Testimony on OVEC Power Plants Subsidies and Ohio Consumer Charges

Client: Office of the Ohio Consumers’ Counsel

Author: Elizabeth A. Stanton, PhD

October 2023

On behalf of the Office of the Ohio Consumers’ Counsel, Senior Economist Elizabeth A. Stanton submitted expert testimony concerning subsidy charges related to OVEC power plants. She emphasized the need for close scrutiny by the Public Utilities Commission of Ohio (PUCO) to ensure that these charges are prudent, in the best interests of consumers, and compliant with PUCO orders. Dr. Stanton's recommendation is to disallow the collection of imprudently incurred OVEC costs from the Company's customers.

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Puerto Rico’s 2019 and 2021 Greenhouse Gas Inventories Report

Client: Puerto Rico Department of Natural and Environmental Resources (DNER)

Authors: Liz Stanton, PhD, Joshua R. Castigliego, Chirag T. Lala, Sachin Peddada,
Jay Bonner, Eliandro Tavares, Sumera Patel, Alicia Zhang, Myisha Majumder,
David Jiang, and Jordan Burt; Ramón Bueno and Kari Hewitt

July 2023

On behalf of the Puerto Rico Department of Natural and Environmental Resources (DNER), AEC staff and partners prepared a report that presents the results for Puerto Rico’s 2019 and 2021 greenhouse gas emission inventories together with 20-year emissions projections under several scenarios and sensitivities. AEC established a methodology for conducting greenhouse gas emission inventories in Puerto Rico, which went through a comprehensive quality assurance and quality control process by an Expert Panel (established for this project and composed of experts in greenhouse gas emissions measurement and Puerto Rico climate and energy issues). Using AEC’s Emissions Measurement Inventory Tool (AEC-EMIT), AEC calculates net greenhouse gas emissions released in Puerto Rico’s seven emitting sectors: (1) Power Supply, (2) Direct Fuel, (3) Industrial Processes and Product Use, (4) Transportation, (5) Agriculture, (6) Forestry and Other Land Use, and (7) Waste Management.

Puerto Rico’s 2019 Climate Change Mitigation, Adaption, and Resiliency Law (i.e., Puerto Rico Act No. 33-2019) measures mandated emission reductions against an estimated 2005 emissions level of 53.3 MMT CO₂e and calls for a 50 percent reduction relative to 2005 emissions by 2025 (26.7 MMT CO₂e). Emission levels achieved in 2021 (34.3 MMT CO₂e) represent a 36 percent reduction in emissions from 2005 levels. With 14 percentage points and 4 years left to go, Puerto Rico must find another 7.7 MMT CO₂e to eliminate. Based on the Business-as-Usual projection in AEC’s analysis, Puerto Rico’s greenhouse gas emission levels will reach their mandated levels (50 percent of 2005 levels, or 26.7 MMT CO₂e) in 2035, 10 years later than the required 2025 target.

Based on the analysis presented in this report, AEC has identified several key recommendations to further facilitate Puerto Rico’s work towards achieving its ambitious and necessary decarbonization goals set out in Puerto Rico’s 2019 Climate Change Mitigation, Adaption, and Resiliency Law, including: (1) better data collection, (2) increased climate progress reporting (3) reprioritization in rebuilding its electric sector, and (4) a new focus in transportation planning.

Link to Report (English)

Link to Report (Español)

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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.

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Carbon Capture, Utilization, and Storage and Louisiana’s Power Sector

Image Credit: Chad Davis, CC by 2.0

Client: Union of Concerned Scientists (UCS) and Louisiana Against False Solutions Coalition

Authors: Chirag T. Lala, Joshua R. Castigliego, Sachin Peddada, Liz Stanton, PhD

April 2023

On behalf of the Union of Concerned Scientists (UCS) and the Louisiana Against False Solutions Coalition, Researchers Chirag Lala and Joshua Castigliego, Assistant Researcher Sachin Peddada, and Senior Economist Liz Stanton, PhD prepared a report that assesses the viability of carbon capture, utilization, and storage (CCUS) as a decarbonization strategy in Louisiana’s power sector. AEC staff finds that CCUS is vulnerable to damage, poses risks to human health, safety, and the environment, and has a limited emissions reduction potential.

To fully understand and mitigate the risks associated with CCUS, decision-makers must assess (1) how and to what extent CCUS could negatively impact surrounding communities, (2) what policies, rules and regulations are required to ensure that CCUS deployment is conducted in a safe and responsible manner, and (3) which applications are most appropriate for CCUS versus other decarbonization alternatives. To identify the most appropriate role that CCUS could play in Louisiana’s decarbonization efforts, decision-makers must take into consideration the technical and economic feasibility, emissions reduction potential, and safety of CCUS infrastructure compared to that of alternative decarbonization strategies.

