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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Clean Energy Expansion: Recommendations for Georgia Power

Authors: Tanya Stasio, PhD, Jordan Burt, PhD, and Elisabeth Seliga

May 2025

Senior Researcher Tanya Stasio, PhD, Researcher Jordan Burt, PhD, and Assistant Researcher Elisabeth Seliga prepared a report that reviews the Georgia clean energy policy landscape, assesses Georgia Power’s existing fossil fuel-fired power plants and reviews Georgia Power clean energy program offerings. AEC identifies several sites of Georgia Power-owned retired and operating fossil-fuel energy infrastructure and recommends that Georgia Power consider replacing these sites with clean energy sources such as a solar plus storage facility. In addition, AEC recommends the Company re-assess retirement plans for fossil fuel plants with higher environmental costs that are expected to operate past 2025. Lastly, AEC provides recommendations to expand Georgia Power’s clean energy program offerings and increase customer participation in its existing programs.

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Identifying Priority Areas for Clean Energy Expansion and Emissions Reduction Opportunities

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

April 2025

Senior Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga, and Principal Economist Elizabeth A. Stanton, PhD, prepared a white paper that provides energy, economic, environmental, and equity criteria that can be used by states, regional organizations, or other entities to identify priority areas for clean energy expansion and emissions reduction efforts within a particular jurisdiction. In addition to providing a pathway for identifying efficient and equitable locations for clean energy expansion efforts, these criteria may be helpful for prioritizing efforts to secure funding to support clean energy projects.

Link to White Paper

Link to Workbook Template

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A Community Assessment of Health Impacts from the Pittsfield Generating Facility on Local Communities

Client: Massachusetts Clean Peak Coalition

Authors: Jordan Burt, Elisabeth Seliga, Tanya Stasio, PhD, Lila McNamee, and Liz Stanton, PhD

February 2025

On behalf of the Massachusetts Clean Peak Coalition Researcher Jordan Burt, Assistant Researcher Elisabeth Seliga, Researcher Tanya Stasio, PhD, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD, prepared a report that summarizes the negative health impacts of fossil fuel-fired emissions on communities living near the Pittsfield Generating Facility. The report identifies three key takeaways:

1. As long as the Pittsfield Generating Facility is in operation, it has the potential to produce much higher greenhouse gas emissions and co-pollutants in any given year.

2. EJ and other vulnerable communities live in close proximity to the Pittsfield Generating Facility, increasing vulnerability to adverse health outcomes.

3. Replacing the fossil fuel-fired plant with clean energy resources can reduce emissions in the area.

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Rooftop Coverage Alternatives: Assessing Benefits for Grove Hall

Client: Greater Grove Hall Main Streets (GGHMS)

Authors: Elisabeth Seliga, Sumera Patel, Joshua R. Castigliego

January 2025

On behalf of Greater Grove Hall Main Streets (GGHMS), Assistant Researcher Elisabeth Seliga, Assistant Researcher Sumera Patel, and Senior Researcher Joshua R. Castigliego prepared an issue brief examining a set of rooftop coverage alternatives (i.e., solar photovoltaic (PV), green, white, blue, and brown roofs) aimed at addressing the unique energy and environmental challenges faced by Boston’s Grove Hall community, highlighting the potential for a systems approach encompassing each rooftop coverage alternative to enhance energy efficiency and alleviate energy burden in a region characterized by urban heat island effects and a high share of environmental justice (EJ) populations. The issue brief provides actional recommendations for GGHMS to implement a combination of rooftop coverage alternatives to mitigate energy and environmental disparities, promote environmental resilience, and foster a healthier urban environment in Grove Hall.

