. Informed by these findings and based on a review of existing energy programs across the country, AEC makes six recommendations to reduce energy bills and improve access to clean energy for low-income and renter households in New Hampshire.

Link to Report

Return to Our Work

Comments on Ameren Missouri LLC Integrated Resource Plan Initial Assumptions

Client: Sierra Club

Authors: Bryndis Woods, PhD and Joshua R. Castigliego

July 2026

AEC assisted Sierra Club with its submission of Comments on Ameren Missouri, LLC’s 2026 Integrated Resource Plan Initial Assumptions. Sierra Club’s comments addressed recommendations for Ameren in its forthcoming IRP, including issues related to the Company’s assumptions regarding: energy efficiency, large load customers, coal plant retirements, tax credit eligibility for wind and solar resources, carbon price forecasts, costs of new gas resources, gas price forecasts, and carbon capture and storage costs.

Return to Our Work

Kentucky Ratepayers Absorb Losses at Coal-Fired Power Plants in PJM

Client: Kentucky Resources Council (KRC)

Authors: Bryndis Woods, PhD, Joshua R. Castigliego, and Tyler Comings

July 2026

This Applied Economics Clinic (AEC) report assesses the energy market losses of three Kentucky-owned coal-fired generating units operating in the PJM wholesale energy market: East Bend Generating Station Unit 2 and Mitchell Power Plant Units 1 and 2. In PJM, electric generators are selected in least cost-rank order when they bid into the market (that is, PJM dispatches generators from least expensive to most expensive each hour of the day). However, owners of generator units can decide to run their units uneconomically without subjecting them to the grid operator’s least cost-rank order decision-making—a practice known as “self-commitment” or “must-run”—which passes the costs of running uneconomic units on to ratepayers.

Over a two-year period spanning November 1, 2022 to October 31, 2024, we find that the East Bend and Mitchell coal-fired units fared poorly in the energy market: the units collectively lost nearly $63 million on net, with each unit costing Kentucky ratepayers between $20 and $21 million. All three units had negative net revenues about 80 percent of the time over the two-year period, and when you sum across months with net negative revenues, total losses are about $90 million. Much of these losses can be attributed to the units’ owners (Duke Energy Kentucky and Kentucky Power Company) forcing these units to run uneconomically.

Link to Report

Return to Our Work

Comments on Rhode Island's Draft Least Cost Procurement Standards

Client: Conservation Law Foundation (CLF)

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

June 2026

On behalf of Conservation Law Foundation, Principal Economist Dr. Elizabeth A. Stanton and Senior Researcher Joshua R. Castigliego provided expert comments in Docket No. 26-15-EE on the proposed amendments to the Rhode Island Public Utilities Commission's Least Cost Procurement (LCP) Standards. In their comments, Dr. Stanton and Mr. Castigliego discuss several issues pertaining to the proposed amendments, including: (i) concerns regarding changes to the definitions of Cost of Supply and Cost of Energy Efficiency or Conservation; (ii) provisions related to the Demand Side Management Investment Proposal; and (iii) additional issues raised by other stakeholders in their comments on the proposed amendments. Dr. Stanton and Mr. Castigliego recommend revisions to ensure consistency with the Rhode Island Benefit Cost Test (RI Test) framework, improve clarity and comprehensiveness of the LCP Standards, and strengthen the evaluation of demand-side management investments and their associated costs and benefits.

Link to Comments

Return to Our Work

Sierra Club Comments on the Commission's Draft Integrated Resource Planning Rule in Missouri

Client: Sierra Club

Authors: Liz Stanton, PhD and Joshua R. Castigliego

June 2026

AEC assisted Sierra Club with its submission of Comments on the Missouri Public Service Commission’s draft Integrated Resource Planning (IRP) Rule in File No. EW-2026-0091. Sierra Club’s comments propose revisions to strengthen the IRP process by increasing transparency, clarifying regulatory requirements, enhancing stakeholder participation and access to information, and promoting more robust, data-driven utility planning.

