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.