Authors: Tyler Comings and Joshua R. Castigliego
July 2022
AEC Senior Researcher Tyler Comings and Researcher Joshua Castigliego co-authored an expert report (along with Energy Futures Group) on the Minnesota Power (MP) Integrated Resource Plan. The report presents an alternative to MP's plan to procure a share of a new natural gas combined cycle plant--showing that additional renewable, storage and demand-side resources provided a lower-cost solution than new gas for the utility.
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 Michigan Radio coverage
Client: New York Lawyers for the Public Interest and Earthjustice
Authors: Bryndis Woods, PhD and Liz Stanton, PhD
September 2021
On September 13, 2021, New York Lawyers for the Public Interest and Earthjustice—on behalf of the New York City Environmental Justice Alliance, THE POINT CDC, UPROSE, Chhaya CDC, and Clean Energy Group, together with Sierra Club—submitted comments to the New York State Department of Environmental Conservation (DEC) regarding the Draft Title V Air Permit and the Draft Supplemental Environmental Impact Statement for Astoria Gas Turbine Power LLC's proposed Astoria Replacement Project. The comments urged the DEC to deny the permit for the proposed Project because of its inconsistency with New York State climate and emission reduction goals set forth in the 2019 Climate Leadership and Community Protection Act (CLCPA).
AEC's comments address Astoria Gas Turbine Power LLC's incorrect claims that the proposed Project is CLCPA-consistent and that a hypothetical future conversion to hydrogen fuel is zero emissions or CLCPA-consistent. AEC's comments also outline the negative environmental justice and public health implications of hydrogen fuel use. We conclude that—with or without switching from gas fuel to hydrogen—the proposed Project is not consistent with the CLCPA.
Authors: Joshua Castigliego and Liz Stanton, PhD
February 2021
On February 25, 2021, Researcher Joshua Castigliego and Clinic Director and Senior Economist Liz Stanton, PhD presented on the future of gas in Massachusetts for the Union of Concerned Scientists. Mr. Castigliego and Dr. Stanton spoke on today's planned gas investments, the transition towards cleaner energy sources to meet the Commonwealth's climate goals, and the declining cost of electric heating over the next decade.
Authors: Joshua R. Castigliego, Tanya Stasio, and Liz Stanton, PhD
December 2020
In response to a question posed by Gas Leak Allies, Researcher Joshua Castigliego, Research Assistant Tanya Stasio, and Clinic Director and Senior Economist Liz Stanton, PhD prepared a policy brief that calculates the costs (including financial returns to investors) of repairing Massachusetts' leaky gas system. Our assessment finds that it would take over 90 years to fully pay off the $15.5-$16.6 billion required to replace Massachusetts' leak-prone gas infrastructure. However, new gas pipes installed today will become obsolete in 30 years as Massachusetts makes the changes needed to achieve net-zero emissions by 2050. To stay on track to meet the Commonwealth's 2050 climate goals, the gas industry needs a managed transition geared towards the most efficient and equitable outcomes for customers.
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.
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.
Authors: Liz Stanton, PhD
August 2020
On August 11, 2020, Clinic Director and Senior Economist Liz Stanton, PhD, presented at a meeting on Climate Impacts Considerations in Electricity Advocacy, held by the National Association of State Utility Consumer Advocates Electricity Committee. Dr. Stanton spoke on building electrification and the transition away from gas.
Client: Gas Leak Allies
Author: Joshua R. Castigliego and Liz Stanton, PhD
June 2020 (Updated Sept. 2020)
On behalf of the Gas Leak Allies, Researcher Joshua Castigliego and Clinic Director and Senior Economist Liz Stanton, PhD prepared a policy brief that compares the costs of status quo gas system repair in Massachusetts to the costs of repair under the FUTURE Act. The “FUTURE Act” (An Act For a Utility Transition to Using Renewable Energy, H.2849, S.1940) was introduced in the Massachusetts Legislature in early 2019. The Act aims not only to address existing safety challenges, but also to create a path forward for gas distribution companies to move away from the fossil fuel delivery business and be a part of the clean energy transition. Our assessment finds that Massachusetts’ FUTURE Act (if passed) could save consumers $10.7 billion while transitioning the Commonwealth to a zero-carbon, renewable thermal future.
Client: Town of Ashland
Authors: Liz Stanton, PhD, Joshua R. Castigliego, Bryndis Woods, and Eliandro Tavares
May 2020
Clinic Director Liz Stanton, PhD, Researchers Joshua Castigliego and Bryndis Woods, and Assistant Researcher Eliandro Tavares authored this white paper on behalf of the Town of Ashland to assess the need for the Hopkinton-Ashland Transfer Line Replacement project. Proposed by Eversource to the Massachusetts Energy Facilities Siting Board in 2018, Eversource maintains that the pipeline is required to address current and future customer gas demand, as well as the need for redundancy in the gas delivery system. AEC found that Eversource's claims are not strongly substantiated, include errors/omissions, and do not adequately consider alternatives to building additional gas infrastructure. Overall, this white paper deems the project unnecessary in satisfying both current and expected gas demand, that redundancy is not the planning standard in the state, and that the pipeline contradicts emissions targets and climate laws as Massachusetts transitions to a zero-carbon future.
