Assessing TVA’s IRP Planning Practices

Norris Dam in Anderson County, Tennessee. Image Credit: Brian Stansberry / Creative Commons

Client: Prepared on behalf of the Southern Environmental Law Center

Authors: Chirag Lala, Elisabeth Seliga, Liz Stanton, PhD

July 2023

On behalf of the Southern Environmental Law Center, Researcher Chirag Lala, Assistant Researcher Elisabeth Seliga, and Senior Economist Liz Stanton, PhD published a report that compares the Tennessee Valley Authority’s (TVA’s) Integrated Resource Planning (IRP) processes in 2011, 2015, and 2019 to the actual changes in capacity additions and retirements made by TVA from 2011 to 2021. The paper also examines the site-specific planning process used by TVA to determine the replacements for the Cumberland Fossil Plant.

AEC staff make several key recommendations for TVA’s 2024 Integrated Resource Planning Process: (1) TVA must set aggressive climate goals in line with the Paris Agreement and the Biden Administration’s executive orders on achieving carbon free electricity by 2035; (2) TVA must be transparent about its assumptions and modeling inputs; (4) TVA must select a portfolio with a more targeted preferred resource plan; (3) TVA must plan to utilize the grants, loans, and tax credits of the Inflation Reduction Act; (5) TVA must clarify how it demarcates “ownership” of solar and wind resource; (6) TVA should conduct an all-resource Request for Proposals (RFP) for new resources; (7) TVA must ensure its site-specific planning documents reflect the most recent IRP plans and use methods that do not contradict overall system- and other site-specific planning exercises.

Link to Report

Link to Environmental Group Comments on TVA IRP

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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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Boston Tree Equity Analysis

Client: GreenRoots and Speak for the Trees

Authors: Tanya Stasio, PhD, Elisabeth Seliga, Elizabeth A. Stanton, PhD

Boston’s trees provide shade, cooling, and flood protection, and are an important tool for mitigating climate change impacts—like increased precipitation, sea level rise, and higher temperatures. The distribution of trees across and within Boston neighborhoods determines which communities benefit from these protections and which are left bearing the brunt of climate change impacts.

On behalf of GreenRoots and Speak for the Trees, Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga and Senior Economist Liz Stanton, PhD examined the distribution of tree coverage, pollution, high temperatures, and socioeconomic disparities in the City of Boston in order to identify communities where tree planting efforts could offer the most equitable results.

AEC recommends that equitable tree planting efforts be concentrated in neighborhoods where there is both the greatest opportunity for planting trees in an otherwise tree scarce area and a high concentration of socially vulnerable populations: South Boston, East Boston, Dorchester, and Roxbury.

Link to Report

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Net Emissions Savings Benefit for a Battery Storage Facility in Wendell, Massachusetts

Image source: Borrego

Client: New Leaf Energy, Inc.

Authors: Joshua R. Castigliego, Chirag Lala, and Liz Stanton, PhD

August 2022

On behalf of New Leaf Energy, Inc., Researchers Joshua Castigliego and Chirag Lala, and Senior Economist Liz Stanton, PhD conducted analysis estimating the net change in carbon dioxide (CO2) emissions resulting from New Leaf Energy’s proposed battery storage facility located in Wendell, Massachusetts. AEC estimated net emission savings of this proposed battery storage project as the sum of “positive” CO2 emissions savings (i.e., reduced emissions) from the electric grid due to charging and discharging at specific times and “negative” CO2 emissions (i.e., increased emissions) due to land-use conversion from forestland to grassland. Combined these two effects result in substantial net emissions savings (i.e., reduced emissions) resulting from the proposed New Leaf Energy facility.

The proposed battery facility at the Wendell site would draw power from the grid during periods in which clean, renewable energy sources are a high share of total New England generation, and discharge energy at times when mostly fossil-fuel-powered generators are displaced by this added energy. By charging using low-emission generation and displacing fossil fuel generation while discharging power, new battery resources result in lower electric grid emissions.

This publication is an update to a study originally released in November 2021 (AEC-2021-11-WP-01).