Link to Comments

Return to Our Work

Risks of New Gas-Fired Plants in Southeastern States

Client: Southern Environmental Law Center (SELC)

Authors: Tanya Stasio, PhD, Joshua R. Castigliego, and Elisabeth Seliga

June 2026

Across the Southeastern United States, rising electric demand and ongoing reliability challenges are prompting utilities to propose new gas-fired resources to help meet future system needs. At the same time, regulators are looking for solutions to provide greater energy affordability in the face of high electricity and fuel costs. Major investments in gas-fired power plants, pipelines, and related facilities put customers at risk for increasing electric rates and energy bills. This Applied Economics Clinic (AEC) report, prepared on behalf of Southern Environmental Law Center (SELC), identifies eight risks to electric utility customers that could cause higher energy rates and bills:

1. Growing cost of gas-fired power plants

2. Supply chain constraints

3. Volatile and uncertain gas fuel prices

4. Lack of resource diversity

5. Dependence on out-of-state gas supply

6. Stranded assets due to uncertain forecasts

7. Stranded assets due to more stringent climate policy

8. Stranded assets from existing or more stringent environmental regulations

To ensure that customers’ electric bills remain affordable, while also considering how states will adapt to the region’s anticipated growth in electric demand, policymakers, regulators, and utilities must assess whether pursuing additional gas-fired resources would expose ratepayers to unnecessary risk.

Link to Report

Return to Our Work

Testimony on DTE Electric Company's Request for Expedited Approval of the Company’s Special Contracts with Google LLC

Client: Michigan Environmental Council, Natural Resources Defense Council, and Sierra Club

Authors: Bryndis Woods, PhD

June 2026

On behalf of Michigan Environmental Council, Natural Resources Defense Council, and Sierra Club, Principal Analyst Dr. Bryndis Woods filed testimony before the Michigan Public Service Commission regarding DTE Electric Company's Request for expedited approval of the Company’s "Special Contracts" with Google LLC to serve Google's planned 1.0 gigawatt data center facility in Van Buren Township, Michigan, which is scheduled to begin taking electric service from DTE in December 2027.

Dr. Woods’ direct testimony focuses on the Company’s proposed renewable energy and energy storage buildouts, issues with the Company’s customer benefit analysis, and provides recommendations to help ensure that the Company meets (1) its renewable energy and energy storage capacity goals consistent with utility planning best practices and (2) its Renewable Portfolio Standard obligations. Dr. Woods’ testimony also recommends that certain issues should not be decided in this case, such as cost allocations or resource predeterminations.

Link to Testimony

Return to Our Work

Low-to-Moderate Income Emissions Reductions in Massachusetts: A Marginal Cost of Abatement Analysis

Client: Green Energy Consumers Alliance (GECA)

Authors: Sagal Alisalad, Joshua R. Castigliego, Liz Stanton, PhD

May 2026

On behalf of Green Energy Consumers Alliance (GECA), Researcher Sagal Alisalad, Senior Researcher Joshua R. Castigliego, and Principal Economist Liz Stanton, PhD, prepared a report analyzing the costs of low-to-moderate income (LMI) emissions reductions measures in Massachusetts. AEC staff assessed LMI-specific emissions reduction measures that could be implemented in Massachusetts by 2030 and developed a marginal abatement cost curve showing eight measures from lowest to highest cost. AEC’s analysis found that the eight measures would reduce emissions by 0.2 million metric tons (MMT) in 2030, about 7 percent of the 2.9 MMT needed to meet the Commonwealth’s 2030 climate targets, and that the eight measures total 2.8 MMT of lifetime CO2e reductions and have a net societal benefit, or cost savings, of $7.3 billion.

Link to Report

Return to Our Work

Electrification with Equity, Part 2: Scaling Behind-the Meter Solar and Storage in Massachusetts Environmental Justice Communities

Clients: Clean Energy Group, Union of Concerned Scientists, and Vote Solar

Authors: Tanya Stasio, PhD and Elisabeth Seliga

May 2026

Massachusetts electric demand is expected to increase substantially by 2050, creating the need for additional electric generating capacity. Deployment of on-site or behind-the-meter (BTM) solar and BTM solar paired with storage in allows customers to generate and store their own clean energy, which in turn can lower peak electric demand, reduce the need for additional investments in expensive gas-fired power plants, and provide households and businesses with energy bill savings, increased resilience, and energy autonomy. Increasing BTM deployment in the Commonwealth’s low-income and environmental justice neighborhoods, will advance its commitment to an equitable clean energy transition and direct clean energy and storage benefits where its needed most.

