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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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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Evergy Kansas IRP Comments

Client: Sierra Club

Authors: Senior Researcher Tyler Comings and Researcher Joshua Castigliego

Senior Researcher Tyler Comings and Researcher Joshua Castigliego assisted the Sierra Club in comments on the Evergy Kansas Integrated Resource Plan (IRP). AEC had several criticisms of the Evergy plan, including that the company 1) failed to choose one of its alternative plans that was lower-cost and had accelerated coal unit retirements; 2) failed to conduct true optimization of coal unit retirements; 3) inflated the costs of new renewable resources; and 4) failed to consider any battery storage.

Link to Comments

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Expert Memo: Review of Memphis Light, Gas, and Water RFP Update and Staff Power Supply Recommendation

Client: Southern Environmental Law Center (SELC)

Authors: Elizabeth A. Stanton, PhD, Joshua R. Castigliego, Myisha Majumder, Eliandro Tavares, Sachin Peddada

AEC staff conducted an assessment of Memphis Light, Gas, and Water (MLGW)’s 2020 Integrated Resource Plan on behalf of the Southern Environmental Law Center, finding multiple instances of biases in favor of gas resources and against renewables and batteries. In light of these discoveries, AEC staff recommend that the biases be addressed prior to the MLGW Board making a decision on power supply alternatives.

Link to Memo

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Ameren MO IRP Comments

Source: USFWS Midwest Region

Authors: Tyler Comings, Joshua Castigliego, Sagal Alisalad, Eliandro Tavares, and Sierra Club

March 2021

AEC co-authored (with Sierra Club) comments on the Integrated Resource Plan (IRP) from Ameren Missouri. The comments discuss Ameren's failure to: economically optimize coal unit retirements, adequately address substantial costs from pending litigation, and adequately consider low-cost solar and solar-battery hybrid resources.

Link to Comments

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Comments on Xcel Energy IRP in Minnesota

Source: Greentech Media

Client: Sierra Club

Author: Tyler Comings

February 2021

AEC Senior Researcher Tyler Comings assisted in Sierra Club's comments on Xcel Energy’s 2020-2034 Upper Midwest Resource Plan--along with Synapse Energy Economics, Grid Strategies, and Telos Energy. Mr. Comings developed alternative modeling assumptions, including for wind, solar and battery storage costs. Mr. Comings also contributed to comments on Xcel's methodology and its plans to build a new natural gas combined cycle plant.

Link to Comments

Link to Reply Comments

Link to Surreply Comments

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Comments on Evergy's 2020 Integrated Resource Plan

Client: Sierra Club

Author: Tyler Comings

May 2020

AEC Senior Researcher Tyler Comings assisted the Sierra Club with comments on the Evergy Integrated Resource Plan (IRP) process in Missouri. The comments recommend that Evergy fully assess the economics of its existing fleet, use realistic costs for replacement resources, re-design its solicitation to encourage more competition from new resource options, and more seriously address risks of environmental compliance costs.

Link to Comments

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Comments on Ameren Missouri Integrated Resource Plan

Client: Sierra Club

Author: Tyler Comings

April 2020

AEC Senior Researcher Tyler Comings assisted the Sierra Club with comments on the Ameren Missouri Integrated Resource Plan (IRP) process. The comments recommend that Ameren fully address environmental compliance costs and emissions impacts, conduct rigorous economic modeling of its coal fleet, and reasonable cost assumptions for existing and new resources. 

Link to Comments

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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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Report on Indiana Michigan Power Company 2018-19 IRP

Wildcat Wind Farm, Indiana

Clients: Citizens Action Coalition of Indiana and Earthjustice

Authors: Liz Stanton, PhD, Anna Sommer, Chelsea Hotaling, Chris Neme

December 2019

Clinic Director and Senior Economist Liz Stanton, PhD contributed to comments on Indiana Michigan Power Company's most recent Integrated Resource Plan (IRP), which are filed with the Utility Commission to demonstrate that utilities' decisions to retire and/or add electric generation are in the public interest. While technical, these evaluations provide an important benefit to utility customers and the Indiana public more widely. Third-party review of these and other utilities filings is critical to vet for errors, uncover questionable or self-serving assumptions, and make hidden value-judgments transparent. Important issues found in reviewing Indiana utilities’ 2016 Plans include biases both against retiring coal generation and against adopting new efficiency measures and renewable resources. This testimony is part of a joint AEC and Energy Futures Group series of comments on Indiana utility Integrated Resource Plans (IRPs) on behalf of Citizens Action Coalition of Indiana and Earthjustice.

Report on Indiana Michigan Power Company IRP

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Testimony on Puerto Rico Electric Power Authority (PREPA) Least Cost Integrated Resource Plan

Client: Environmental Defense Fund

Liz Stanton, PhD

October 2019

On behalf of Environmental Defense Fund, Clinic Director and Senior Economist Liz Stanton, PhD provided Applied Economics Clinic expert testimony to Docket 2018-0001 before the Puerto Rico Energy Bureau. In her testimony, Dr. Stanton recommended that the Energy Bureau reject Puerto Rico’s energy utility’s (PREPA) June 2019 IRP and require that the Utility submit a new IRP under a set of outlined instructions and conditions. Dr. Stanton concluded that PREPA must constrain all scenarios to follow Puerto Rican Law, must submit model runs with higher demand forecasts, must issue an all resource RFP for new generation and peak-shifting resources, and must hold stakeholder meetings for the general public for future IRPs, including meetings in Spanish.

Link to 2018-0001 Testimony

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Puerto Rico Integrated Resource Plan: Lessons from Hawaii's Electric Sector

Client: Earthjustice

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

October 2019

Researcher Bryndis Woods, Assistant Researchers Eliandro Tavares and Sagal Alisalad and Clinic Director and Senior Economist Liz Stanton, PhD prepared a report that compares Puerto Rico Electric Power Authority’s (PREPA’s) most recent version of its Integrated Resource Plan (IRP), released in June 2019, to best practices distilled from the most recent Hawaiian electric sector planning process, which was finalized in 2016. The report presents the parallels between Hawaii and Puerto Rico’s island electric systems and outlines how important lessons from the Hawaiian context have the potential to improve Puerto Rico’s planning process, ensure that PREPA is in compliance with Puerto Rico’s climate laws, and provide the lowest possible rates to consumers.

Link to Report

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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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Comments on Cleco Power's Draft 2019 Integrated Resource Plan

Source: Wind 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 Cleco’s Draft 2019 Integrated Resource Plan. The Sierra Club concluded that Cleco failed to evaluate the economics of all of its existing resources as part of the IRP and also encouraged Cleco to pursue the company's preferred portfolio, including the addition of wind and solar resources.

Link to Comments

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Review of Minnesota Utilities' Resource Planning

Client: Minnesota Center for Environmental Advocacy

Authors: Liz Stanton, PhD

October 2017

On behalf of the Minnesota Center for Environmental Advocacy, Clinic Director and Senior Researcher Liz Stanton, PhD evaluated Minnesota's electric utilities' resource planning including Great River Energy's Integrated Resource Plan (IRP) and Minnesota Power's EnergyForward docket. Resource Plans are filed with the Utility Commission to demonstrate that utilities’ decisions to retire and/or add electric generation resources are in the public interest. While technical, these evaluations provide an important benefit to utility customers and the Minnesota public more widely. Third-party review of these and other utilities filings is critical to vet for errors, uncover questionable or self-serving assumptions, and make hidden value-judgments transparent.