Comments Regarding STREAM’s Proposed Data Center

Client: Tonawanda Seneca Nation and Sierra Club Niagara Group

Author: Bryndis Woods, PhD 

April 2026

In January 2026, STREAM U.S. Data Centers, LLC (STREAM) applied to the Genesee County Economic Development Center to construct a 2.2 million square-foot data center campus in the Town of Alabama, New York, located in Genesee County. On behalf of Tonawanda Seneca Nation and Sierra Club Niagara Group, Senior Analyst Dr. Bryndis Woods drafted comments that address STREAM’s proposed data center, including its claimed costs and benefits for the local community. STREAM does not provide any supporting materials for its cost-benefit analysis (CBA), which fails to meet standards expected in a public decision-making process and is insufficient to determine whether the proposed project would provide net benefits for the local community.

Other key findings include:

• The project would require electric capacity that is about four times the total capacity currently operating in Genesee County.

• STREAM’s CBA results differ substantially from one CBA to the next.

• STREAM has failed to address numerous potential costs associated with the project.

• STREAM’s job creation estimates exceed values found in publicly available data and information.

• STREAM has requested tax abatements that are worth 25 times more than the benefits provided by the proposed PILOT/Host payments.

• Valuing data centers is challenging and complex.

• STREAM’s proposed data center may negatively impact local tourism and recreation, which are an integral part of the community and economy.

  
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Background Report: Evaluation of Connecticut Medical Protections

Client: Connecticut Public Utilities Regulatory Authority

Authors: Tanya Stasio, PhD, Sagal Alisalad, Elizabeth A. Stanton, PhD, Jordan Burt, PhD, Joshua R. Castigliego, and Bryndis Woods, PhD 

March 2026

On behalf of Connecticut Public Utilities Regulatory Authority, Senior Researcher Tanya Stasio, PhD, Researcher Sagal Alisalad, Principal Economist Liz Stanton, PhD, and AEC staff prepared a background report that evaluates Connecticut's electric and gas utility shutoff policies for medically protected customers. Most of Connecticut's medically protected customers have year-round shutoff protection and, as a result, maintain average arrearages that are thousands of dollars more than customers without medical protections. While limiting shutoff protections may increase utility revenues and reduce ratepayer costs, AEC finds that introducing payment or financial hardship requirements to Connecticut shutoff protections for medically protected customers could cost the State of Connecticut millions by way of increased need for social services. 

This report was included as an Appendix to Connecticut Public Utilities Regulatory Authority's Report to the General Assembly Regarding the Evaluation of Medical Protection available here.

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Assessing Ratepayer Risks of the Proposed Edisto Gas Plant in South Carolina

Client: Conservation Voters of South Carolina (CVSC)

Authors: Joshua R. Castigliego, Elisabeth Seliga, Jordan Burt, PhD, Sagal Alisalad, and Bryndis Woods, PhD

March 2026

On behalf of the Conservation Voters of South Carolina (CVSC), Senior Researcher Joshua R. Castigliego, Assistant Researcher Elisabeth Seliga, Researchers Jordan Burt, PhD and Sagal Alisalad, and Principal Analyst Bryndis Woods, PhD prepared a report that evaluates Santee Cooper and Dominion Energy South Carolina’s December 2025 Joint Application to build a new jointly owned, 2,180-MW natural gas-fired combined cycle generating facility—the proposed “Edisto Gas Plant” or Canadys Joint Resource—on the banks of the Edisto River. The report examines the risks that the project could pose to South Carolina ratepayers if approved by the South Carolina Public Service Commission.

In the report, AEC identifies three primary risks to ratepayers (i.e. the potential for electric customers to face higher costs) as a result of new gas-fired capacity like the proposed Edisto Gas Plant to meet increasing electric demand: (1) uncertain forecasts of customer demand, which could leave ratepayers paying for unused capacity; (2) higher-than-expected capital costs, including from construction delays and cost overruns; and (3) fuel price uncertainty, which can increase operating expenses and, ultimately, electric rates and customer bills. AEC's review of the Companies’ Joint Application reveals several significant concerns related to these risks.

