Testimony on Dominion's 2023 Integrated Resource Plan

Client: Clean Virginia

Author: Bryndis Woods, PhD

August 2023

Senior Researcher Bryndis Woods, PhD filed testimony before the Virginia State Corporation Commission on Virginia Electric and Power Company’s (“Dominion”) 2023 Integrated Resource Plan (IRP). Dr. Woods' testimony addresses failures by Dominion in its 2023 IRP to:

• Meet the basic obligations of the Virginia Clean Economy Act including energy efficiency requirements, renewable energy requirements and fossil fuel retirement requirements;

• Present useful modeling results: the Company fails to identify a preferred plan, a feasible least-cost plan, or present meaningfully distinct modeling results over the planning period;

• Conduct a peak load sensitivity analysis that adequately accounts for uncertainties related to Dominion's load forecast, particularly anticipated load from data centers;

• Account for federal regulations that impact its coal fleet or consider a reasonable social cost of carbon; or

• Address environmental justice impacts of its resource planning decisions or conduct any stakeholder engagement as part of the 2023 IRP development.

As a result of these failures, Dr. Woods concludes that the Commission cannot find Dominion’s 2023 IRP to be reasonable and in the public interest, and provides specific recommendations for the Company’s IRPs moving forward.

Link to Direct Testimony

Link to Testimony Corrections

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The Interconnection Bottleneck: Why Most Energy Storage Projects Never Get Built

Image Credit: Sara Levine | Pacific Northwest National Laboratory

Client: Prepared on behalf of Clean Energy Group

Authors: Chirag Lala, Jordan Burt, Sachin Peddada

May 2023

On behalf of the Clean Energy Group, Researcher Chirag Lala and Assistant Researchers, Sachin Pedadda and Jordan Burt prepared a report that assesses the obstacles preventing efficient interconnection of distributed energy storage resources. This Applied Economics Clinic (AEC) white paper identifies and explains these interconnection barriers in Massachusetts and makes recommendations to state agencies and working groups overseeing interconnection, distribution utilities, independent system operators, and the Federal Energy Regulatory Commission.  

AEC staff make these five key recommendations to stakeholders: (1) Develop proactive, integrated, and system-wide interconnection planning that takes a systemic view of applications and separates hosting capacity upgrades from particular project or cluster applications and makes hosting capacity upgrades in anticipation of grid-needs and future interconnection volume. (2) Continuously iterate interconnection processes to build in regular improvements, examine effectiveness, and coordinate public and private stakeholders to tackle ad hoc coordination problems. (3) Tackle barriers and solutions comprehensively by integrating multiple solutions. (4) End cost causation by spreading distribution system upgrade costs over a broader set of stakeholders (including ratepayers) than just allocating those costs to the projects or clusters applying for interconnection. (5) Incorporate storage operational parameters into interconnection processes so that storage resources are assessed in a manner reflecting how they would reasonably be expected to operate once interconnected alone or in conjunction with technologies regulating bidirectional power flows and facilitating predictable charging and discharging.

Link to Report

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Massachusetts MLPs Exemption from RPS: Impacts on Clean Energy

Client: Prepared on behalf of Massachusetts Climate Action Network

Authors: Tanya Stasio, PhD, Elisabeth Seliga, Liz Stanton, PhD

April 2023

On behalf of the Massachusetts Climate Action Network, Researcher Dr. Tanya Stasio, Assistant Researcher Elisabeth Seliga, and Senior Economist Dr. Liz Stanton prepared a presentation on the Massachusetts Municipal Light Plant (MLP) exemption from the Renewable Portfolio Standard (RPS) and the impact on clean energy in the Commonwealth. AEC finds that the MLP Greenhouse Gas Emissions Standard, and the RPS exemption, allow MLPs to remain at today's level of Class I renewable energy sources, resulting in substantially less clean energy in the Commonwealth than if MLPs were required to comply with the RPS.

This work was presented at the April 19th, 2023 MCAN Legislative Launch titled, "Advancing Clean Energy, Equity, and Innovation in Municipal Utilities." For more information, or to watch the recording of the event, visit the MCAN website here.