On behalf of Clean Energy Group, Union of Concerned Scientists, and Vote Solar, AEC Senior Researcher Tanya Stasio, PhD and Assistance Researcher Elisabeth Seliga prepared a report that estimates the technical potential for BTM solar paired with storage in Massachusetts environmental justice neighborhoods using solar technical potential estimates from the 2023 Massachusetts Department of Energy Resources’ Technical Potential of Solar Study. In addition, this report, through original analysis and input from an environmental justice advisory committee, identifies nine primary barriers to solar and storage adoption and advances 18 recommendations to address these barriers and help realize BTM solar and storage potential in Massachusetts’ environmental justice neighborhoods. In Electrification with Equity, Part 1, linked below, AEC estimates Massachusetts statewide “highly suitable” technical potential for BTM solar paired with storage.

Link to Report

Link to Electrification with Equity, Part 1 Report

Return to Our Work

Electrification with Equity, Part 1: The Opportunity for Behind-the-Meter Solar and Storage in Massachusetts

Clients: Clean Energy Group and Vote Solar

Authors: Tanya Stasio, PhD, Elizabeth A. Stanton, PhD and Joshua R. Castigliego

May 2026

Massachusetts electric demand is expected to increase substantially by 2050, creating the need for additional electric generating capacity. Behind-the-meter (BTM) solar and solar paired with storage resources provide an opportunity for meeting this demand while reducing energy bills for customers, increasing renewable energy integration, and improving grid resiliency. On behalf of the Clean Energy Group and Vote Solar, AEC Senior Researcher Tanya Stasio, PhD, Principal Economist Elizabeth A. Stanton, PhD, and Senior Researcher Joshua R. Castigliego prepared a report that estimates the technical potential for BTM solar and solar paired with storage and the opportunity for these distributed energy resources to reduce expected increases in Massachusetts’ peak electric demand.

Link to Report

Link to Electrification with Equity, Part 2 Report

Return to Our Work

Savings from Coal to Gas Conversion: Florida’s Northside 1 and 2

Client: Sierra Club

Author: Liz Stanton, PhD, Joshua R. Castigliego, Jordan Burt, PhD, and Bryndis Woods, PhD

April 2026

AEC-2026-04-WP-01

On behalf of Sierra Club, Principal Economist Elizabeth A. Stanton, PhD, Senior Researcher Joshua R. Castigliego, Researcher Jordan Burt, PhD, and Principal Analyst Bryndis Woods, PhD, prepared a white paper that investigates the potential cost savings associated with transitioning JEA’s Northside Generation Station to retire its coal-fired operations and run exclusively on natural gas. Using a simple model of annual expenses and revenues at the unit for the period 2026 to 2035, AEC compared net costs under a “business-as-usual” scenario in which the operations of recent historical years continue into the future with a “gas conversion” scenario in which full-time gas operations commence in 2030. Over the 10-year modeling period, elimination of all coal operations at Northside Units 1 and 2 result in a total savings of $122.8 million, or $51.9 million at Northside Unit 1 and $70.9 million at Unit 2. Northside Unit 1’s levelized costs fall by $11.4 per MWh and Unit 2’s by $8.5 per MWh.

A cost savings opportunity of this magnitude—approximately 12 percent reduction from current Northside 1 and 2 costs—deserves careful and transparent examination. Utility decisions regarding capital investments, maintaining aging infrastructure, and day-to-day operations must consider affordability and keep an open mind to new options for lowering costs. To achieve a successful conversion at Northside Units 1 and 2, AEC recommends that JEA conduct and publicly share a comparative analysis of its future operations (including all fixed, variable, and capital costs and financing) under current mixed fuel operations and under all gas operations. All assumptions, data, and methodologies should be fully transparent and made publicly available, and JEA’s analysis should also assess the conversion’s impact on rates and customer bills.