Understanding risks to South Carolina ratepayers, individually and collectively, underscores the importance of prudent utility planning and the need for the Commission to carefully consider whether approving the Companies’ Joint Application for the proposed Edisto Gas Plant would expose ratepayers to unnecessary risk, particularly when alternative, lower-risk pathways may exist that the Companies have not fully evaluated.

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Testimony on Southwestern Public Service Company's (SPS) Application to Construct New Generation Facilities

Client: Sierra Club

Authors: Bryndis Woods, PhD

February 2026

On behalf of Sierra Club, Principal Analyst Dr. Bryndis Woods filed testimony before the Texas Public Utility Commission regarding SPS's Application to amend its Certificate of Convenience and Necessity (CCN) to construct eight new generation facilities totaling over 4,100 megawatts in Texas and New Mexico. 

Dr. Woods' direct testimony evaluates three issues in SPS’s Application: 1) the claim that additional generating capacity is needed to serve large-load interconnection requests; 2) the Company's approach to pursuing solar and wind resources; and 3) the potential impacts of the forthcoming expansion of SPS’s regional grid operator, Southwest Power Pool (SPP). Dr. Woods' recommendations included that the Commission require SPS: include only contractually committed new loads in its base load forecast; establish consumer protections for new large loads; utilize available surplus interconnection capacity to develop additional wind and solar projects; and assess the potential impacts of SPP's expansion.

Dr. Woods' cross-rebuttal testimony focused on additional issues in the proceeding, including that: SPS's Island Case modeling should not be used to make determinations regarding resource reliability; battery storage projects contribute significantly to grid reliability during extreme winter weather events; new gas pipeline capacity in the Permian Basin favors retirement of coal-fired units at the Tolk plant; and any extension of Tolk's coal-fired units would entail significant costs. 

Link to Direct Testimony

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Risks of New Gas-Fired Generation in Arizona

Client: Western Resource Advocates (WRA)

Authors: Bryndis Woods, PhD, Elisabeth Seliga, Alicia Zhang, Brady Dye, and Elizabeth A. Stanton, PhD

February 2026

On behalf of Western Resource Advocates (WRA), a new AEC report assesses the risks associated with new gas-fired electric generation in Arizona.

The report finds that Arizona’s electric sector is dominated by gas-fired resources and much more gas-fired capacity is currently proposed. Arizona’s utilities claim that new gas-fired generation is needed to address reliability challenges and meet anticipated growth in electric demand. However, the report finds that building new gas-fired generation hurts reliability and exposes Arizona’s residents and ratepayers to six serious risks: 1) More gas generation means higher electric bills; 2) Overreliance on gas-fired generation; 3) High electric bills due to high gas prices; 4) Gas pipelines and storage constraints; 5) Growing electric demand; and 6) Human health and safety impacts.

The report concludes that, rather than furthering reliance on gas, Arizona’s utilities should instead prioritize resources that stand to benefit the state’s residents and ratepayers. Solar, wind, battery storage, energy efficiency, and demand-side management resources lower costs, diversify Arizona’s energy mix, are not reliant on fuel supply, and reduce pollution.

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Evaluating Load Management Strategies for a Net Zero Grid in Massachusetts

Client: Massachusetts Department of Energy Resources (DOER)

Authors: Bryndis Woods, PhD and Tanya Stasio, PhD

December 2025

On behalf of the Massachusetts Department of Energy Resources (DOER), Principal Analyst Bryndis Woods, PhD and Senior Researcher Tanya Stasio, PhD contributed to an assessment of load management potential in Massachusetts in futures aligned with deep decarbonization and the Commonwealth’s Climate and Clean Energy Plan (CECP) goals. The assessment was led by Energy + Environmental Economics (E3) and AEC supported by leading the development of resiliency and equity impacts of load management resource deployment and managing the advisory group and stakeholder sessions.

AEC managed a total of four advisory group meetings and two public stakeholder workshops between May and September 2025. AEC's analysis included the development of a Social Vulnerability Index (SVI) that identified disadvantaged communities in Massachusetts by assessing their vulnerability across ten measures (e.g. income, race/ethnicity, energy burden). We find that mindful design of programs to support load management strategies can improve outcomes for disadvantaged communities (e.g. reduced energy burden, reduced outages).