 Link to Report

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Impact of Refinery Row on the City of Corpus Christi

Client: Indigenous Peoples of the Coastal Bend

Authors: Tanya Stasio, PhD, Sachin Peddada, Elisabeth Seliga, Jordan Burt, Liz Stanton, PhD

March 2023

On behalf of the Indigenous Peoples of the Coastal Bend (IPCB), this Applied Economics Clinic (AEC) report summarizes the economic impact of the petroleum industry in Nueces County, Texas and the negative impacts of the polluting facilities located in the City of Corpus Christi and its “Refinery Row” district. While major petroleum companies have promised economic benefits, Corpus Christi's petroleum refineries employ less than 2 percent of the City's workforce. In the absence of more stringent reporting requirements and enforcement actions, Refinery Row releases high levels of harmful pollutants with minor consequences while nearby neighborhoods suffer higher rates of asthma and cancer prevalence rates than other areas in Corpus Christi. 

This report was funded through AEC's Pro Bono Fund, which provides pro bono analysis, research, testimony, policy briefs, or detailed reports to Environmental Justice groups on topics including energy economics, climate and other environmental impacts, and diversity, equity, and inclusion analysis.

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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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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.

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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.

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Testimony on The United Illuminating Company’s Proposed Clean Energy Transformation Initiatives

Prepared on behalf of The Connecticut Office of Consumer Counsel

Author: Elizabeth A. Stanton, PhD

On behalf of the Connecticut Office of Consumer Counsel, Senior Economist Elizabeth A. Stanton provided expert testimony to Docket No. 22-08-08 before Connecticut’s Public Utilities Regulatory Authority (PURA). In her testimony, Dr. Stanton reviewed The United Illuminating Company’s (UI) Application and proposed Clean Energy Transformation initiatives to assess whether they are consistent with Connecticut’s climate and clean energy policies, plans, and targets and in the best interest of ratepayers. Dr. Stanton concluded that UI has not provided enough information to adequately assess its proposed cost recovery for clean energy transformation initiatives. Dr. Stanton recommends that PURA should require electric distribution companies to do the following when seeking approval of proposed initiatives and programs: (1) submit benefit-cost analyses, (2) present comparative assessments, (3) engage in public stakeholder processes, and (4) evaluate performance based on specific metrics.

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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.

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Testimony on Washington Gas Light Company’s Application to the District of Columbia

Prepared on behalf of the Office of the People’s Counsel for the District of Columbia

Author: Senior Economist Elizabeth A. Stanton, PhD

Senior Economist Elizabeth A. Stanton submitted testimony before the Public Service Commission of the District of Columbia on behalf of the Office of the People’s Counsel for the District of Columbia in response to the Washington Gas Light Company’s (WGL) application to the Public Service Commission of the District of Columbia for authority to increase existing rates and charges for gas service. Dr. Stanton found that the WGL proposals provided limited emission reductions and that in order to achieve the goal of 60% emission reduction by 2030, the District of Columbia needs WGL climate-related proposals to provide for serious emission reductions in the near-term.

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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.

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Expert Memo: Review of Memphis Light, Gas, and Water RFP Update and Staff Power Supply Recommendation

Client: Southern Environmental Law Center (SELC)

Authors: Elizabeth A. Stanton, PhD, Joshua R. Castigliego, Myisha Majumder, Eliandro Tavares, Sachin Peddada

AEC staff conducted an assessment of Memphis Light, Gas, and Water (MLGW)’s 2020 Integrated Resource Plan on behalf of the Southern Environmental Law Center, finding multiple instances of biases in favor of gas resources and against renewables and batteries. In light of these discoveries, AEC staff recommend that the biases be addressed prior to the MLGW Board making a decision on power supply alternatives.

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Bringing Equity into Energy Reliability Decisions

Client: Environmental Defense Fund

Authors: Bryndis Woods, PhD, Sachin Peddada, Sagal Alisalad, Jordan Burt, Elisabeth Seliga, Tanya Stasio, PhD, Eliandro Tavares, Grace Wu, Elizabeth A. Stanton, PhD

AEC staff prepared a report on behalf of the Environmental Defense Fund that analyzes the connection between issues of energy system reliability and equity. This data-driven report utilizes case studies of advocates’ for more equitable energy systems real-world experiences to assess how decision-makers should account for equity when making decisions regarding system reliability. The report concludes with recommendations for future decision-making in energy system reliability, including strengthening consumer and community representation. A common theme across the real-world experiences of the advocates discussed in this report is the ways in which community engagement efforts in energy system decision-making often fall short of creating real change in energy sector decisions, and environmental justice and other under-resourced and underserved communities are often left out and left behind in decisions that directly disproportionately harm the health and wealth of their communities.

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Link to Press Release

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