Link to Presentation

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Recommendations for Cities and States to Improve Equity Evaluation and Reporting in Energy Efficiency Programming

Client: American Council for an Energy-Efficient Economy (ACEEE)

Authors: Bryndis Woods, PhD, Liz Stanton, PhD, and Sagal Alisalad

October 2021

On behalf of the American Council for an Energy-Efficient Economy (ACEEE), this Applied Economics Clinic white paper recommends measures that cities and states can undertake to facilitate equitable energy efficiency evaluation and reporting of energy efficiency efforts, based on the results of our review of low-income energy efficiency efforts in ACEEE’s top-scoring cities and states in their 2020 City and State energy efficiency scorecards.

We find that the cities and states most highly-rated for energy efficiency offer programs for low-income community members, but fail to take critical actions necessary for equitable evaluation and reporting to facilitate equitable outcomes. Based on our review of these programs, we find that—while these programs have made important progress on addressing equity concerns by offering efficiency programming specifically to low-income households—more robust energy efficiency evaluation and reporting are needed to shine a light on city and state equity-focused energy efficiency programming and ensure that efficiency benefits are equitably distributed. We recommend three main improvements that would drastically enhance the ability to evaluate these programs for their equity-related impacts:

• Mandate disaggregated efficiency program performance reporting;
• Identify, track, and target vulnerable populations; and
• Integrate energy efficiency, climate, and equity planning and reporting.

Link to Report

Link to ACEEE's Leading with Equity Initiative White Paper

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Consumers Energy Rate Case Testimony

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

Author:
Tyler Comings

June 2021

AEC Senior Researcher Tyler Comings filed testimony on the Consumers Energy 2021 rate case in Michigan. Mr. Comings analyzed the economics of coal units Campbell 1 and 2, concluding that they should be considered for retirement in 2024 or 2025. He also recommended that certain capital costs not be allowed in rates because they could be avoided if the units were to retire in those years. (Subsequent to Mr. Comings' testimony, Consumers Energy announced a plan to retire all of its coal units by 2025.)

Link to Testimony

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Benefits of Net Zero Buildings for the Town of Bedford

Client:
Facilities Department of the Town of Bedford, MA

Authors:
Bryndis Woods, PhD and Joshua R. Castigliego

June 2021

On behalf of the Facilities Department of the Town of Bedford, Massachusetts, Senior Researcher Bryndis Woods, PhD and Researcher Joshua R. Castigliego prepared a report outlining the Town’s climate and energy goals and how investments in Net Zero and Net Zero Ready buildings can contribute to these goals and provide additional health, comfort, cost savings, resiliency, and safety benefits. Achieving the Town’s goal of net-zero energy use in all municipal buildings by 2030 will require investments in “Net Zero” buildings—which generate at least as much renewable energy in a year as they consume—and “Net Zero Ready” buildings—which reduce building energy and fossil fuel use to the point that any remaining emissions could be offset with purchases of carbon offset credits. In this report, AEC analyzes proposed Net Zero Ready investments in Bedford High School’s heating and cooling system. We find that Net Zero Ready investments are $2.9 million more expensive than a gas-fired alternative over 20 years; every “extra” thousand dollars invested in Net Zero Ready would provide the Town with a reduction benefit of 2 metric tons of carbon dioxide over the equipment lifetime. A Net Zero Ready Bedford High School would reduce average annual emissions from the High School by 64 percent and the Town’s municipal buildings by 21 percent.

Link to Report

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Risks Outweigh Rewards for Investors Considering PJM Natural Gas Projects

Client: Energy Foundation

Authors: Bryndis Woods, PhD, Liz Stanton, PhD, Eliandro Tavares, Sagal Alisalad, Myisha Majumder; and Dennis Wamsted from the Institute for Energy Economics and Financial Analysis (IEEFA)

October 2020

On behalf of the Energy Foundation, the Applied Economics Clinic and the Institute for Energy Economics and Financial Analysis (IEEFA) prepared a report that assesses the substantial risks to financial entities investing in natural gas-fired power plant development in the Pennsylvania-New Jersey-Maryland (PJM) region—the largest independent power system operator (ISO) in the United States. 