Link to White Paper

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Testimony on Demand Charge Alternatives in Massachusetts

Image Credit: Saur Energy International

Client: Green Energy Consumers Alliance

Author: Joshua Castigliego

May 2022

On behalf of the Green Energy Consumers Alliance, Researcher Joshua Castigliego provided Applied Economics Clinic expert testimony to Track 2 of Dockets 21-90 and 21-91 before the Massachusetts’ Department of Public Utilities. In his testimony, Mr. Castigliego investigated co-locating renewable power generation (e.g., solar PV) and/or energy storage at electric vehicle (EV) charging stations as a technology-based approach to alleviating the financial barrier that utility demand charges pose to the widespread deployment of direct current fast charging (DCFC) stations across the Commonwealth. His analysis demonstrates that co-location with renewables and/or energy storage has the potential to lower the average cost per EV charge (depending, in part, on the utility’s rate structure), which would alleviate the financial barrier for EV charging stations due to demand charges. Mr. Castigliego demonstrates that utility demand charges can work hand in hand with the co-location of renewables and energy storage to synergistically combat the financial barrier and increase overall deployment of DCFC stations in Massachusetts. To obtain those benefits, the electric distribution companies and the Department must take the impact of co-location into consideration when constructing and approving demand charge rate structures.

Link to Testimony (DPU Docket Nos. 21-90 and 21-91)

Media Coverage - GECA Blog Post - September 30, 2022

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Testimony on Eversource Energy's Certificate of Environmental Impact and Public Interest regarding the East Eagle Street Substation

Clients: GreenRoots Inc., and Conservation Law Foundation

Author: Liz Stanton, PhD

May 2022

On behalf of GreenRoots, Inc. and Conservation Law Foundation, AEC Senior Economist Liz Stanton, PhD filed testimony on Eversource Energy’s proposed East Eagle Street Substation in East Boston with the Commonwealth of Massachusetts Energy Facilities Citing Board (Docket No. EFSB 22-01). Dr. Stanton examined Eversource Energy’s rationale and found the company failed to provide sufficient evidence for the need for a new gas substation. Dr. Stanton highlights that Eversource’s justification for the proposed substation has changed over time without providing additional forecasts or data indicating such a substation is necessary to meet current consumer demand.

Link to Testimony (Docket No. EFSB 22-01)

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Making Clean Energy Decisions in New England

Client: Community Action Works

Authors: Bryndis Woods, PhD, Sachin Peddada, Eliandro Tavares, Elisabeth Seliga, and Myisha Majumder

April 2022

On behalf of Community Action Works, AEC staff developed a report that identifies and examines six on-going clean energy and energy justice advocacy campaigns in New England. AEC profiles and assesses each campaign to determine which decision makers possess the authority to act on the advocates’ goals. These six campaigns include opposition to the proposed peaker plant in Peabody, MA; continued operation of New England’s last coal-fired power plant in Bow, New Hampshire; three existing peaker plants in Berkshire County, MA; a proposed gas-fired power plant in Killingly, CT; a proposed gas pipeline between Longmeadow and Springfield, MA; and an approved electric substation in East Boston awaiting construction. In addition to profiling each project, the report clarifies the key role the Independent System Operator of New England (ISO-NE), governors, and state legislatures play in developing New England’s energy mix.

Across all six campaigns, we find that advocates have more opportunities to pursue their goals while a project is still in its proposal phase; it becomes more challenging to shut down an energy project once it is operational. In addition, we recommend changes at ISO-NE that have the potential to render many polluting New England energy projects less competitive.

Link to Our Report

Press Release

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Decarbonizing Building Heat in Massachusetts

Client: HEET

Authors: Tanya Stasio, Joshua Castigliego, Sagal Alisalad, and Liz Stanton, PhD.

March 2022

On behalf of the HEET, Researchers Tanya Stasio and Joshua Castigliego, Assistant Researcher Sagal Alisalad, and Director and Senior Economist Liz Stanton, PhD explored the feasibility of injecting green hydrogen and/or upgraded biogas (also known as “renewable” natural gas) into Massachusetts’ existing gas supply as a building decarbonization strategy. AEC compared these alternatives to gas heating and modern electric heat pumps in terms of price, feasibility, supply, and safety, and found that upgraded biogas and green hydrogen are infeasible, expensive, and unsafe strategies for decarbonization of building heating. Moreover, a green hydrogen/fossil gas blend is not feasible before 2040; For a green hydrogen/fossil gas blend to be a viable heating fuel, gas utilities would need to replace all of Massachusetts’ leaky-prone pipes.