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Link to DOER Project Webpage

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GreenRoots’ Pathway to Interconnection

Client: GreenRoots

Authors: Sagal Alisalad and Bryndís Woods, PhD

November 2025

On behalf of GreenRoots, Researcher Sagal Alisalad and Principal Analyst Bryndís Woods, PhD, prepared a report summarizing GreenRoots’ experience applying to interconnect three behind-the-meter (BTM) projects to the electric grid: 1) Chelsea City Hall (solar and storage), 2) Chelsea Police Department (solar and storage), and 3) Municipal Public Works Yard (rooftop solar). AEC examined the obstacles and complexities of the interconnection process for small- and medium-sized customers like GreenRoots. This analysis highlights how these barriers hinder a community’s ability to develop community-owned BTM resources.

AEC recommends that decision-makers, utilities, and communities collaborate to address barriers to interconnection in order to boost community resiliency, support the clean energy transition, help the Commonwealth reach its clean energy and emission reduction goals, and ensure energy systems in the Commonwealth benefit everyone.

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Equity Advisory Working Group Recommendations: Equity Metrics for the District of Columbia's Benefit-Cost Analysis Model and Stakeholder Engagement for Utility Planning

Client: Public Service Commission of the District of Columbia (DC PSC)

Authors: Bryndis Woods, PhD, Elizabeth A. Stanton, PhD, Sagal Alisalad, Alicia Zhang, Jordan Burt, PhD, and Elisabeth Seliga

July 2025

On behalf of the Public Service Commission of the District of Columbia (DC PSC), AEC—together with our partner Visionary Leadership Group—convened and facilitated a seventeen-member Equity Advisory Working Group (EAWG) to recommend: 1) Criteria for designating Priority Populations in the District; 2) Racial equity, energy burden, and low- and moderate-income metrics for inclusion in the District’s evaluation framework for utility proposals; and 3) A stakeholder accountability process to facilitate local resident engagement and representation in utility proposal decision-making processes. EAWG members attended 10 meetings between January and May 2025. At each meeting, EAWG members were given presentations and supporting materials developed by AEC to ensure that all EAWG members had the information they required to make their recommendations, such as how BCAs work for proposed utility programs, or examples of  equity metrics from the publicly available literature. AEC was also responsive to requests from EAWG members, such as by designing and modifying priority population definitions, providing equity metric methods and data, and presenting map visualizations of how different priority population definitions capture different District communities. The report presents the EAWG’s 29 recommendations which—if adopted—will help ensure that social and racial equity are included in electric and gas utility planning processes and that the disproportionate and systemic harms related to the current energy system, climate change, and environmental injustice are considered and addressed for all District communities.

Errata: On page 55 of the report, it states that "15 percent of DC households are classified as low income." This should read "19 percent of DC households are classified as low income." On page 57 of the report, it state that "The District’s moderate-income households make more than $32,000 but less than $88,000—a group that includes 25 percent of households District-wide." This should read "The District’s moderate-income households make more than $32,000 but less than $88,000—a group that includes 32 percent of households District-wide."

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Amicus Curiae in the Case of Genesis B. v. United States Environmental Protection Agency

Author: Liz Stanton, PhD

July 2025

Principal Economist Elizabeth A. Stanton led AEC Staff in drafting an amicus curiae brief submitted on appeal from the United States District Court for the Central District of California, No. 2:23-cv-10345, in the case of Genesis B. v. United States Environmental Protection Agency (EPA). The Genesis plaintiffs (a group of 18 youths) argued that the EPA violated their right to equal protection of the law through discriminatory discounting of children’s lives when making environmental decisions.

In the brief, the amici curiae contend that discounting practices used by the EPA are detrimental to children and future generations, and that the dismissal of the case “reflects fundamental misunderstandings of the economics of discounting.” The Plaintiffs’ amended complaint challenged the EPA’s policy of positive social discounting, which privileges current adults while giving less weight to today’s children that will be affected by the harms of today’s environmental policies in the future. The brief concludes that the EPA’s current analyses do not give full weight to the long-term benefits of pollution reduction policies enacted now and advises the Court to reverse the District Court’s dismissal.

Signatories to the amicus curiae brief: Dr. Elizabeth A. Stanton, Dr. Eban Goodstein, Dr. Robin Hahnel, Dr. James K. Boyce, Dr. Gerald Epstein, Dr. Michael Ash, Dr. Bryndís Woods, Dr. Jordan Burt, and Dr. Tanya Stasio.