AEC and IEEFA identify six overarching threats that pose growing risks for investors in new PJM gas-fired power plants: increasing price competitiveness of clean solar, wind, demand response and battery storage alternatives; significant existing over-capacity, flat demand growth and market turmoil; high-impact, unpredictable global events such as COVID-19 that radically reshape markets and expectations of future demand; uncertainty over the future direction of gas prices, particularly given the substantial increase in U.S. liquefied natural gas (LNG) exports; actions by state governments within the PJM market to limit future fossil fuel generation and/or even withdraw from the market entirely; and public opposition that can delay project development and raise overall costs.

Link to Report

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Municipal Light Plants and Energy Efficiency

Client: Massachusetts Climate Action Network

Authors: Bryndis Woods, Sagal Alisalad, Myisha Majumder, Liz Stanton, PhD

September 2020

On behalf of the Massachusetts Climate Action Network, the Applied Economics Clinic reviewed over 60 Municipal Light Plants (MLPs) and electric cooperatives across 27 states to identify leaders in energy efficiency, renewable energy, and beneficial electrification programs. This white paper includes case studies of effective programs implemented by electric providers in this assessment. Overall, AEC found that MLPs in Massachusetts can utilize energy efficiency, renewable energy, and beneficial electrification to improve their energy programs.

Link to White Paper

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Health and Cost Benefits of Energy Efficiency Policies

Client: Green Energy Consumers Alliance (GECA)

Authors: Bryndis Woods, Hannah Brown and Myisha Majumder

March 9, 2020

On behalf of the Green Energy Consumers Alliance (GECA), Researcher Bryndis Woods and Research Assistants Hannah Brown and Myisha Majumder prepared a policy brief that assesses the impact of various efficiency policies on energy savings. We find that, on average, the more fully policies account for the benefits of energy efficiency, the more energy they save; states that account for participant health benefits, societal health benefits or mandate the implementation of all cost-effective efficiency measures save more energy than states that do not. In states that do not consider participant and societal health benefits, fewer efficiency measures are implemented—leaving both energy savings and benefits on the table.

Link to Policy Brief

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Social Equity Analysis of Carbon Free Boston

Client: Green Ribbon Commission

Authors: Bryndis Woods, Liz Stanton, PhD, and Applied Economics Clinic Staff

December 2018 - May 2019

In May 2019, Applied Economics Clinic worked together with All Aces and the Institute for Sustainable Energy (ISE) at Boston University to produce Carbon Free Boston: Social Equity Report 2019 on behalf of the Boston Green Ribbon Commission (GRC). The report details how actions taken toward carbon neutrality, which will fundamentally transform the city’s buildings, transportation, waste and energy systems, will also affect socially vulnerable populations and provides a roadmap to equitably engage the City’s communities in climate action. The report finds that the path to carbon neutrality presents a unique opportunity to address historic inequities while creating a cleaner, healthier and more prosperous City for all those who live and work in Boston. Three themes defined the framework for the social equity analysis: 1) careful planning to avoid unintended consequences, 2) intentional design with a clear focus on equity outcomes, and 3) inclusive practices from start to finish in all decision making.

For more information, see Carbon Free Boston on The City of Boston’s website.

Link to Social Equity Report

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Avoided Emissions of 100,000 renters in MA 2019-2021 Energy Efficiency Plan

Photo from Schochet Companies

Client: Clean Water Action

Author: Ricardo Lopez, PhD

March 2019

On behalf of Clean Water Action, Senior Researcher Ricardo Lopez, PhD provided a memo that estimates how much energy could be saved from including 100,000 renters in Massachusetts’ 2019-2021 Energy Efficiency Plan programs.

Link to Memo

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Municipal Light Plant Report Card

Client: Massachusetts Climate Action Network

Authors: Eliandro Tavares

January 2019

On behalf of the Massachusetts Climate Action Network, Assistant Researcher Eliandro Tavares along with additional Applied Economics Clinic (AEC) staff reviewed data and calculations from Massachusetts Climate Action Network for their report card on Municipal Light Plants. AEC assisted in turning the data and calculations into graphs for this report card.