AEC also estimated annual home heating costs for an average Massachusetts home using different heating options and found that by the mid-2030’s heating with air-source heat pumps, ground-source heat pumps, and/or networked geothermal systems will be more affordable than heating with fossil gas.

Link to White Paper

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Peabody Peaker Plant Risk Assessment

Client: Massachusetts Climate Action Network

Authors: Bryndis Woods, PhD, Chirag Lala, and Joshua Castigliego

March 2022

On behalf of the Massachusetts Climate Action Network (MCAN), AEC staff developed a policy brief that presents risks that Municipal Light Plants (MLPs) should consider as they decide whether to retain their ownership shares in the Peabody peaking power plant or withdraw from the contract: 1) market risks, like capacity and fuel prices, and 2) climate/environmental risks. We find that while ownership in the Peabody peaker protects against some capacity market risks, it leaves MLPs open to a variety of other important risks, including uncertainty in future gas fuel prices. existing Massachusetts emissions regulations and Environmental Justice (EJ) community protection laws, and the potential for stronger EJ laws, new federal legislation, and/or regulatory changes that put fossil fuel-fired assets at a disadvantage.

Link to Policy Brief

Link to MCAN Press Release

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Testimony on Off-Peak Charging Rebates in Massachusetts

Client: Green Energy Consumers Alliance

Authors: Liz Stanton, PhD and Joshua R. Castigliego

January 2022

On behalf of the Green Energy Consumers Alliance, Clinic Director and Senior Economist Liz Stanton, PhD and Researcher Joshua Castigliego provided Applied Economics Clinic expert testimony to Dockets 21-90 and 21-91 before the Massachusetts' Department of Public Utilities. In their testimony to Docket 21-91, Dr. Stanton and Mr. Castigliego reviewed and critiqued National Grid's methods and assumptions in setting a 3 to 5 cent per kilowatt-hour (kWh) rebate for its Off-Peak Charging Program. Dr. Stanton and Mr. Castigliego determined that National Grid is underestimating its rebate by excluding important benefits of off-peak charging such as avoided transmission and distribution costs, avoided emissions and emission costs, avoided reliability costs, avoided costs due to induced price effects, and non-energy benefits. Their analysis shows that including these benefits in a value for off-peak charging could raise National Grid's rebate by 10 cents per kWh from 3 to 5 cents per kWh to 13 to 15 cents per kWh. Similarly in Docket 21-90, Dr. Stanton and Mr. Castigliego examined a possible off-peak charging rebate for Eversource by modeling avoided energy and capacity costs based on National Grid’s methodology, and offering an illustrative methodology for inclusion of other off-peak charging benefits. In the absence of a rebate, EV owners are currently being overcharged for the energy used to charge their vehicles; implementing a rebate value that includes a complete set of benefits would eliminate a cross-subsidy from EV owners to non-EV owners while at the same time providing an incentive to adopt critical emission reductions in the transportation sector.

Link to Joint Testimony (DPU 21-90)

Link to Joint Testimony (DPU 21-91)

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Cambridge Net Zero Action Plan

Client: City of Cambridge

Authors: Bryndis Woods and Liz Stanton, PhD

December 2021

Together with DNV GL and Sorensen Partners, AEC led the City of Cambridge's stakeholder engagement process to provide equity input on the City's 2021 update to its 2015 Net Zero Action Plan.

The Net Zero Task Force held five public, remote meetings between November 2020 and June 2021.
AEC provided equity guidance and input throughout the process as the Task Force worked to propose and evaluate adjustments to the Net Zero Action Plan.

• Meeting 1, November 2020: 
  AEC presented on its Climate and Social Equity Framework and baseline equity considerations for the City of Cambridge.

• Meeting 2, December 2020: 
  AEC provided guidance regarding the potential co-benefits of Net Zero Actions, including equity co-benefits.

