LG&E-KU’s 2024 Integrated Resource Plan: An Assessment

Image credit: Bill McLaugh

Client: Mountain Association (MA), Kentuckians for the Commonwealth (KFTC), Kentucky Solar Energy Society (KYSES), and Metropolitan Housing Coalition (MHC)

Authors: Joshua R. Castigliego, Elizabeth A. Stanton, PhD

March 2025

On behalf of the Mountain Association (MA), Kentuckians for the Commonwealth (KFTC), Kentucky Solar Energy Society (KYSES), and Metropolitan Housing Coalition (MHC) (collectively, the “Joint Intervenors”), Senior Researcher Joshua R. Castigliego and Principal Economist Elizabeth A. Stanton, PhD prepared a white paper that sets out best practices for IRP modeling and reporting, and assesses the Louisville Gas and Electric Company (LG&E) and Kentucky Utilities Company (KU) (collectively, LG&E-KU) 2024 IRP filed on October 18, 2024 in Case No. 2024-00326 based on those criteria.

AEC’s best practices are organized into five categories: (A) Demand-Side Analysis; (B) Supply-Side Analysis; (C) Modeling Structure; (D) Selection of Recommended Plan; and (E) Stakeholder Input. Through its best-practices assessment, AEC finds that LG&E-KU’s 2024 IRP is missing critical components and includes errors in forecasting key assumptions, resulting in an overall flawed least-cost resource plan selection. LG&E-KU’s failure to follow IRP best practices results in resource decisions that are not properly informed (or justified) by comprehensive IRP modeling, leading to possible adverse effects on ratepayers. In particular, the flawed IRP findings may result in support for uneconomic resource additions in near-term CPCN applications.

Link to White Paper

Link to Joint Intervenors’ Comments

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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. 

Link to Comments

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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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Assessing the Net Emissions Benefit for a Clean Energy Facility in Wareham, Massachusetts

Client: New Leaf Energy, Inc.

Authors: Joshua Castigliego and Sumera Patel

November 2024

On behalf of New Leaf Energy, Inc., Senior Researcher Joshua R. Castigliego and Assistant Researcher Sumera Patel conducted analysis estimating the net change in carbon dioxide (CO2) emissions resulting from New Leaf Energy’s proposed clean energy facility on Maple Springs Road in Wareham, Massachusetts. This proposed facility will house solar photovoltaics (PV) and an energy storage system (ESS) (collectively referred to as “PV+ESS facility”) and require 32.7 acres of land to be cleared of trees to make way for its development.

AEC estimated net emission savings of this proposed PV+ESS facility as the sum of “positive” CO2 emissions savings (i.e., reduced emissions) from the electric grid due to renewable energy generation and “negative” CO2 emissions (i.e., increased emissions) due to land-use conversion from forestland to grassland. Combined, these two effects result in substantial net emissions savings (i.e., reduced emissions) resulting from the proposed New Leaf Energy facility: AEC’s analysis shows that the facility’s grid emissions reductions would be roughly 4.4 times greater than its added emissions due to site development.

Link to White Paper

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Evergy Integrated Resource Plans in Missouri and Kansas

Authors: Tyler Comings and Joshua Castigliego

October 2024

Principal Economist Tyler Comings and Senior Researcher Joshua Castigliego co-wrote comments on Evergy's Integrated Resource Plan (IRP) that were filed with the commissions in Kansas and Missouri. AEC's comments showed that Evergy did not fully address greenhouse gas compliance costs at its coal and gas generators. AEC also showed that Evergy overstated the costs of clean energy replacement options, and unfairly favored gas replacement.

Link to MO Comments

Link to KS Comments

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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.

Link to Report

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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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Home Heating in Massachusetts: What Influences Future Costs?

Client: Home Energy Efficiency Team (HEET)

Author: Tanya Stasio, PhD, Joshua R. Castigliego, Sumera Patel, and Elizabeth A. Stanton, PhD

March 2024

On behalf of the Home Energy Efficiency Team (HEET), Researchers Tanya Stasio and Joshua R. Castigliego, Assistant Researcher Sumera Patel, and Senior Economist Elizabeth A. Stanton prepared a white paper that estimates the average home heating costs faced by Massachusetts households using different heating technologies.