Client: Earthjustice
Authors: Bryndis Woods, Sagal Alisalad and Liz Stanton, PhD
March 2020
On behalf of Earthjustice, Researcher Bryndis Woods, Assistant Researcher Sagal Alisalad and Senior Economist Liz Stanton, PhD prepared a report that reviews New York State’s past progress on its new climate law as it applies to the electric sector. We find that the state has its work cut out for it in meeting its ambitious targets regarding: renewable energy development, energy efficiency, and greenhouse gas emissions reductions. Given historical trends in these areas, New York will need to dramatically scale up its efforts, beginning immediately, to reach its goals. Importantly, we also find that solar, wind and solar plus storage technologies are feasible and immediately available, and that currently planned gas capacity is at odds with the state’s renewable energy and emission reduction goals and will, therefore, impose unnecessary costs on New York consumers.
Client: Town of Weymouth
Author: Liz Stanton, PhD
February 2020
On behalf of the Town of Weymouth, Clinic Director and Senior Economist Liz Stanton, PhD provided Applied Economics Clinic expert testimony to Docket 19-132 before the Massachusetts' Department of Public Utilities. In her testimony, Dr. Stanton examined whether National Grid's proposed Atlantic Bridge Agreement meets the following criteria: (1) the public need for this capacity based on forecasted demand and available alternatives, (2) the public need for this capacity based on price, and (3) consideration of evidence relevant to the Global Warming Solutions Act ("GWSA"). Dr. Stanton concluded that National Grid failed to prove the necessity, cost-effectiveness, and GWSA compliance of the proposed Atlantic Bridge Agreement.
Client: Mothers Out Front
Liz Stanton, PhD, and Eliandro Tavares
September 2019
On behalf of Mothers Out Front, Clinic Director and Senior Economist Liz Stanton, PhD, and Assistant Researcher Eliandro Tavares prepared a white paper that analyzed the need for the Hampton Roads spur of the Atlantic Coast Pipeline. The white paper concludes that: Virginia Natural Gas (VNG) has substantially overstated its annual peak demand growth forecasts; VNG has presented no evidence that any gas supply constraint could affect electric supply in the region; and any industrial gas curtailments in the Hampton Roads area appear to have been voluntary in exchange for price reductions.
Client: Conservation Law Foundation
Liz Stanton, PhD
September 2019
On behalf of Conservation Law Foundation, Clinic Director and Senior Economist Liz Stanton, PhD provided Applied Economics Clinic expert testimony in Dockets 17-152 and 17-189 before the New Hampshire Public Utilities Commission. In her testimonies, Dr. Stanton addressed the need to evaluate the environmental impacts of new gas infrastructure as it relates to climate change. Her testimonies concluded that Liberty Gas’ least cost integrated resource plan fails to adequately address the climate change impacts of the Company’s planned expansion of gas.
Client: Appalachian Voices
Authors: Liz Stanton, PhD and Eliandro Tavares
July 2019
On behalf of Appalachian Voices, Clinic Director and Senior Economist Liz Stanton, PhD and Assistant Researcher Eliandro Tavares prepared a report that uses publicly available data and documents to examine the need for the Mountain Valley Pipeline (MVP) Southgate project, concluding that neither the developer nor the gas utility have demonstrated the need for MVP Southgate. The report finds that:
MVP LLC has not provided sufficient evidence of the need for MVP Southgate.
PSNC’s forecasts of gas demands are higher than other publicly available forecasts for the region.
Lower gas demand forecasts eliminate or delay the need for additional supply capacity.
Cost-effective supply- and demand-side alternatives exist to new pipeline infrastructure.
Client: Gas Leak Allies
Authors: Bryndis Woods, Liz Stanton, PhD, and Eliandro Tavares
November 2018 - May 2019
Researcher Bryndis Woods, Clinic Director and Senior Economist Liz Stanton, PhD, and Assistant Researcher Eliandro Tavares prepared a policy brief discussing natural gas leaks in Massachusetts and assessing the return on investment for gas leak repairs in the Commonwealth.
The policy brief estimates the payback period for repairing two volume-based categories of non-explosion-hazard gas leaks (called “Grade 3” leaks):
Leaks of Significant Environmental Impact (“Grade 3 SEI”): The top 10 percent of Grade 3 leaks, which is responsible for approximately 53 percent of lost gas.
Other Grade 3 leaks: The bottom 90 percent of Grade 3 leaks, which is responsible for 47 percent of lost gas.
The policy brief concludes that, while the average cost to fix a Grade 3 leak is approximately the same ($3,740) regardless of the leak volume, the cost of lost gas is not. Grade 3 SEI leaks cost $3,850 a year in lost gas, on average, while Other Grade 3 leaks cost $380. This ten-to-one difference in the cost of leaked gas means that SEI leaks pay for their own repairs ten times faster than other Grade 3 leaks; in 1 year versus 10 years, respectively (see Figure above).
This policy brief is the second of two AEC publications on behalf of Gas Leak Allies. Our April 2019 policy brief analyzed performance-based incentives that can align Massachusetts natural gas utilities' business interests with their responsibility to reduce emissions.
Client: Gas Leak Allies
Authors: Bryndis Woods, Liz Stanton, PhD, and Ricardo Lopez, PhD
November 2018 - April 2019
Researcher Bryndis Woods, Clinic Director and Senior Economist Liz Stanton, PhD, and Senior Researcher Ricardo Lopez, PhD, prepared a policy brief discussing how Massachusetts' natural gas utilities currently receive compensation, the inconsistencies between utilities' incentives and the Commonwealth's legally mandated emission reductions, and the performance-based incentives that can align gas utilities' business interests with their responsibility to reduce emissions.
This policy brief is the first of two AEC publications on behalf of Gas Leak Allies. A forthcoming policy brief will analyze the return on investment for gas leak repairs in the Commonwealth.