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

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Alabama Power’s Plant Miller: An Economic Assessment of Alternative Portfolios

Client: Southern Environmental Law Center (SELC)

Authors: Joshua R. Castigliego, Jordan Burt, PhD, and Tyler Comings

July 2025

On behalf of the Southern Environmental Law Center, Senior Researcher Joshua R. Castigliego, Researcher Jordan Burt, PhD, and Principal Economist Tyler Comings prepared a report that evaluates four alternative portfolios to demonstrate that the continued business-as-usual (BAU) operation of Alabama Power’s James H. Miller Jr. Electric Generating Plant (also known as “Plant Miller”) is uneconomic and not in the best interest of customers.

One method of comparing alternative resource portfolios is to examine customer costs on a “levelized” basis—which normalizes total costs by total generation (in megawatt-hours or “MWh”) over an assumed time period. The levelized cost of energy (LCOE, in $ per MWh) provides insight into how each of the alternative portfolios compare to one another regardless of the total energy provided by each portfolio. Among its four modeled alternatives, AEC finds that replacing Plant Miller with clean energy and storage resources is cheaper on a levelized cost basis than keeping the plant operational into the 2040s.

Alabama Power should also continually evaluate the costs and risks of keeping the plant on-line by looking at viable alternatives. Although the alternative portfolios presented in this report are meant to be illustrative, the results of the analysis have demonstrated that the continued operation of Plant Miller (with or without carbon sequestration retrofits) is uneconomic, and Alabama Power would be able to provide customers with cost savings by investing further in clean energy resources. In order to determine the most cost-effective replacement of Plant Miller, Alabama Power should periodically conduct capacity expansion modeling that considers the retirement of Plant Miller in the context of the Company’s entire system.

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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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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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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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Duke KY IRP Comments

Client: Sierra Club

Authors: Tyler Comings, Joshua R. Castigliego, and Jordan Burt

January 2025

Principal Economist Tyler Comings, Senior Researcher Joshua Castigliego, and Researcher Jordan Burt co-wrote comments on the Duke Energy Kentucky 2024 Integrated Resource Plan (IRP). The comments focused on the utility's decision to co-fire a coal unit (East Bend Unit 2) with natural gas. We found that full conversion of the unit to gas was more cost-effective and reduced regulatory risk. 

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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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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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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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The Interconnection Bottleneck: Why Most Energy Storage Projects Never Get Built

Image Credit: Sara Levine | Pacific Northwest National Laboratory

Client: Clean Energy Group

Authors: Chirag Lala, Jordan Burt, and Sachin Peddada

May 2023

On behalf of the Clean Energy Group, Researcher Chirag Lala and Assistant Researchers, Sachin Pedadda and Jordan Burt prepared a report that assesses the obstacles preventing efficient interconnection of distributed energy storage resources. This Applied Economics Clinic (AEC) white paper identifies and explains these interconnection barriers in Massachusetts and makes recommendations to state agencies and working groups overseeing interconnection, distribution utilities, independent system operators, and the Federal Energy Regulatory Commission.  

AEC staff make these five key recommendations to stakeholders: (1) Develop proactive, integrated, and system-wide interconnection planning that takes a systemic view of applications and separates hosting capacity upgrades from particular project or cluster applications and makes hosting capacity upgrades in anticipation of grid-needs and future interconnection volume. (2) Continuously iterate interconnection processes to build in regular improvements, examine effectiveness, and coordinate public and private stakeholders to tackle ad hoc coordination problems. (3) Tackle barriers and solutions comprehensively by integrating multiple solutions. (4) End cost causation by spreading distribution system upgrade costs over a broader set of stakeholders (including ratepayers) than just allocating those costs to the projects or clusters applying for interconnection. (5) Incorporate storage operational parameters into interconnection processes so that storage resources are assessed in a manner reflecting how they would reasonably be expected to operate once interconnected alone or in conjunction with technologies regulating bidirectional power flows and facilitating predictable charging and discharging.

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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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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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Overburdened Communities and Power Plants in New Jersey

Authors: Sagal Alisalad, Tanya Stasio, PhD, Elisabeth Seliga, and Sachin Peddada, and Jordan Burt

Assistant Researcher Sagal Alisalad, Researcher Tanya Stasio, PhD, Assistant Researchers Elisabeth Seliga, and Sachin Peddada, and Research Assistant Jordan Burt prepared a policy brief on how New Jersey power plants disproportionately affect overburdened communities.

New Jersey environmental justice law defines overburdened communities as census blocks where at least a third of the household is low income, 40 percent of residents identify as racial-ethnic minorities, or 40 percent have low English proficiency. These communities are disproportionately affected by the pollutants emitted by power plants. AEC researchers explain that environmental justice initiatives will require full understanding of the impacts on vulnerable communities.

Link to Policy Brief

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