Link to White Paper

Return to Our Work

Savings from Coal to Gas Conversion: Florida’s Deerhaven 2

Client: Sierra Club

Author: Liz Stanton, PhD, Joshua R. Castigliego, Jordan Burt, PhD, and Bryndis Woods, PhD

April 2026

AEC-2026-04-WP-02

On behalf of Sierra Club, Principal Economist Elizabeth A. Stanton, PhD, Senior Researcher Joshua R. Castigliego, Researcher Jordan Burt, PhD, and Principal Analyst Bryndis Woods, PhD, prepared a white paper that investigates the potential cost savings associated with transitioning Gainesville Regional Utilities’ (GRU) Deerhaven Generation Station to retire its coal-fired operations and run exclusively on natural gas. Using a simple model of annual expenses and revenues at the unit for the period 2026 to 2035, AEC compared net costs under a “business-as-usual” scenario in which the operations of recent historical years continue into the future with a “gas conversion” scenario in which full-time gas operations commence in 2030. Over the 10-year modeling period, elimination of all coal operations at Deerhaven Unit 2 results in a total savings $31.3 million (or a reduction in levelized costs of $7.4 per MWh).

A cost savings opportunity of this magnitude—approximately a 7 percent reduction from current Deerhaven Unit 2 costs—deserves careful and transparent examination. Utility decisions regarding capital investments, maintaining aging infrastructure, and day-to-day operations must consider affordability and keep an open mind to new options for lowering costs. To achieve a successful conversion at Deerhaven Unit 2, AEC recommends that GRU conduct and publicly share a comparative analysis of its future operations (including all fixed, variable, and capital costs and financing) under current mixed fuel operations and under all gas operations. All assumptions, data, and methodologies should be fully transparent and made publicly available, and GRU’s analysis should also assess the conversion’s impact on rates and customer bills.

Link to White Paper

Return to Our Work

Rhode Island Heat Pump Rate “RI Test” Report

Client: Conservation Law Foundation and Environmental Defense

Author: Elizabeth A. Stanton, PhD, Joshua R. Castigliego, and Jordan Burt, PhD

April 2026

On behalf of Conservation Law Foundation and Environmental Defense, Principal Economist Elizabeth A. Stanton, PhD, Senior Researcher Joshua R. Castigliego, and Researcher Jordan Burt, PhD, prepared a report assessing the results of a “Rhode Island Benefit Cost Test” (RI Test) cost-benefit analysis comparing the monetized costs and benefits of a new heat pump electric rate proposed in Rhode Island Public Utility Commission Docket No. 25-45-GE.

AEC found that the net impact of a heat pump rate is a system-wide cost savings of $11.9 million, or benefit to cost ratio of 1.3. The proposed residential heat pump rate shows greater benefits than costs under the RI Test methodology.

Link to Report

Testimony on the Proposed Rhode Island Residential Heat Pump Rate

Return to Our Work

Testimony on the Proposed Rhode Island Residential Heat Pump Rate

Client: Conservation Law Foundation and Environmental Defense

Author: Elizabeth A. Stanton, PhD 

April 2026

On behalf of the Conservation Law Foundation and Environmental Defense, Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Rhode Island Public Utilities Commission describing the methodology and results of the benefit-cost analysis “RI Test” performed on the proposed Rhode Island residential heat pump rate in Docket No. 25-45-GE. Dr. Stanton found that the net impact of a heat pump rate is a system-wide cost savings of $11.9 million, or benefit to cost ratio of 1.3. The proposed residential heat pump rate shows greater benefits than costs under the RI Test methodology.

Link to Direct Testimony

Rhode Island Heat Pump Rate “RI Test” Report

Return to Our Work

Comments Regarding STREAM’s Proposed Data Center

Client: Tonawanda Seneca Nation and Sierra Club Niagara Group

Author: Bryndis Woods, PhD 

April 2026

In January 2026, STREAM U.S. Data Centers, LLC (STREAM) applied to the Genesee County Economic Development Center to construct a 2.2 million square-foot data center campus in the Town of Alabama, New York, located in Genesee County. On behalf of Tonawanda Seneca Nation and Sierra Club Niagara Group, Senior Analyst Dr. Bryndis Woods drafted comments that address STREAM’s proposed data center, including its claimed costs and benefits for the local community. STREAM does not provide any supporting materials for its cost-benefit analysis (CBA), which fails to meet standards expected in a public decision-making process and is insufficient to determine whether the proposed project would provide net benefits for the local community.

Other key findings include:

• The project would require electric capacity that is about four times the total capacity currently operating in Genesee County.

• STREAM’s CBA results differ substantially from one CBA to the next.