Link to Brief

News: Economists, physicians and legal scholars back kids climate lawsuit

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Basin Electric's Coal Fleet: Risks to Continued Operation and Opportunities for Replacement

Authors: Bryndis Woods, PhD, Joshua R. Castigliego, Jordan Burt, PhD, Elisabeth Seliga

Client: Western Organization of Resource Councils

June 2025

On behalf of the Western Organization of Resource Councils, this AEC report evaluates the risks associated with continued operation of Basin Electric’s coal-fired plants and outlines opportunities for replacement with lower-cost clean energy resources. The continued operation of Basin Electric’s coal plants entails important risks to Basin Electric, its members and members’ ratepayers, including risks presented by: 

1. Federal oversight: In 2019, Basin Electric became subject to Federal Energy Regulatory Commission (FERC) oversight, which means Basin Electric is facing greater scrutiny of whether continued operation of its coal plants is most prudent for its members and their ratepayers. 

2. Competition in Southwest Power Pool (SPP): Basin Electric’s forthcoming full membership in the Southwest Power Pool (SPP) risks that Basin Electric’s coal plants will operate less often because more of its coal generation will compete in every hour of the day with every other resource in SPP’s marketplace.

3. Environmental regulations: There are cost risks for Basin Electric’s coal-fired power plants related to new emission and pollution control technologies to comply with federal environmental regulations including: the Regional Haze Rule, the coal ash waste rules, and carbon pollution standards.

AEC finds that Basin Electric can hedge against risks to its coal-fired resources by taking advantage of cost-saving opportunities to replace coal resources with cheaper wind and solar resources—resources which become even more cost-effective when coupled with federal incentives, funding, and financing streams targeted specifically at electric cooperatives to pursue them. 

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Assessing U.S. Electric Grid Operators' Governance: Transparency, Accessibility, Accountability

Authors: Bryndis Woods, PhD, Deja Garraway, Alicia Zhang, PhD, Sagal Alisalad, Sumera Patel

Client: Slingshot

May 2025

On behalf of Slingshot (and their participation in the broader, grassroots Fix the Grid campaign in New England), this AEC report card utilized approximately 250 sources—including grid operator documents, research reports, and expert testimony—to develop and assign points across 34 metrics among three categories: 1) transparency is making information and materials publicly available; 2) accessibility is facilitating public awareness and involvement in grid operator processes; and 3) accountability is structuring governance and decision-making processes to incorporate viewpoints reflective of the diversity of the communities in each grid operator's territory. 

The primary finding of the report card is that none of the seven U.S. grid operators perform particularly well in any assessment category and there is considerable room for improvement across grid operators in terms of transparency, accessibility, and accountability. The highest overall grade was a C+ earned by CAISO due to its strong performance in the accountability category. The lowest overall grade was an F earned by ISO-NE due to its receiving a failing grade in the accessibility and accountability categories. The five remaining grid operators (PJM, MISO, SPP, ERCOT and NYISO) each received an overall grade ranging from C- to D-.

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Link to Workbook

News: Consumer Liaison Group Discusses ISO-NE’s Failing Accessibility Grade, June 4, 2025

News: ISO-NE should make its governance transparent, accessible and accountable, August 13, 2025

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Michigan City Generating Station Closure: Environmental Implications and Community Benefits

Client: Just Transition Northwest Indiana (JTNWI)

Authors: Bryndis Woods, PhD, Deja Garraway, Lila McNamee, Sumera Patel, Elizabeth A. Stanton, PhD

December 2024

On behalf of Just Transition Northwest Indiana (JTNWI), AEC assessed the retirement of Michigan City Generating Station (MCGS)—a 93-year-old coal-fired power plant located on the southern shore of Lake Michigan in Michigan City, Indiana. AEC's report presents the environmental and community impacts of MCGS' retirement, outlines opportunities for just and equitable redevelopment of the MCGS site, presents eight related case studies of coal plant redevelopment efforts, and makes five recommendations for a just transition for Michigan City to ensure that the communities most impacted by MCGS’ operations benefit from redevelopment. 