Link to Issue Brief

Link to Works Cited

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Tackling Extreme Heat: Recommendations for Strengthening Massachusetts Policy

Client: A Better City

Authors: Tanya Stasio, PhD, Elisabeth Seliga, Jordan Burt, Lila McNamee, and Elizabeth A. Stanton, PhD

December 2024

On behalf of A Better City, Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga, Researcher Jordan Burt, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD prepared a policy brief and accompanying background report that (1) provides a discussion of extreme heat in Massachusetts and the disproportionate impact on low-income and Black, Indigenous, and People of Color (BIPOC) communities, (2) reviews policies to address extreme heat in the Commonwealth and across the United States, and (3) develops six recommendations for Massachusetts policymakers to address both short-term extreme heat emergency preparedness and long-term heat resiliency in the Commonwealth, supporting cooler neighborhoods, cooler buildings and homes, and cooler commutes.

Link to Policy Brief

Link to Background Report

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Insights from Fossil Fuel Replacement Case Studies

Client: Berkshire Environmental Action Team

Authors: Jordan Burt, Elisabeth Seliga, Tanya Stasio, PhD, Lila McNamee, and Elizabeth A. Stanton, PhD

December 2024

On behalf of the Berkshire Environmental Action Team, Researcher Jordan Burt, Assistant Researcher Elisabeth Seliga, Researcher Tanya Stasio, PhD, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD, prepared a report that reviews case studies of fossil-fuel plant conversions to clean energy resources across the country and discusses the replacement of existing peaker plants in Massachusetts to achieve statewide climate goals. The report identifies three key takeaways for the Commonwealth:

1.     Fossil-fuel sites can be desirable locations for clean energy siting

2.     Reducing reliance on fossil-fuel generation can help lessen the burden of environmental and health impacts on already overburdened communities

3.     Fossil-fuel plant conversions are a tool that can be used to achieve state and local greenhouse gas emission limits.

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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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Assessing Alternatives to the Proposed Chesterfield Energy Reliability Center (CERC)

Client: Southern Environmental Law Center (SELC)

Authors: Chirag T. Lala, Elisabeth Seliga, Joshua R. Castigliego, Elizabeth A. Stanton, PhD

July 2024

On behalf of the Southern Environmental Law Center (SELC), Researcher Chirag T. Lala, Assistant Researcher Elisabeth Seliga, Senior Researcher Joshua R. Castigliego, and Executive Director and Principal Economist Liz Stanton, PhD prepared a report that critiques the Virginia Electric and Power Company’s (d/b/a Dominion Energy Virginia) proposed Chesterfield Energy Reliability Center (CERC)—a 1,000-megawatt gas-fired combustion turbine facility—in Chesterfield, Virginia. AEC presents an assessment of an Alternative Portfolio—composed of solar, wind, and storage resources—that would provide the same energy and capacity needs as CERC, but at a lower cost. AEC finds that the midpoint of the range of likely levelized costs of the Alternative Portfolio is 52 percent less expensive than that of Dominion Energy Virginia’s proposed CERC: $263 million versus $544 million. The combination of solar, wind and storage meets CERC on peak capacity, beats CERC on annual generation, and would cost ratepayers just half of what Dominion Energy Virginia wants to spend on CERC. Notably, the Alternative Portfolio presented in this report includes neither energy efficiency nor demand response, both of which have the potential to lower costs still further. Investments in energy efficiency alone—made at levels similar to the annual investments common in numerous other states—could obviate the need for CERC by 2030 or sooner.

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Comparing Electric Supply Rates in Massachusetts

Client: Green Energy Consumers Alliance (GECA)

Authors: Joshua R. Castigliego and Elisabeth Seliga

June 2024

On behalf of the Green Energy Consumers Alliance (GECA), Senior Researcher Joshua R. Castigliego and Assistant Researcher Elisabeth Seliga prepared a policy brief that presents a cost comparison of electric supply options offered to residential customers served by investor-owned utilities in Massachusetts. AEC’s analysis finds that residential customers are paying a premium for electric supply provided by Third-Party Competitive Suppliers compared to electricity provided by electric distribution companies and Municipal Aggregation programs. AEC also finds that previous estimates of cost premiums associated with Competitive Suppliers have underestimated the extent to which they raised average residential electric rates by not considering the cost savings associated with Municipal Aggregation programs, which often offer rates lower than both Competitive Supply and Utility Basic Service.

