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 the Proceeding on Motion of the Commission as to the Rates, Charges, Rules and Regulations of Consolidated Edison Company of New York, Inc. for Electric Service

Clients: We Act for Environmental Justice and Alliance for a Green Economy

Author: Liz Stanton, PhD

May 2022

On behalf of We Act for Environmental Justice and Alliance for a Green Economy, AEC Senior Economist Liz Stanton, PhD filed testimony on issues related to greenhouse gas emissions and compliance with New York’s Climate Leadership and Community Protection Act in Consolidated Edison’s 2022 rate case before the New York State Public Service Commission (Case 22-E-0064/65). Dr. Stanton found a significant discrepancy between the Company’s planned greenhouse gas emission reductions and the State’s established climate goals. Dr. Stanton also outlines potential solutions to eliminate this discrepancy and ensure Consolidated Edison’s emissions reduction plan adheres to New York State law.

Link to Testimony (Case 22-E-0064/65)

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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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Risk Assessment of Florida Power and Light and NextEra Energy Clean Energy Transition Plans

Client: Environmental Defense Fund

Authors: Tanya Stasio, Joshua Castigliego, Chirag Lala, and Liz Stanton, PhD

May 2022

On behalf of the Environmental Defense Fund, Researchers Tanya Stasio, Joshua Castigliego, Chirag Lala, and Director and Senior Economist Liz Stanton, PhD make recommendations for Florida Power and Light (FPL) to assist the utility in embracing the clean energy transition and reduce risks to ratepayers and its parent company, NextEra Energy's, shareholders.

Utilities across the United States are pursuing net-zero emissions targets while NextEra, the only large utility parent company that lacks an absolute carbon reduction goal, aims to reduce carbon intensity by 67 percent of 2005 levels by 2025. Moreover, FPL’s plans for the future are not aligned with NextEra’s emission rate reduction target. Based on AEC's assessment of FPL/NextEra’s transition plans and a review of electric utility climate plans, AEC offers seven recommendations for a new transition plan:

1. Coordinate NextEra and FPL transition plans

2. Establish short-, medium-, and long-term emission reduction targets, including a net zero target

3. Ramp up demand-side management efforts

4. Invest in energy storage technologies

5. Modernize the electric grid and increase renewable energy capacity

6. Consider multiple scenarios in future planning and reduce planning time horizon

7. Increase stakeholder and community engagement and continue to align plan with TCFD recommendations

Link to Report (updated May 16, 2022)

Link to Executive Summary

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Testimony on Xcel Colorado's Energy Resource Plan

Source: The Denver Post

Clients: Natural Resources Defense Council and Sierra Club

Author: Tyler Comings

October 2021

Senior Researcher Tyler Comings filed testimony on Xcel's Colorado's Energy Resource Plan (ERP), focusing on the utility's decisions for two of its coal units--Comanche unit 3 and Pawnee. Mr. Comings' testimony found that earlier retirement of Comanche unit 3 and earlier conversion of Pawnee were lower cost. He provided inputs to modeling performed by Dr. Maria Roumpani at Strategen Consulting which quantified more than $1 billion in savings (including carbon costs) from their alternative plan compared to Xcel's ERP.

Link to Answer Testimony

Link to Cross Answer Testimony

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Comments on Evergy Missouri's Integrated Resource Plan

Source: Missouri Independent

Client: Sierra Club

Authors: Tyler Comings and Joshua Castigliego

September 2021

Senior Researcher Tyler Comings and Researcher Joshua Castigliego co-authored comments with Sierra Club on Evergy Missouri's Integrated Resource Plan (IRP). AEC found several deficiencies in the utility's plan including: 1) the lack of optimization modeling, 2) limited consideration of battery storage, 3) failure to model power purchase agreements (PPAs), and 4) failure to consider other coal retirement portfolios (among others).

Link to Comments

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Utility Reporting Practices

Client: District of Columbia Office of the People’s Council

Authors: Liz Stanton, PhD

March 2021

On March 26, 2021 Senior Economist Liz Stanton, PhD presented on gas and electric utility reporting practices to the DC Climate NOI Reporting Working Group on behalf of the District of Columbia Office of the People's Council. Dr. Stanton addressed current reporting requirements for the District's utilities, how these requirements compare to those around the United States, and potential best practices for reporting.

Link to Presentation

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Fixing Massachusetts’ Leaky Pipes: When Will It Be Paid Off?

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.

Link to Policy Brief

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Planning for the Future: Massachusetts Cleans Up Its Heating

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.

Link to Policy Brief (Updated 9/22/2020)

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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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Testimony on Algonquin Gas Transport Agreement

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.

Link to Testimony

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Testimony on the Public Service Company of New Mexico's (PNM) Plan for Replacing the San Juan Coal Units

Aerial photo of San Juan Generating Station, by Doc Searls

Client: Coalition for Clean Affordable Energy (CCAE)

Author: Tyler Comings

December 2019

AEC Senior Researcher Tyler Comings filed testimony on behalf of the Coalition for Clean Affordable Energy (CCAE) on Public Service Company of New Mexico's (PNM) plan for replacing the San Juan coal units with new resources. Mr. Comings testified that CCAE's replacement plan was a viable alternative and would invest more in the existing San Juan region than PNM's replacement plan. Mr. Comings also testified to flaws in PNM's resource evaluation that were addressed in developing CCAE's plan.

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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Load Forecasting Best Practices

Client: Citizens Action Coalition of Indiana

Liz Stanton, PhD

September 2019

On behalf of Citizens Action Coalition of Indiana, Clinic Director and Senior Economist Liz Stanton, PhD gave a presentation on best practices in load forecasting to the Indiana General Assembly's 21st Century Energy Policy Development Task Force at their September 19, 2019 meeting.

Link to Presentation

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Testimony on Eversource's Proposed East Eagle Street Substation

Client: GreenRoots

Author: Bryndis Woods

May 2019 - June 2019

On behalf of GreenRoots, Researcher Bryndis Woods provided testimony on Eversource's justification for its proposed East Eagle Street Substation. Ms. Woods testified that Eversource has failed to substantiate its argument that the East Eagle Street Substation is needed to maintain reliability. Eversource's claimed reliability concerns include: increasing customer demand—despite the fact that ISO-New England's most recent load forecast is projected to decrease (see Figure above)—and a new Massport customer project—which is neither clearly identified or described. Eversource would need to provide updated load forecasts and more detailed information on the Massport project for a third-party review to determine the validity of Eversource's reliability claims.

Link to Testimony

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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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Performance-Based Incentives for Gas Utilities

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.

Link to Policy Brief

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