DTE Electric Company IRP

Clients: Michigan Environmental Council (MEC), Natural Resources Defense Council (NRDC), Sierra Club (SC) and Citizens Utility Board of Michigan

Author: Tyler Comings

April 2023

Senior Researcher Tyler Comings filed testimony before the Michigan Commission on DTE Electric Company's Integrated Resource Plan (IRP). Mr. Comings argued that two of the Monroe coal should be retired in 2032, as opposed to 2035 in DTE's plan. He helped develop an alternative plan that included earlier retirement of the coal units with clean replacement resources which was cheaper than DTE's plan.

 Link to Direct Testimony

Link to Rebuttal

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Ameren Missouri Rate Case

Photo Credit: Missouri Department of Natural Resources

Client: Sierra Club

Author: Tyler Comings

April 2023

Senior Researcher Tyler Comings filed testimony before the Missouri Commission on Ameren Missouri's rate case. Mr. Comings argued that Ameren should be considering earlier retirement of its coal units, especially given pending environmental regulations and lower-cost clean replacement options. He also recommended that Ameren be asked to identify capital costs that could be avoided should they be retired earlier than currently planned.

 Link to Testimony

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Testimony on Indiana Michigan Power IRP

Client: Sierra Club

Author: Senior Researcher Tyler Comings

Senior Researcher Tyler Comings filed testimony before the Michigan Commission on the Indiana Michigan Power (I&M) Integrated Resource Plan (IRP). Mr. Comings found several major flaws with I&M's calculations which unfairly biased the results in favor of keeping its contracted power from some of the oldest coal units in the U.S. He also argued that this contract should be re-evaluated and that, in the event of its termination, related costs should not be passed on to ratepayers.

Link to Testimony

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Entergy Louisiana IRP Comments

Author: Tyler Comings

July 2022

AEC Senior Researcher Tyler Comings co-authored comments (along with Sierra Club) on Entergy Louisiana's Integrated Resource Plan (IRP). The comments ask Entergy to include more reasonable costs for renewable and storage resources, to model more early retirement options for its coal units, and fully capture the costs of using hydrogen fuel.

Link to Comments

Link to Comments on Draft IRP

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Background Report: Benefits of Coal Ash Cleanup and Remediation

Client: Earthjustice

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

July 2021

On behalf of Earthjustice, Researcher Joshua Castigliego, Senior Researcher Tyler Comings, Assistant Researcher Sagal Alisalad, and Senior Economist Liz Stanton, PhD prepared a report outlining the benefits of coal ash cleanup and remediation at three power plants: Montana’s Colstrip Steam Electricity Station, South Carolina’s Grainger Generating Station, and Indiana’s Michigan City Generating Station.

AEC staff found that the more complete and more effective cleanup scenarios with full excavation of coal ash in contact with groundwater and contaminated soils results in more than double the jobs compared to the less effective cleanup plans. In all three case studies, workers’ income and local economic activity follow this same pattern with more stringent clean up protocols resulting in greater benefits for both workers and the community.

Following release of this report, on August 6, 2021, Michigan City Council passed a unanimous resolution supporting the more stringent coal ash cleanup option. Read the resolution below.

Link to Report

Link to Earthjustice Publication

Link to Press Release

Link to Resolution

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Testimony on Harrison and Fort Martin Coal Units in West Virginia

Source: Charleston Gazette-Mail

Client: Earthjustice

Author: Tyler Comings

December 2020

AEC Senior Researcher Tyler Comings testified before the West Virginia Public Service Commission on the economics of the Fort Martin and Harrison coal units. Mr. Comings found that the costs of the units would likely exceed their market value, and therefore the units should be subjected to a forward-looking analysis prior to any further investments. He also recommended that the owner of the units be required to report on the impact of their coal contract obligations on the operating decisions.