Link to Policy Brief

Link to Appendix

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TVA’s Kingston Fossil Plant: An Economic Assessment of Replacement Alternatives

Client: Southern Environmental Law Center (SELC)

Author: Chirag T. Lala, Joshua R. Castigliego, Tyler Comings, Elisabeth Seliga

March 2024

On behalf of the Southern Environmental Law Center, Researchers Chirag T. Lala and Joshua R. Castigliego, Senior Economist Tyler Comings, and Assistant Researcher Elisabeth Seliga prepared a report that models the costs to consumers of alternatives for the soon-to-be retired Kingston Fossil Plant—a coal-fired power plant in Harriman, Tennessee that is owned and operated by the Tennessee Valley Authority (TVA). TVA’s Alternative A plan replaces Kingston with a gas-heavy portfolio that constructs gas combined cycle (CC) and combustion turbine (CT) plants, while Alternative B focuses on replacing Kingston with a clean energy portfolio that relies on solar and battery storage resources.

Among its four modeled alternatives, AEC finds the net present value costs of Alternative B—renewable and storage replacements that are self-built or procured through power purchase agreements—to be the lower cost option. This contradicts TVA’s claim that Alternative A is the lower cost option. In addition, it is not clear why TVA selected the amounts of solar and storage capacity in Alternative B. The storage capacity is exorbitant compared to the size of the Kingston plant and the solar capacity is made additional to a large amount of capacity TVA is already scheduled to build.

These irregularities are partly attributable to TVA’s failure to synchronize site specific resources assessments with an integrated planning process that provides a full range of plausible alternatives. AEC provides the following recommendations for TVA’s 2024 IRP:

• Conduct an all-resource RFP that assesses the range of resources that could reasonably be constructed.

• Consider the full set of resources that could facilitate decarbonization of TVA’s grid, including transmission and distribution, distributed energy resources, energy efficiency, demand response, and others.

• Conduct optimization modelling on all potential resources instead of on pre-selected portfolios.

• Ensure site-specific planning does not contradict TVA’s most recent IRP.

• Ensure the IRP provides plausible schedules for the installation and decommissioning of capacity.

• Use transparent assumptions and modeling inputs

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Space Heating with Heat Pumps: The Need for Alternative Rate Designs in Massachusetts

Client: Green Energy Consumers Alliance (GECA)

Author: Joshua R. Castigliego, Elisabeth Seliga, Elizabeth A. Stanton, PhD

December 2023

On behalf of the Green Energy Consumers Alliance (GECA), Researcher Joshua R. Castigliego, Assistant Researcher Elisabeth Seliga, and Senior Economist Elizabeth A. Stanton prepared a white paper that presents a preliminary assessment of costs to customers heating with air-source heat pumps, and discusses the need for alternative electric rate designs to make heating electrification cost effective in Massachusetts. An “operating cost gap” is a measure that can be used to determine whether switching from one heating system to another would be a cost-effective choice for a given household. The “cost gap” is the difference between current and expected future operating costs and can be used to compare different heating systems. A household looking to electrify its heating system by switching from a gas-fired furnace to electric heat pumps will include this operating cost gap in its decision-making. AEC’s analysis finds that an average-sized Massachusetts home heating with air-source-heat pumps (ASHPs) versus gas-fired heating results in an operating cost gap, under current gas and electric rate schedules, between $166 and $605 over the 6-month heating season between November and April.

Alternative rate designs have the potential to close the operating cost gap between heating technologies, which would make ASHPs a cost-effective heating option relative to fossil-fuel heating systems like gas-fired furnaces. By exploring and implementing alternative rate designs, Massachusetts would be able to make ASHPs more attractive to consumers, which would stimulate the widespread adoption of electric heat pumps and support its decarbonization efforts in the buildings sector.