• Meeting 3, January 2021: 
  AEC answered stakeholders’ questions regarding equity.

• Meeting 4, April 2021: 
  AEC presented on the equity implications of the proposed Net Zero Action Plan adjustments, including equitable action design and implementation.

• Meeting 5, May 2021: 
  AEC presented on the “equity rating” assigned to each proposed Net Zero Action—equity ratings indicate whether each Action, as it currently stands, is likely to have equity impacts that are positive, neutral, or need to be addressed with additional action (“flagged”).

In January 2022, the City of Cambridge received City Council approval on its final Net Zero Action Plan.

Link to Final Cambridge Net Zero Action Plan

Equity Measurement and Targeting Underserved Communities in Massachusetts’ 2022-2024 Energy Efficiency Plan

Client: Green Justice Coalition

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

December 2021

On behalf of the Green Justice Coalition, AEC staff developed three white papers on equity measurement and how underserved communities will be served in the implementation of Massachusetts’ 2022-2024 Energy Efficiency Plan. The first paper, Equity Measurement for Massachusetts’ 2022-2024 Energy Efficiency Plan, builds on the equity recommendations of the Energy Efficiency Advisory Council’s (EEAC) Equity Working Group (EWG) and the Green Justice Coalition by describing metrics needed to evaluate progress towards equity goals. The second paper, Energy Efficiency and Equity Efforts Nationwide, provides examples from other jurisdictions around the nation on the state of equity programming in energy efficiency policies. The third AEC white paper, Targeting Underserved Communities in Massachusetts’ 2022-2024 Energy Efficiency Plan, is a detailed review of Massachusetts towns identified as underserved by the energy efficiency program administrators and their partners.

Link to White Paper 1: Equity Measurement for Massachusetts’ 2022-2024 Energy Efficiency Plan

Link to White Paper 2: Energy Efficiency and Equity Efforts Nationwide

Link to White Paper 3: Targeting Underserved Communities in Massachusetts’ 2022-2024 Energy Efficiency Plan

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Energy Storage for Winter Grid Reliability: How Batteries Became the Low-Cost Solution for Power Assurance in Massachusetts

Client: Clean Energy Group

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

December 2021

On behalf of the Clean Energy Group, Researcher Joshua Castigliego, Senior Economist Liz Stanton, PhD, and Assistant Researchers Sagal Alisalad and Eliandro Tavares evaluated the value of winter reliability services and the opportunity to provide these services economically in New England using distributed battery storage. AEC finds that the value of winter peaking capacity services from distributed (customer-sited) resources is incorrectly assumed to be $0 in the battery program cost-benefit analyses that determine performance payments to battery storage owners.

The value of winter electric capacity is treated by electric distributors as distinct from that same value in summer, and it has been dubbed “winter reliability” to distinguish it from “summer capacity.” When calculating customer performance payments, summer capacity services are valued, but winter reliability services are not. In this report, AEC introduces a winter reliability metric defined as the assurance of adequate electric capacity during periods of critical need, called—following ISO-New England’s convention—capacity scarcity condition (CSC) events. AEC calculated a “winter reliability value” measured as the net dollar value to supply any given peak supply technology (i.e., gas peaker or large-scale battery storage) on a per kilowatt-hour (kWh) basis during a CSC period.

Link to Report

Link to Presentation

Media Coverage

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ConnectedSolutions: A Program Assessment for Massachusetts

Client: Clean Energy Group

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

September 2021

On behalf of the Clean Energy Group, this Applied Economics Clinic report assesses the design and performance of the Massachusetts ConnectedSolutions program. Massachusetts’ ConnectedSolutions program offers incentives to customers in exchange for allowing their electric supplier to draw on the energy stored in their grid-connected batteries and/or to curtail energy use via smart thermostats or electric vehicle charging at times of peak electric demand. Launched as a full program offering in 2019, ConnectedSolutions had about 34,000 customer participants with 310 megawatts (MW) of capacity enrolled by the end of 2020.

This report compares the Massachusetts ConnectedSolutions program, as it has been administered in the first three-year program cycle, with related programs in other states across the country. In several important areas, the Massachusetts program administrators could benefit from best practices implemented elsewhere; chief among these is the treatment of income-eligible customers and those in historically underserved communities.