• STREAM has failed to address numerous potential costs associated with the project.

• STREAM’s job creation estimates exceed values found in publicly available data and information.

• STREAM has requested tax abatements that are worth 25 times more than the benefits provided by the proposed PILOT/Host payments.

• Valuing data centers is challenging and complex.

• STREAM’s proposed data center may negatively impact local tourism and recreation, which are an integral part of the community and economy.

Errata:

On page 12 of the comments, it states that: "Empire State Development of New York State’s 2024 Tourism Economics Report found that, in Genesee County, visitors spent $144.5 million in 2024, generating about $331.1 million in direct personal income for county residents, creating about 11,000 direct jobs and about 5,000 indirect jobs, and generating $8.8 million in local tax revenue—equal to $665 in tax savings per household." This should read: "Empire State Development of New York State’s 2024 Tourism Economics Report found that, in Genesee County, visitors spent $144.5 million in 2024, generating about $46.8 million in direct personal income for county residents, creating 1,850 direct jobs and generating $8.8 million in local tax revenue—equal to $665 in tax savings per household." 

Link to Comments

Return to Our Work

Background Report: Evaluation of Connecticut Medical Protections

Client: Connecticut Public Utilities Regulatory Authority

Authors: Tanya Stasio, PhD, Sagal Alisalad, Elizabeth A. Stanton, PhD, Jordan Burt, PhD, Joshua R. Castigliego, and Bryndis Woods, PhD 

March 2026

On behalf of Connecticut Public Utilities Regulatory Authority, Senior Researcher Tanya Stasio, PhD, Researcher Sagal Alisalad, Principal Economist Liz Stanton, PhD, and AEC staff prepared a background report that evaluates Connecticut's electric and gas utility shutoff policies for medically protected customers. Most of Connecticut's medically protected customers have year-round shutoff protection and, as a result, maintain average arrearages that are thousands of dollars more than customers without medical protections. While limiting shutoff protections may increase utility revenues and reduce ratepayer costs, AEC finds that introducing payment or financial hardship requirements to Connecticut shutoff protections for medically protected customers could cost the State of Connecticut millions by way of increased need for social services. 

This report was included as an Appendix to Connecticut Public Utilities Regulatory Authority's Report to the General Assembly Regarding the Evaluation of Medical Protection available here.

Link to Report

Return to Our Work

Assessing Ratepayer Risks of the Proposed Edisto Gas Plant in South Carolina

Client: Conservation Voters of South Carolina (CVSC)

Authors: Joshua R. Castigliego, Elisabeth Seliga, Jordan Burt, PhD, Sagal Alisalad, and Bryndis Woods, PhD

March 2026

On behalf of the Conservation Voters of South Carolina (CVSC), Senior Researcher Joshua R. Castigliego, Assistant Researcher Elisabeth Seliga, Researchers Jordan Burt, PhD and Sagal Alisalad, and Principal Analyst Bryndis Woods, PhD prepared a report that evaluates Santee Cooper and Dominion Energy South Carolina’s December 2025 Joint Application to build a new jointly owned, 2,180-MW natural gas-fired combined cycle generating facility—the proposed “Edisto Gas Plant” or Canadys Joint Resource—on the banks of the Edisto River. The report examines the risks that the project could pose to South Carolina ratepayers if approved by the South Carolina Public Service Commission.

In the report, AEC identifies three primary risks to ratepayers (i.e. the potential for electric customers to face higher costs) as a result of new gas-fired capacity like the proposed Edisto Gas Plant to meet increasing electric demand: (1) uncertain forecasts of customer demand, which could leave ratepayers paying for unused capacity; (2) higher-than-expected capital costs, including from construction delays and cost overruns; and (3) fuel price uncertainty, which can increase operating expenses and, ultimately, electric rates and customer bills. AEC's review of the Companies’ Joint Application reveals several significant concerns related to these risks.

Understanding risks to South Carolina ratepayers, individually and collectively, underscores the importance of prudent utility planning and the need for the Commission to carefully consider whether approving the Companies’ Joint Application for the proposed Edisto Gas Plant would expose ratepayers to unnecessary risk, particularly when alternative, lower-risk pathways may exist that the Companies have not fully evaluated.

Link to Report

Return to Our Work