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

Testimony on LG&E-KU’s Certificates of Public Convenience and Necessity and Site Compatibility Certificates

Client: Kentuckians for the Commonwealth, Kentucky Solar Energy Society, Metropolitan Housing Coalition, and Mountain Association

Authors: Liz Stanton, PhD

June 2025

Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Kentucky Public Service Commission to assess the load forecasting assumptions utilized in the 2025 request for approval for Certificates of Public Convenience and Necessity (CPCN) filed by Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E-KU) in Kentucky PSC Case No. 2025-00045. In her testimony, Dr. Stanton reviews the Companies’ 2025 CPCN Load Forecast and assesses the methodology, assumptions, and findings of their economic development growth forecast, particularly as they related to projected growth in data centers.

Dr. Stanton recommends that the Companies employ a short-term forecast of new data center and other large customer load based on concrete evidence that there is a high likelihood that such load will actually come online, while discounting or excluding possible large customer load that is merely speculative or has a low likelihood of materializing, and presents an alternative framework for using probability weighting to forecast future load growth from data centers.

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 Workbook Template

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

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 Joint Intervenors’ Comments

Testimony on East Kentucky Power Cooperative Certificates of Public Convenience and Need

Client: Appalachian Citizens’ Law Center, Kentuckians for the Commonwealth, and Mountain Association

Authors: Liz Stanton, PhD

February 2025

Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Kentucky Public Service Commission (“the Commission”) in response to the 2024 request for approval of Certificates of Public Convenience and Need (“CPCN”) filed by East Kentucky Power Cooperative, Inc. (“EKPC”). In her testimony, Dr. Stanton assesses EKPC’s: annual and peak customer demand forecasts, with a focus on its Winter Peak; alternative supply resource options; modeling and resource selection methods; and rate impacts. Dr. Stanton’s review finds that EKPC has not adequately supported its winter peak demand forecast, failed to provide the modeling and analytical support needed to justify the CCGT, and failed to demonstrate that the CCGT is superior to other available alternatives such as battery storage, demand response, or peaking resources.

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:

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.
EJ and other vulnerable communities live in close proximity to the Pittsfield Generating Facility, increasing vulnerability to adverse health outcomes.
Replacing the fossil fuel-fired plant with clean energy resources can reduce emissions in the area.

Testimony on Alabama Power Company Petition for Certificate of Convenience and Necessity

Client: Energy Alabama and GASP

Authors: Elizabeth A. Stanton, PhD

January 2025

Principal Economist Elizabeth A. Stanton, PhD, submitted direct testimony before the Alabama Public Service Commission (“Commission”) in response to Alabama Power Company’s proposed Lindsay Hill Generating Station (“Lindsay Hill”) purchase. In her testimony, Dr. Stanton addresses Alabama Power’s failure to satisfactorily consider alternative resources to its proposed purchase and determines that without consideration of alternative resources, it is not possible to conclude that the Lindsay Hill purchase is the lowest cost option. Dr. Stanton’s review of Alabama Power’s Lindsay Hill Certificate of Convenience and Necessity (“CCN”) Petition finds that the proposed purchase would decrease the Company’s resource diversity and increase its reliability risks. To address these concerns, Dr. Stanton recommends the Commission require Alabama Power to:

Include portfolio diversity risks in IRP and CCN cost modeling
Issue a new Capacity request for proposals (“RFP”) that does not exclude bids by alternative resources including battery storage and solar plus storage resources
Require that cost modeling be conducted for more than one resource (or more than two versions of the same resource) to be considered for CCN approval
Reissue RFPs when there are insufficient bids submitted to obtain proposals for a minimum of four resources and three resource types.

Link to Background Report

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

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.

Michigan City Generating Station Closure: Environmental Implications and Community Benefits

Client: Just Transition Northwest Indiana (JTNWI)

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

December 2024

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

Best Practices in Electric Sector Load Forecasting

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

November 2024

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

Link to Slides

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.

Testimony on Rhode Island Energy's 2024-2025 Last Resort Service Procurement Plan

Client: Conservation Law Foundation

Authors: Elizabeth A. Stanton, PhD

September 2024

On behalf of the Conservation Law Foundation, Principal Economist Elizabeth A. Stanton, PhD, submitted expert testimony before the State of Rhode Island Public Utilities Commission in response to the Narragansett Electric Company d/b/a Rhode Island Energy’s 2024-2025 Last Resort Service Procurement Plan. In her testimony, Dr. Stanton asserts that the methodology used to create the LRS Procurement Plan and rate design must be updated “to incorporate new policy goals and legislative directives to be considered by the Commission and Division and subsequently applied to Rhode Island Energy (‘RIE’).” To address these concerns, Dr. Stanton recommends the Commission initiate a process to evaluate competing interests and policies and reach a transparent decision to guide future LRS procurement and rate design.

Link to Rebuttal Testimony

Affordable Housing and Energy Resilience in Lynn, Massachusetts: Community Land Trusts and Microgrids

Client: Neighbor to Neighbor

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

July 2024

On behalf of Neighbor to Neighbor, Researcher Deja Garraway, Research Assistant Lila McNamee, Assistant Researcher Sumera Patel, and Principal Economist Liz Stanton, PhD prepared a report discussing the potential benefits of community land trusts and community microgrids in the City of Lynn, Massachusetts. In particular, AEC finds that community land trusts and microgrids provide an opportunity to improve affordable housing outcomes for low-to-moderate income communities in the City of Lynn by, for example, supporting more permanent affordable housing, encouraging community empowerment and counteracting gentrification-induced displacement.

AEC offers four recommendations for Lynn communities to take ownership of their electric production, create long-term sustainable housing options, and provide homeownership opportunities for low- and moderate-income communities:

1. Promote awareness and knowledge of the community land trust and microgrid models,

2. Build capacity by providing funding to bring projects to scale,

3. Promote the development of affordable housing options with land acquisition, and

4. Foster long-term sustainability of community land trusts and microgrids.

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.

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.

Testimony on Duke's Roxboro Certificate of Public Convenience and Necessity Request

Client: Southern Alliance for Clean Energy, Sierra Club, and Natural Resources Defense Council

Author: Elizabeth A. Stanton, PhD

June 2024

On behalf of the Southern Alliance for Clean Energy, Sierra Club, and Natural Resources Defense Council, Executive Director and Principal Economist Elizabeth A. Stanton, PhD, provided expert testimony before the North Carolina Utilities Commission in response to Duke Energy's petition to construct a 1,360 MW gas-fired combined-cycle electric generating facility in North Carolina. In her testimony, Dr. Stanton identified five concerns with the assumptions uses and information presented to justify the new facility:

Selective treatment of temporary technical challenges as extended barriers
Overestimation of the costs of renewables and storage
Underestimation of risks as costs to ratepayers
Noncompliance with the federal Clean Air Act
Exposure of ratepayers to costs from delayed plant construction

To address these concerns, Dr. Stanton makes several recommendations regarding the Commission’s determination of Duke’s certificate of public convenience and necessity request.

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.

Return to our Work

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