AEC's Heating Electrification Assessment Tool (AEC-HEAT) was utilized in this analysis to estimate the heating component of a residential customer's energy usage

Link to White Paper

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AEC's Heating Electrification Assessment Tool (AEC-HEAT)

Client: Green Energy Consumers Alliance (GECA)

Author: Joshua R. Castigliego, Elisabeth Seliga

December 2023

On behalf of the Green Energy Consumers Alliance (GECA), Researcher Joshua R. Castigliego and Assistant Researcher Elisabeth Seliga developed a spreadsheet-based tool—AEC's Heating Electrification Assessment Tool (AEC-HEAT)—that (1) compares heating costs for various resource types and (2) evaluates the impact of new space heating electrification on regional peak electric use during the winter heating season.

AEC-HEAT houses two Dashboard tabs (i.e., Heating Costs Dashboard and Load Profile Dashboard) to provide users with an interface to evaluate impacts associated with space heating electrification. Users can customize the tool by selecting parameters from drop-down menus or inputting their own data values. AEC-HEAT is currently equipped to perform assessments specific to Massachusetts but has the ability to evaluate other jurisdictions pending data availability. AEC-HEAT's User Guide and Methodology document provides an overview of the tool as well as the methodological approach, parameters, and data requirements.

AEC-HEAT was utilized in the analysis for AEC’s December 2023 white paper, Space Heating with Heat Pumps: The Need for Alternative Rate Designs in Massachusetts.

Link to AEC-HEAT [Excel Workbook]

Link to User Guide and Methodology

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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.

Link to the Report

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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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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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Electric Justice: A Toolkit for the Mid-Atlantic Region

Prepared on behalf of PJM Cities and Communities Coalition

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

Energy decisions affect everyone, but local communities and businesses often lack the time and resources needed to engage in grid operator decision-making. On behalf of the PJM Cities and Communities Coalition, AEC Researcher Tanya Stasio, PhD, Assistant Researchers Elisabeth Seliga and Sachin Peddada, and Senior Economist Liz Stanton, PhD developed a report to assist coalition members and other consumer groups in advocating for greater equity in PJM Interconnection decision-making. This resource was developed with the invaluable input of representatives of organizations that sponsored the Fix the Grid campaign in New England, which is focused on rejecting fossil fuels and calling for a just and democratic energy grid.

Link to Report

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Cumulative Impact Assessment of the North Brooklyn Pipeline Project

Prepared on behalf of Sane Energy and Alliance for a Green Economy

Author: Tanya Stasio, PhD, Jordan Burt, Elisabeth Seliga, Sachin Peddada, Elizabeth A. Stanton, PhD

The National Grid Phase 5 expansion of fossil fuel infrastructure and the Vaporizer 13/14 project at the Greenpoint Energy Center create a multi-pronged set of threats to the North Brooklyn communities.

AEC Researcher Tanya Stasio, PhD, Research Assistant Jordan Burt, Assistant Researchers Elisabeth Seliga and Sachin Peddada, and Senior Economist, Liz Stanton, PhD  have prepared a cumulative impact assessment on behalf of Sane Energy and Alliance for a Green Economy to highlight the existing and overlapping socioeconomic, environmental, and health-related burdens facing the communities living near the pending Phase 5 pipeline construction and vaporizer additions at the Greenpoint Energy Center. AEC finds that the Bushwick, Bedford, and Williamsburg neighborhoods would be impacted the most from these fossil fuel expansion projects and include densely populated communities with majority BIPOC and low-income residents.

Link to Report

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Energy Storage Benefit-Cost Analysis

Prepared on behalf of the Clean Energy States Alliance

Authors: Bryndis Woods, PhD, Sachin Peddada, Elisabeth Seliga, Chirag Lala, Eliandro Tavares, Gabriel Lewis, Tsanta Rakotoarisoa, Elizabeth A. Stanton, PhD

Contributing Editor: Todd Olinsky-Paul, Clean Energy States Alliance

AEC staff prepared a report that provides a framework for state energy agencies contemplating a benefit-cost analysis (BCA) for battery storage on behalf of the Clean Energy States Alliance. AEC’s battery storage BCA framework provides guidance for state energy agencies preparing to conduct cost-effectiveness evaluation for battery storage, including information regarding: cost-effectiveness tests, discount rates, benefits, costs, sensitivity analyses, and stakeholder engagement.

Link to Report

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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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