Link to Testimony

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Testimony on Dominion Energy South Carolina's 2020 Rate Case

Source: The Times and Democrat

Client: Sierra Club

Author: Liz Stanton, PhD

On behalf of Sierra Club, Clinic Director and Senior Economist Liz Stanton, PhD provided expert testimony to Dominion Energy South Carolina’s 2020 Rate Case (Docket No. 2020-125-E) before the Public Service Commission of South Carolina. In her testimony, Dr. Stanton evaluated the economics of the coal-fired units owned by Dominion and assessed the degree to which both recovery of capital costs incurred at the Wateree, Williams, and Cope plants during the period from 2012 through 2019 and continued investment in and operation of these units in the future are just and reasonable.

Her recommendations to the Public Service Commission of South Carolina for the Wateree, Williams, and Cope plants included a cap on future capital expenditures intended to prolong the lives of the coal units, as well as requiring DESC to seek approval of any expenditure that exceeds that cap before that expenditure can be recovered from ratepayers.

Link to Testimony

Link to Surrebuttal

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Testimony on Four Corners Coal Units in Arizona

Source: The Durango Herald

Client: Sierra Club

Author: Tyler Comings

October 2020

(Updated: December 2020)

AEC Senior Researcher Tyler Comings filed testimony in Arizona on the economics of the Four Corners Units 4 and 5. Mr. Comings found that Arizona Public Service (APS) has repeatedly failed to justify continued investment in the units, and that the units should be retired sooner than currently planned. Mr. Comings analysis showed that there would be substantial savings to ratepayers if the units were to retire in 2023. 

Link to Testimony

Link to Surrebuttal (December 2020)

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Testimony on Consumers Energy's 2020 Rate Case

Source: MiBiz

Client: Michigan Environmental Council, Natural Resources Defense Council, Sierra Club, and Citizens Utility Board of Michigan

Author: Tyler Comings

June 2020

On behalf of Michigan Environmental Council, Natural Resources Defense Council, Sierra Club, and Citizens Utility Board of Michigan, Senior Researcher Tyler Comings filed testimony on the Consumers Energy rate case in Michigan. Mr. Comings evaluated the economics of two coal units, Campbell Units 1 and 2. He concluded that the units should be considered for retirement and that future spending that could be avoided with earlier retirement should be disallowed. He also found that other spending should be disallowed because the company failed to provide sufficient documentation for those projects. 

Link to Testimony

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A Whole New Ballgame: Indiana Coal and the New Energy Landscape

Client: Citizens Action Coalition of Indiana

Authors: Liz Stanton, PhD, Bryndis Woods, Joshua Castigliego, Eliandro Tavares and Sagal Alisalad

February 2020

Clinic Director and Senior Economist Liz Stanton, PhD, Researchers Bryndis Woods and Joshua Castigliego and Assistant Researchers Eliandro Tavares and Sagal Alisalad prepared a report on behalf of the Citizens Action Coalition of Indiana that responds to several myths that persist regarding claimed benefits of aging coal-fired generators over renewable wind and solar. The report finds that legacy power generation sources like coal are characterized by a lack of flexibility, making them costly and inconvenient to integrate with more modern renewables.

Link to Report

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Testimony on Indiana Michigan Power Company's Integrated Resource Plan

Client: Earthjustice

Author: Tyler Comings

January 2020

AEC Senior Researcher Tyler Comings filed testimony on behalf of Sierra Club on the Indiana Michigan Power Company (I&M) Integrated Resource Plan (IRP) in Michigan, focusing on two coal units (Rockport 1 and 2). Mr. Comings found that I&M was justified in proposing retirement  of Rockport 1 in 2028 and letting its lease expire for Rockport 2 in 2022. Mr. Comings found that there was additional savings from retiring the Rockport 1 unit even earlier than I&M was proposing: 2025 instead of 2028. He also recommended additional Commission oversight of the Company's share of output from the Kyger Creek and Clifty Creek coal units.