Link to Report

Link to Webinar

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Estimating the Net Change in Carbon Dioxide Emissions for Solar Projects in Massachusetts

Client: Borrego

Authors: Joshua R. Castigliego, Chirag Lala, Eliandro Tavares, and Liz Stanton, PhD

September 2021

On behalf of Borrego, Researchers Joshua Castigliego and Chirag Lala, Assistant Researcher Eliandro Tavares, and Senior Economist Liz Stanton, PhD conducted analysis estimating the net change in carbon dioxide (CO2) emissions of Borrego’s proposed solar projects at three sites in Wareham, Massachusetts. AEC estimated net emission savings of the proposed projects as the sum of “positive” CO2 emissions savings from the electric grid due to renewable energy generation, and “negative” CO2 emissions due to land use conversion from forestland to grassland. AEC found that Borrego’s proposed projects offset four times more CO2 emissions than are emitted in their development.

Link to White Paper

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Assessment of Backup Diesel Generators in Massachusetts and New York City

Client: Bloom Energy

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

August 2021

On behalf of Bloom Energy, Researchers Joshua Castigliego and Tanya Stasio, Assistant Researcher Sagal Alisalad, and Senior Economist Liz Stanton, PhD prepared two reports assessing backup diesel generators in Massachusetts and New York City. AEC compiled inventories of backup diesel generators in each jurisdiction based on publicly available data and reviewed the quantity, combined capacity, proximity to environmental justice (EJ) communities, and emissions impact of backup diesel generators.

AEC found that there is an abundance of backup diesel generators throughout both areas that are commonly sited near EJ communities and represent a considerable—and largely avoidable—source of air pollution and greenhouse gas emissions that threaten public health and the environment.

Link to Massachusetts Report

Link to New York City Report

Link to Download Shapefile for Massachusetts Environmental Justice Communities

Link to Download Shapefile for New York City Environmental Justice Communities

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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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Conditional Benefits of Sustainable Community Microgrids

Client: GreenRoots

Authors:
Joshua R. Castigliego, Tanya Stasio, and Eliandro Tavares

May 2021

On behalf of GreenRoots, Researcher Joshua Castigliego, Research Assistant Tanya Stasio, and Assistant Researcher Eliandro Tavares prepared a policy brief on the impacts of community microgrids on vulnerable populations. AEC staff defined “sustainable community microgrids” as independently controlled energy systems that, depending on their design, have the potential to enhance grid resilience, lower electric bills, improve public health, and strengthen local communities while prioritizing equitable outcomes.

Link to Policy Brief

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Initial Assessment of the Climate Justice Working Group’s Recommended Policy Priorities – Tracking Equity and Justice

Client: Massachusetts’ Climate Justice Working Group

Authors: Bryndis Woods, PhD and Liz Stanton, PhD

March 2021

On behalf of members of the Massachusetts’ Climate Justice Working Group (CJWG)—Conservation Law Foundation, Health Care Without Harm, Neighbor to Neighbor, Alternatives for Community and Environment, GreenRoots, Coalition for Social Justice, Clean Water Action, and Unitarian Universalist Mass Action—this Applied Economics Clinic report describes how progress could be tracked, measured and evaluated for each of CJWG’s six policy priorities by recommending specific metrics to evaluate their equity and justice impacts. This report also includes a discussion of the importance of setting measurable, actionable equity goals that include clear standards for community engagement in the Massachusetts 2030 Clean Energy and Climate Plan (2030 CECP).

For Massachusetts equity goals, including those specified by the CJWG and those contained in the 2030 CECP, to be more than just lip-service, it is of vital importance that they be formalized with concrete, specific plans that meaningfully engage the community and actionable metrics to facilitate their evaluation. In other words, all equity and justice goals need to be measurable, actionable, and involve robust, meaningful, and transparently conducted community engagement processes. This report demonstrates that much of the data and information needed to measure progress towards equity and justice goals do not currently exist or are not currently publicly available, and draws attention to the additional efforts that will be required to measure progress regarding the impacts of climate policy in EJ populations and other historically marginalized communities.

Link to Report

Link to Comments

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