This March 2024 AEC white paper updates the home heating cost analysis conducted in AEC’s January 2021 white paper; both analyses present operating costs only, excluding the costs of purchasing or maintaining heating equipment. Updated analysis, based on the most recent data and cost projections, finds that heating with networked geothermal and ground-source heat pumps is less expensive than heating with gas-fired furnaces today and can be expected to remain so through 2050. Our findings regarding air-source heat pumps, however, point to more questions than answers: Changes in gas and electric prices over the past few years reversed our earlier findings, suggesting that notoriously uncertain forecasts of future fuel prices are of paramount importance in understanding the likely impacts of ASHP adoption on household finances.

Link to White Paper

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Testimony on National Grid’s 2023 Rate Case in Massachusetts

Source: National Grid

Client: Environmental Defense Fund (EDF) and Conservation Law Foundation (CLF)

Author: Joshua R. Castigliego

March 2024

On behalf of the Environmental Defense Fund (EDF) and Conservation Law Foundation (CLF), Researcher Joshua R. Castigliego provided expert testimony before the Massachusetts’ Department of Public Utilities (DPU) in response to National Grid’s petition to increase its base distribution rates and approve its proposed performance-based ratemaking (PBR) plan, referred to as its Comprehensive Performance and Investment Plan (CPIP). In his testimony, Mr. Castigliego specifically focused on the Company’s Infrastructure, Safety, Reliability, and Electrification (ISRE) Mechanism and performance incentive mechanisms (PIMs, including investment-based “IPIMs” and operating-based PIMs) included in its proposed CPIP. He also addressed National Grid’s proposed electrification pricing option and low-income discount rate proposal.

Based on these assessments, Mr. Castigliego found that the Company’s proposals on these topics were insufficient and should either be rejected or strengthened by DPU to better protect ratepayers and address the affordability challenges facing the National Grid’s customers. Mr. Castigliego also offered recommendations on these topics to better align National Grid’s proposals with the Commonwealth’s climate and clean energy goals and support a more equitable distribution of benefits resulting from the Company’s investments and programs

Link to Testimony

Link to Surrebuttal Testimony

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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

Link to Report

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Comments on Ameren 2023 Integrated Resource Plan

Client: Ameren 2023 Integrated Resource Plan

Author: Tyler Comings, Joshua R. Castigliego

March 2024

Senior Economist Tyler Comings and Researcher Joshua Castigliego co-wrote comments with Sierra Club on Ameren Missouri's 2023 Integrated Resource Plan (IRP) filed at the Missouri Public Service Commission. The comments focused on flaws in the IRP including the lack of a thorough evaluation of the coal units' futures, the understatement of new gas replacement costs and overstatement of clean energy costs.

Link to Comments

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Comments on Avoided Emissions from Energy Recovery in EPA’s Waste Reduction Model (WARM) v16

Author: Joshua R. Castigliego

February 2024

On behalf of the Energy Justice Network, Researcher Joshua R. Castigliego provided expert comments in Docket No. EPA-HQ-OLEM-2023-0451 on the U.S. Environmental Protection Agency’s (EPA) Waste Reduction Model (WARM) Version 16 and its supporting documentation. In his comments, Mr. Castigliego reviewed and critiqued WARM’s methodology and assumptions regarding avoided emissions from the displacement of grid electricity through energy recovery at waste incineration facilities. Mr. Castigliego determined that WARM’s current methodology and assumptions are flawed and include errors that together appear to result in an overestimation of net emission reductions from waste incineration facilities.