Link to Testimony

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Testimony on the Public Service Company of New Mexico's (PNM) Plan for Replacing the San Juan Coal Units

Aerial photo of San Juan Generating Station, by Doc Searls

Client: Coalition for Clean Affordable Energy (CCAE)

Author: Tyler Comings

December 2019

AEC Senior Researcher Tyler Comings filed testimony on behalf of the Coalition for Clean Affordable Energy (CCAE) on Public Service Company of New Mexico's (PNM) plan for replacing the San Juan coal units with new resources. Mr. Comings testified that CCAE's replacement plan was a viable alternative and would invest more in the existing San Juan region than PNM's replacement plan. Mr. Comings also testified to flaws in PNM's resource evaluation that were addressed in developing CCAE's plan.

Link to Testimony

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Testimony on Duke Energy Indiana's Coal Fleet

Client: Sierra Club

Tyler Comings

November 2019

Senior Researcher Tyler Comings filed testimony on the cost of Duke Energy Indiana’s coal fleet in Cause No. 45253 before the Indiana Utility Regulatory Commission. Mr. Comings concluded that the Edwardsport plant was uneconomic and should be retired as soon as possible. He also recommended disallowances of costs associated with the coal fleet, a requirement for evaluating earlier retirement of the units, and that the Commission open an investigation into Duke’s “self-commitment” of its coal units and the practice's impact on customers.

Link to Testimony

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A Future for Indiana Coal: Emissions and Costs of Alternative Electric Generation

Client: Citizens Action Coalition of Indiana

Authors: Bryndis Woods and Liz Stanton, PhD

October 2019

Researcher Bryndis Woods and Clinic Director and Senior Economist Liz Stanton, PhD prepared a report on behalf of the Citizens Action Coalition of Indiana that examines the cost and emission impacts of various options available to the State of Indiana as it replaces its aging coal generation fleet with other electric-generating resources. The report finds that: replacing aging coal with renewables reduces emissions and saves money and that gas-fired resources do not provide clear benefits as a bridge to greater renewables.

Link to Report

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Risks Growing for India’s Coal Sector

Client: Institute for Energy Economics and Financial Analysis (IEEFA)

Authors: Bryndis Woods and David Schlissel (IEEFA)

September 2019

Researcher Bryndis Woods and Director of Resource Planning Analysis at the Institute for Energy Economics and Financial Analysis (IEEFA) David Schlissel prepared a report that presents three major risks confronting India’s coal sector:

(1)   The over-building of coal-fired capacity. The boom in coal plant construction during the early 2010s has resulted in significant over-capacity. The amount of installed coal-fired capacity in India is now 20 percent higher than the country’s peak demand level and fully 50 gigawatts (GW) above average demand levels.

(2)   Increasing competition from renewable energy sources, particularly during the monsoon season. Low-cost renewable wind and hydro energy sources have a great advantage during the monsoon season, when coal generation dips while wind and hydro generation peak.

(3) Declining water supplies. Groundwater levels across India are in decline. Since 2012, both total annual rainfall and monsoon rainfall have generally been below normal levels ‒ a major concern for coal generation, which requires substantial amounts of water for steam production and cooling.

The report concludes that these risks are already manifesting, and will intensify in the years ahead. As a result, Indian policy makers should: agree not to built additional coal-fired plants; review plants under construction for possible cancellation; conduct an economic assessment of the nation’s oldest coal-fired power plants to determine their financial viability; and address coal capacity in the most drought-stricken as a priority.

Link to Report

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Testimony on Sooner Coal Plant Scrubbers

Source: The Oklahoman

Client: Sierra Club

Author: Tyler Comings

April 2019

On behalf of Sierra Club, Senior Researcher Tyler Comings provided testimony on the prudence of Oklahoma Gas and Electric (OG&E's) investment in scrubbers for its Sooner coal plant. Mr. Comings testified that OG&E was imprudent in choosing the scrubber investment in 2014 and also imprudent in not updating the analysis underlying that decision when new facts became available.