Link to Graphs

Link to Report

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Testimony Regarding the Joint Statewide Three-Year Energy Efficiency Plan for Massachusetts, 2019-2021

Client: Conservation Law Foundation

Authors: Liz Stanton, PhD

November 2018

On behalf of Conservation Law Foundation, Clinic Director and Senior Researcher Liz Stanton provided testimony regarding the joint statewide three-year energy efficiency plan for Massachusetts for years 2019 to 2021. The testimony provided an independent review of the petitions filed by the Massachusetts gas and electric energy efficiency program administrators to assess their consistency with the Green Communities Act (GCA), the Global Warmings Solutions Act (GWSA), and other prior Department Orders.

This report is one of three AEC publications on behalf of Conservation Law Foundation and other stakeholders in the Massachusetts Energy Efficiency Advisory Council.

Link to Testimony

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Review of Massachusetts Efficiency Program Administrator's April 2018 Draft 2019-2021 Energy Efficiency Plan

Client: Conservation Law Foundation

Author: Liz Stanton, PhD

July 2018

AEC-2018-07-WP-01

On behalf of Conservation Law Foundation, Clinic Director and Senior Economist Liz Stanton, PhD, prepared an Applied Economics Clinic white paper of Massachusetts efficiency program administrator's April 2018 draft 2019-2021 energy efficiency plan. The detailed review and assessment included testing the sensitivity of the Plan's benefit-cost ratios to changes in assumptions regarding the cost of carbon emissions and the value of non-energy benefits to low-income households.

This report is one of three AEC publications on behalf of Conservation Law Foundation and other stakeholders in the Massachusetts Energy Efficiency Advisory Council.

Link to White Paper

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The Economic Impacts of Repealing Indiana's Energy Efficiency Resource Standard

Client: Citizens Action Coalition of Indiana

Bryndis Woods and Nina Schlegel

July 2018

On behalf of the Citizens Action Coalition of Indiana, Researchers Bryndis Woods and Nina Schlegel prepared an Applied Economics Clinic policy brief that analyzes energy efficiency savings, saved energy costs, and job impacts since the repeal of Indiana's energy efficiency resource standard (EERS) in 2015. The brief compares what happened as a result of the repeal with what would have been achieved had the program not been repealed. Ms. Woods and Ms Schlegel found that had EERS not been repealed: Indiana would have saved more energy, ratepayers would have saved millions of dollars, and many jobs would have been created. This policy brief serves as a companion to another AEC policy brief, entitled The Performance of Indiana Utilities’ Energy Efficiency Programs, that compares utility sales, energy efficiency savings and program costs over the period 2012 to 2019 across Indiana’s five investor-owned electric utilities.

This policy brief is one of two AEC publications on behalf of Citizens Action Coalition and Energy Foundation that investigate the impact of Indiana's 2014 repeal of its energy efficiency program through passage of the Senate Enrolled Act 340.   

Link to Policy Brief

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The Performance of Indiana Utilities’ Energy Efficiency Programs

Client: Citizens Action Coalition of Indiana

Bryndis Woods and Nina Schlegel

June 2018

On behalf of the Citizens Action Coalition of Indiana, Researchers Bryndis Woods and Nina Schlegel prepared a policy brief that compares the energy efficiency programs of five investor-owned utilities in Indiana: Duke Energy, Indiana Michigan Power Company (I&M), Indianapolis Power and Light Company (IPL), Northern Indiana Public Service Company (NIPSCO), and Southern Indiana Gas & Electric Company d/b/a Vectren Energy Delivery (Vectren). The policy brief presents side-by-side comparisons of Indiana’s investor-owned electric utilities’ sales, energy efficiency savings and program costs from 2012 to 2019. This brief serves as a companion to two forthcoming Applied Economics Clinic publications that investigate the impact of two Indiana legislative developments: the 2014 repeal of its energy efficiency program through passage of the Senate Enrolled Act 340 and the approval of its Transmission Distribution and Storage Improvement Charge (TDSIC) state statute, which was passed in 2013 with the Senate Enrolled Act 560.

This policy brief is one of two AEC publications on behalf of Citizens Action Coalition and Energy Foundation that investigate the impact of Indiana's 2014 repeal of its energy efficiency program through passage of the Senate Enrolled Act 340.   