His assessment highlights that WARM’s assumptions contain a critical error due to its failure to consider the sales of renewable energy credits (RECs), particularly as they relate to state renewable portfolio standards (RPS), in its estimation of emissions displaced by electric generation from waste incinerators. In addition, Mr. Castigliego identified additional critiques of WARM’s current methodology for estimating electric sector emission factors: (1) WARM’s emission factors for the electric sector are too simplistic and a poor proxy for marginal emissions; (2) avoided electric emissions are best estimated using the displacement of the marginal resource; (3) wind regularly serves as the marginal resource in some regions, meaning that emitting resources are not the only ones displaced; and (4) WARM’s regions do not align with the regions that correspond to electric sector operations and dispatch decisions.

Mr. Castigliego concludes that a majority of the flaws in WARM’s grid displacement assumptions center around the misalignment with how these emissions are addressed within the electric sector. To improve the accuracy of estimating avoided emissions from energy recovery in the waste management sector, EPA must better approximate what resources are most likely to be displaced by waste incinerators based on the characteristics of these facilities compared to other resources on the grid.

Link to Comments

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AEC’s Emissions Measurement Inventory Tool (AEC-EMIT)

Author: Joshua R. Castigliego

December 2023

To support AEC’s emissions accounting work, Researcher Joshua R. Castigliego developed a spreadsheet-based tool—AEC's Emissions Measurement Inventory Tool (AEC-EMIT)—that provides users with an interface to build a greenhouse gas emissions inventory (and 20-year emissions projections) for a specific geographic region. Users can customize the tool by selecting greenhouse gases, sectors, subsectors, scenarios, sensitivities, and other information specific to their inventory. Users are also provided a dashboard to toggle select assumptions and parameters (e.g., global warming potentials, scenarios, and sensitivities, etc.). Summary tabs aggregate results across sectors and can be used to provide disaggregated sub-sector-specific results.

AEC-EMIT was utilized for AEC’s analysis on Puerto Rico’s 2019 and 2021 Greenhouse Gas Inventories Report.

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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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Economic Impacts of Offshore Wind in Connecticut

Client: Connecticut Roundtable on Climate and Jobs (CRCJ)

Author: Chirag T. Lala, Joshua R. Castigliego

October 2023

On behalf of the Connecticut Roundtable on Climate and Jobs (CRCJ), Researchers Chirag Lala and Joshua Castigliego prepared a policy brief that assesses the economic impacts associated with installing and operating 2,000 megawatts (MW) of offshore wind resources in Connecticut to meet the State’s 2030 target. The benefits of wind procurement need not flow to Connecticut’s economy if neighboring states undertake industrial development efforts and Connecticut does not. AEC’s analysis finds that a concerted policy effort to develop Connecticut’s offshore wind industry would allow the addition of these offshore wind resources to create a total of 39,880 in-state job-years (i.e., one job-year is the equivalent of one person working full-time for one year) between 2024 and 2049 as well as an estimated $5,529 million in state economic output and $4,190 million in labor income

Link to Policy Brief

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Evergy Integrated Resource Plan in Missouri and Kansas

Client: Sierra Club

Author: Tyler Comings, Joshua Castigliego

October 2023

Senior Researcher Tyler Comings and Researcher Joshua Castigliego co-wrote comments on Evergy's Integrated Resource Plan (IRP) that were filed with the commissions in Kansas and Missouri. AEC's comments focused on Evergy's bias towards choosing new gas replacement, including its assumption that new gas would become carbon-free at no cost. AEC also noted assumptions that were overly optimistic for Evergy's coal units and that the company's consideration of early retirement for some units was too limited.

Link to Missouri Comments

Link to Kansas Comments

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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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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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Evergy Kansas IRP Comments

Client: Sierra Club

Authors: Senior Researcher Tyler Comings and Researcher Joshua Castigliego

Senior Researcher Tyler Comings and Researcher Joshua Castigliego assisted the Sierra Club in comments on the Evergy Kansas Integrated Resource Plan (IRP). AEC had several criticisms of the Evergy plan, including that the company 1) failed to choose one of its alternative plans that was lower-cost and had accelerated coal unit retirements; 2) failed to conduct true optimization of coal unit retirements; 3) inflated the costs of new renewable resources; and 4) failed to consider any battery storage.

Link to Comments

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