Link to Testimony

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Comments on Southwestern Electric Power Company's Draft 2019 Integrated Resource Plan

SWEPCO John W. Turk Jr. Power Plant

Source: Power Engineering

Client: Sierra Club

Authors: Sierra Club with assistance from AEC (Tyler Comings, Bryndis Woods, Ricardo Lopez, PhD, and Eliandro Tavares)

April 2019

Senior Researcher Tyler Comings, Researcher Bryndis Woods, Senior Researcher Ricardo Lopez and Assistant Researcher Eliandro Tavares assisted Sierra Club in comments on Southwestern Electric Power Company (SWEPCO)’s Draft 2019 Integrated Resource Plan. The Sierra Club concluded that SWEPCO's analysis was biased in favor keeping coal assets on-line and failed to evaluate economics of its existing resources.

Link to Comments

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Duke Energy Integrated Resource Plans in North Carolina

Client: Southern Environmental Law Center

Authors: Tyler Comings, Bryndis Woods, Liz Stanton, PhD, and Eliandro Tavares

March 2019

Senior Researcher Tyler Comings, Researcher Bryndis Woods, Director and Senior Economist Liz Stanton, PhD and Assistant Researcher Eliandro Tavares prepared a report on Duke Energy's 2018 Integrated Resource Plans (IRPs) in North Carolina on behalf of Southern Environmental Law Center and its clients, Natural Resources Defense Council, Southern Alliance for Clean Energy and the Sierra Club. AEC concluded that Duke has failed to evaluate the economics of its coal units, even though many are operating infrequently, and has not encouraged competition from other resources. As a result, AEC found Duke's plans to be flawed and incomplete.

August 2019 Update: Based in part on AEC comments, North Carolina Utilities Commission orders Duke Energy to re-evaluate coal units in 2020 IRPs.

AEC's comments (prepared for Natural Resources Defense Council, the Sierra Club and the Southern Alliance for Clean Energy) stated that Duke's IRP analysis: "...fails to consider whether existing resources can be cost effectively replaced with new resources. Therefore, Duke has not performed a least-cost analysis to design its recommended plans.” The Commission agreed, stating that: "It does not appear from the information in the IRPs that DEC and DEP have fully considered early retirement of any of these coal plants by replacing their contributions with other alternative generation resources or with energy efficiency (EE) and demand-side management (DSM) resources."

The order is available here.

Link to Review

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Testimony on Consumers Energy Integrated Resource Plan (IRP)

Consumers Energy J.H. Campbell coal plant, Source: mlive.com

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

Author: Tyler Comings

October 2018

Senior Researcher Tyler Comings filed testimony on the Consumers Energy IRP in Michigan. Mr. Comings concluded that Consumers did not adequately evaluate the potential for retiring two coal units, Campbell 1 and 2, prior to 2031. He found that the Company failed to consider enough replacement options for the units as part of its preferred plan. Modeling requested by Mr. Comings (run by Witness George Evans) showed that retirement of the two units in 2023 would save ratepayers money. 

Link to Testimony

Link to Rebuttal Testimony

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Testimony on the Economics of Karn Coal Units in Michigan

Source: Power Engineering

Clients: Michigan Environmental Council, the Natural Resources Defense Council, and Sierra Club

Tyler Comings

September 2018

On behalf of Michigan Environmental Council, the Natural Resources Defense Council, and Sierra Club, Senior Researcher Tyler Comings testified on two coal units (Karn 1 and 2) as part of the Consumers Energy rate case in Michigan. Mr. Comings concluded that non-essential capital investments for Karn Units 1 and 2 should be denied by the Commission. He discussed that the units have been shown to be uneconomic in past analyses performed by Consumers Energy and delaying a retirement decision would only cost ratepayers more.

Link to Testimony

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