• Home
  • About
    • Our People
    • Mission and Funding
    • 990 Filings
    • Governance and Disclosure Statements
  • Our Work
    • Publications
    • Newsletters
    • Equity Resources
  • Blog
  • Jobs
    • Internships
    • AEC Fellowship
    • Careers
  • Pro Bono Fund
    • Pro Bono Fund
    • Donate
    • MassCEC Empower Grant
Applied Economics Clinic
  • Home
  • About
    • Our People
    • Mission and Funding
    • 990 Filings
    • Governance and Disclosure Statements
  • Our Work
    • Publications
    • Newsletters
    • Equity Resources
  • Blog
  • Jobs
    • Internships
    • AEC Fellowship
    • Careers
  • Pro Bono Fund
    • Pro Bono Fund
    • Donate
    • MassCEC Empower Grant

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

Return to Our Work

tags: Tyler-Comings
categories: Decarbonization, Coal Plants, IRP, Michigan
Wednesday 04.26.23
Posted by Liz Stanton
 

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

Return to Our Work

tags: Tyler-Comings
categories: Renewable Energy, IRP, Indiana, Michigan, Coal Plants
Monday 10.17.22
Posted by Liz Stanton
 

Testimony on the DTE Electric Company Rate Case

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

Authors: Senior Researcher Tyler Comings

AEC Senior Researcher Tyler Comings filed testimony before the Michigan PSC on the DTE Electric Company (DTE) rate case on behalf of Michigan Environmental Council (MEC), Natural Resources Defense Council (NRDC), Sierra Club (SC), and Citizens Utility Board of Michigan. Mr. Comings recommended disallowance of capital investments that could be avoided if DTE's coal units retired earlier than currently planned--as well as disallowance of other capital projects that were not justified.

Link to Testimony

Return to Our Work

tags: Tyler-Comings
categories: Michigan
Monday 08.29.22
Posted by Liz Stanton
 

Testimony on Consumers IRP in Michigan

Author: Tyler Comings

July 2022

AEC Senior Researcher Tyler Comings filed direct and rebuttal testimony on Consumers Energy's Integrated Resource Plan (IRP) before the Michigan Public Service Commission. Mr. Comings argued with the economics of the company's proposal to acquire three affiliate gas plants, and also supported the company's plan to retire its Campbell coal units by 2025.

Link to Testimony

Link to Rebuttal Testimony

Return to Our Work

tags: Tyler-Comings
categories: Clean Energy Transition, Michigan
Friday 07.08.22
Posted by Liz Stanton
 

Testimony on the Enbridge Energy Limited Partnership Proposed Replacement and Relocation of Line 5

timothy-meinberg-phx4UXMQRTg-unsplash.jpg

Clients: The Environmental Law & Policy Center, The Michigan Climate Action Network, and the Bay Mills Indian Community

Author: Liz Stanton, PhD

September 2021

On behalf of The Environmental Law & Policy Center, The Michigan Climate Action Network, and the Bay Mills Indian Community, Clinic Director and Senior Economist Liz Stanton, PhD filed testimony on the Enbridge Energy LP (Enbridge) application to replace and relocate a segment of an oil and natural gas pipeline (Line 5)that crosses the Straits of Mackinac into a tunnel underneath the Straits of Mackinac. Dr. Stanton found that Enbridge failed to consider a “no-action” alternative to replace the oil pipeline and that shutting down the existing line is not only feasible but would also likely have a positive impact on Michigan’s economy while accelerating the state’s transition to a zero-carbon economy.

Link to Testimony

Link to Michigan Radio coverage

Link to Bridge Michigan coverage

Link to News-Review coverage

Return to Our Work

tags: Liz-Stanton
categories: Natural Gas, Michigan, Pipeline
Wednesday 09.29.21
Posted by Liz Stanton
 

Background Report: Benefits of Coal Ash Cleanup and Remediation

image (5).png

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

Return to Our Work



tags: Joshua-Castigliego, Liz-Stanton, Tyler-Comings, Sagal-Alisalad
categories: Michigan, Montana, South Carolina, Jobs, Coal Plants
Thursday 07.29.21
Posted by Liz Stanton
 

Consumers Energy Rate Case Testimony

photo-1615916583701-e75713cf753a.jpeg

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

Return to Our Work



 
tags: Tyler-Comings
categories: Greenhouse Gas Emissions, Michigan, Energy Efficiency
Tuesday 06.29.21
Posted by Liz Stanton
 

Testimony on Consumers Energy's 2020 Rate Case

Source: MiBiz

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

Return to Our Work

tags: Tyler-Comings
categories: Coal Plants, Michigan
Tuesday 06.30.20
Posted by Liz Stanton
 

Testimony on Consumers Energy Integrated Resource Plan (IRP)

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

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

Return to Our Work

tags: Tyler-Comings
categories: Michigan, Coal Plants
Wednesday 10.17.18
Posted by Liz Stanton
 

Testimony on the Economics of Karn Coal Units in Michigan

Source: Power Engineering

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

Return to Our Work

tags: Tyler-Comings
categories: Coal Plants, Michigan
Friday 09.14.18
Posted by Liz Stanton