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Best Practices in Electric Sector Load Forecasting

Authors: Elizabeth A. Stanton, PhD, Alicia Zhang, Sagal Alisalad, Bryndis Woods, PhD

November 2024

This Applied Economics Clinic (AEC) white paper examines best practices of annual and peak electric demand forecasting and provides additional examples for South Carolina. AEC asserts that conventional load forecasting methods must be updated to reflect the rapid transformation of demand trends and real-word conditions. To address these concerns, AEC recommends eight best practices to ensure thorough, transparent, and accurate load forecasts: model and data transparency; emerging policies and technologies; large industrial loads; non-energy constraints; forecasting innovation; uncertainty analysis and multiple future scenarios; post-modeling adjustments; and stakeholder review. Adopting contemporary best practices in load forecasting benefits consumers, utilities and regulators with lower costs, increased reliability, and improved facilitation of state-mandated decarbonization plans.

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Energy Storage Equity: An Assessment of Three Massachusetts Programs

Client: Clean Energy Group

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

September 2024

On behalf of the Clean Energy Group (CEG), Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga, Principal Analyst Bryndis Woods, PhD and Principal Economist Liz Stanton, PhD assessed equity provisions in three Massachusetts energy storage-incentivizing programs: the Solar Massachusetts Renewable Target (SMART) program, the Clean Peak Standard, and ConnectedSolutions. AEC finds that three energy programs assessed lack mandates, targets and reporting requirements to support the Commonwealth’s commitment to equitable access to clean and efficient energy. AEC makes eight recommendations to better align Massachusetts’ energy storage programs with its equity commitments, as well as to draw on lessons learned and best practices from similar programs in other states.

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Illinois Adult Use Cannabis Industry Disparity Study

Client: Illinois Cannabis Regulation Oversight Office

Authors: Elizabeth A. Stanton, PhD, Bryndis Woods, PhD, Tanya Stasio, PhD, Jordan Burt, Deja Garraway, Nayantara Biswas, and Alannah Shute

July 2024

On behalf of the Illinois Cannabis Regulation Oversight Office, AEC assisted the Nerevu Group, LLC in preparing a disparity study to evaluate and assess existing discrimination within the State of Illinois cannabis industry. In particular, AEC staff reviewed public and private data sources to provide utilization, availability, and disparity analyses for the Illinois economy and the Illinois cannabis industry. AEC finds evidence of significant disparities in Illinois business ownership and wages across race/ethnicity and gender. Specifically, AEC finds that, compared to White men, racial and/or ethnic minorities and women are less likely to be business owners and have less access to capital through either hourly wages or bank loans.

To cultivate a more inclusive and equitable industry, Nerevu Group, LLC recommends broadening availability of financing for cannabis businesses, improved data management, consolidating of the Illinois regulatory structure, additional disparity studies, and more industry-state collaboration along with a set of administrative recommendations.

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Equity and Environmental Justice Guidance and Recommendations

Client: the Nature Conservancy

Author: Bryndis Woods, PhD

March 2024

On behalf of the Nature Conservancy (TNC), AEC Principal Analyst Bryndis Woods, PhD provided equity and environmental justice guidance and support to TNC Northeast (and New York) Division’s government relations staff. As part of this work, AEC provided an equity and environmental justice organization library and a Diversity, Equity, Inclusion, and Justice (DEIJ) library that includes DEIJ Action Plans, Implementation Guides, Strategy Frameworks, and other related equity, environmental and social justice materials. Informed by the results of AEC’s engagement with TNC staff, Dr. Woods made nine recommendations to guide TNC staff to center and prioritize equity and justice in their work.

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Distributed Energy Storage: The Missing Piece in North Carolina's Decarbonization Efforts

Client: Clean Energy Group (CEG)

Author: Tanya Stasio, PhD, Elisabeth Seliga, Deja Garraway, Bryndis Woods, PhD, Elizabeth A. Stanton, PhD

December 2023

On behalf of the Clean Energy Group (CEG), Researcher Tanya Stasio, Assistant Researcher Elisabeth Seliga, Researcher Deja Torrence, Senior Researcher Bryndis Woods, and Senior Economist Elizabeth A. Stanton prepared a report that identifies distributed energy storage as the missing piece in North Carolina's decarbonization efforts. Distributed energy storage can provide load management to help meet peak electric demand and reduce the need for costly and polluting fossil fuel peaker plants. When paired with solar PV, distributed energy storage batteries can provide clean backup power to improve energy resilience while reducing home energy bills.