Link to Policy Brief

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Energy Snapshots for Governor's Accord States

Clients: The Governor's Accord for a New Energy Future

Authors: Liz Stanton, PhD, and Bryndis Woods

May 2018

On behalf of The Governor’s Accord for a New Energy Future, Clinic Director and Senior Economist Liz Stanton, PhD and Researcher Bryndis Woods conducted a pilot analysis of energy resources and energy markets for some of the Governors’ Accord for a New Energy Future's 17 member states. The pilot analysis provided information on each state’s energy market, including its defining characteristics, future potential for growth, key economic trends, and clean energy and energy efficiency policy coverage.

Accessing Energy Efficiency in Massachusetts

Client: Conservation Law Foundation

Liz Stanton, PhD, Emrat Nur Marzan and Sagal Alisalad

February 2018

On behalf of the Conservation Law Foundation, Clinic Director and Senior Economist Liz Stanton, PhD, and Research Assistants, Emrat Nur Marzan and Sagal Alisalad, prepared an Applied Economics Clinic (AEC) report that investigates how well Massachusetts' energy efficiency programs are reaching under-served communities and hard-to-reach families. In 2017, Massachusetts' "Mass Save" energy efficiency programs ranked number one in the annual efficiency scorecard produced by the American Council for an Energy-Efficient Economy (ACEEE) for the seventh consecutive year. Mass Save's ranking is not, however, a good indicator of whether or not low-income households are getting the services they need. At present, it is not possible to answer this question completely because Mass Save program administrators have access to - but do not include in publicly available statistics - information regarding low-income households, under-served communities and hard-to-reach families. Working with limited data, AEC found that there are substantial differences in energy savings among Massachusetts’ towns, and lower-income communities are receiving lower efficiency savings. This report presents maps and other figures showing differences in efficiency savings, income, and other community characteristics like language abilities and renter status for both Massachusetts towns and neighborhoods within Boston.

This report is one of three AEC publications on behalf of Conservation Law Foundation and other stakeholders in the Massachusetts Energy Efficiency Advisory Council.

News Coverage: Barr Foundation Blog Post

News Coverage: Sampan Newspaper

Link to Maps

Link to Report

Link to Data

Link to AEC/CLF Webinar

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Missed Opportunities for Energy Efficiency in Virginia

Client: Consumers Union (CU)

Liz Stanton, PhD, Rachel Wilson, and Bryndis Woods

February 2018

On behalf of Consumers Union, Clinic Director and Senior Economist Liz Stanton, PhD, Senior Researcher Rachel Wilson, and Researcher Bryndis Woods prepared a report that investigates the impact of various levels of energy efficiency on electric rates and bills of Dominion Energy Virginia (Dominion) customers. Dominion is asking state utility regulators to approve billions of dollars in new spending to increase nuclear and natural gas capacity over the next 10 years in order meet its forecast for future energy demand. These costs would be passed on to consumers in the form of substantially higher utility bills. Applied Economics Clinic found that by investing in energy efficiency, Dominion customers would enjoy lower rates and bills while future energy demand would be met with fewer than half of the new power plants currently proposed by Dominion.

News Coverage: UtilityDive

News Coverage: WHSV3 News

Link to Report

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Testimony on Entergy New Orleans' Request to Construct New Orleans Power Station

Client: Alliance for Affordable Energy

Author: Liz Stanton, PhD

October 2017

On behalf of Alliance for Affordable Energy, Clinic Director and Senior Economist Liz Stanton, PhD submitted an Applied Economics Clinic testimony in Docket No. UD-16-02 providing an expert opinion as to whether or not Entergy New Orleans' request for a new power station to address their capacity deficit is reasonable, given alternative options to address any assumed capacity deficit and within the context of the City of New Orleans' climate regulations. Dr. Stanton concluded that Entergy New Orleans needs less capacity than it has reported, that the company has not considered a full set of alternatives to meet New Orleans' needs, and that the New Orleans City Council should wait to make a decision about the New Orleans Power Station until it has all information at hand.

Link to Stanton Testimony

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