To support North Carolina’s decarbonization efforts and equity goals, this report makes three key policy recommendations for increasing incentives and lowering barriers to distributed energy storage deployment:

1. Approve and expand utility deployment of equitable distributed solar and distributed energy storage pilot programs.

2. Create statewide financial incentives for residential and community-based distributed solar and behind-the-meter battery installations.

3. Establish equity, climate, and energy performance-based metrics and targets for electric utilities.

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Equity and Justice in Rhode Island’s Climate Policy

Client: The Nature Conservancy (TNC) and the State of Rhode Island Department of Environmental Management (DEM)

Author: Bryndis Woods, PhD

September 2023

On behalf of The Nature Conservancy (TNC) and the State of Rhode Island Department of Environmental Management (DEM), Senior Researcher Bryndis Woods, PhD and other AEC staff provided two environmental justice (EJ) and equity-focused training sessions for Rhode Island’s Executive Climate Change Coordinating Council (EC4), the EC4 Advisory Board (AB), and the EC4 Science and Technical Advisory Board (STAB).

The presentations included: an equity baseline for Rhode Island, including maps of Rhode Island EJ communities; foundational training on EJ and equity concepts to develop a shared understanding and vocabulary; an EJ and equity framework that provides guidance for EC4, AB and STAB to meaningfully incorporate EJ and equity in their planning and decision-making; Rhode Island-specific equity examples, including equity opportunities and common pitfalls as they relate to economy-wide decarbonization efforts; EJ scenarios for participants to consider and discuss; and recommendations for participants that will help them proactively prioritize equitable outcomes.

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Testimony on Dominion's 2023 Integrated Resource Plan

Client: Clean Virginia

Author: Bryndis Woods, PhD

August 2023

Senior Researcher Bryndis Woods, PhD filed testimony before the Virginia State Corporation Commission on Virginia Electric and Power Company’s (“Dominion”) 2023 Integrated Resource Plan (IRP). Dr. Woods' testimony addresses failures by Dominion in its 2023 IRP to:

• Meet the basic obligations of the Virginia Clean Economy Act including energy efficiency requirements, renewable energy requirements and fossil fuel retirement requirements;

• Present useful modeling results: the Company fails to identify a preferred plan, a feasible least-cost plan, or present meaningfully distinct modeling results over the planning period;

• Conduct a peak load sensitivity analysis that adequately accounts for uncertainties related to Dominion's load forecast, particularly anticipated load from data centers;

• Account for federal regulations that impact its coal fleet or consider a reasonable social cost of carbon; or

• Address environmental justice impacts of its resource planning decisions or conduct any stakeholder engagement as part of the 2023 IRP development.

As a result of these failures, Dr. Woods concludes that the Commission cannot find Dominion’s 2023 IRP to be reasonable and in the public interest, and provides specific recommendations for the Company’s IRPs moving forward.

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Comparing Connecticut's Electric Vehicle Charging Program with Others from around the United States

Prepared on behalf of Connecticut Office of Consumer Counsel

Authors: Bryndis Woods, PhD, Sachin Peddada, Jay Bonner, Liz Stanton, PhD

March 2023

On behalf of the Connecticut Office of Consumer Counsel, this Applied Economics Clinic (AEC) white paper reviews the potential for electric vehicle (EV) charging programs to provide net benefits to consumers in Connecticut and fourteen other states. AEC finds that Connecticut’s EV charging programs are well-positioned to provide net benefits to consumers and meet the state’s EV and electric vehicle supply equipment deployment goals. Connecticut stands out as a leader due to the detailed nature of its EV and EV charging deployment goals, the inclusion of alternative rate structures to incentivize public EV charging stations, the availability of incentives to cover up to 100 percent of EV charging “make-ready” costs, and enhanced incentives for underserved communities (inclusive of low-income populations). AEC also finds, however, that Connecticut’s EV charging program could be strengthened by adopting best practices from other states’ programs, such as by setting more ambitious EV and EV charging deployment goals, working to target EV charging in as equitable a fashion as possible, and by offering ongoing incentives for EV charging.

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