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:

1. Selective treatment of temporary technical challenges as extended barriers

2. Overestimation of the costs of renewables and storage

3. Underestimation of risks as costs to ratepayers

4. Noncompliance with the federal Clean Air Act

5. 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.

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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.

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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

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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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Link to Surrebuttal Testimony

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Net Emissions Savings Benefit for a Battery Storage Facility in Wendell, Massachusetts

Image source: Borrego

Client: New Leaf Energy, Inc.

Authors: Joshua R. Castigliego, Chirag Lala, and Liz Stanton, PhD

August 2022

On behalf of New Leaf Energy, Inc., Researchers Joshua Castigliego and Chirag Lala, and Senior Economist Liz Stanton, PhD conducted analysis estimating the net change in carbon dioxide (CO2) emissions resulting from New Leaf Energy’s proposed battery storage facility located in Wendell, Massachusetts. AEC estimated net emission savings of this proposed battery storage project as the sum of “positive” CO2 emissions savings (i.e., reduced emissions) from the electric grid due to charging and discharging at specific times 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.

The proposed battery facility at the Wendell site would draw power from the grid during periods in which clean, renewable energy sources are a high share of total New England generation, and discharge energy at times when mostly fossil-fuel-powered generators are displaced by this added energy. By charging using low-emission generation and displacing fossil fuel generation while discharging power, new battery resources result in lower electric grid emissions.

This publication is an update to a study originally released in November 2021 (AEC-2021-11-WP-01).

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District of Columbia Public Service Commission Formal Case No. 1167 Affidavit regarding Washington Gas and Light Company's 5 and 30 Year Plans

Author: Liz Stanton, PhD

July 2022

In July 2022, Senior Economist and Director Liz Stanton, PhD, filed an affidavit with the Public Service Commission of the District of Columbia on behalf of the Office of the People’s Counsel for the District of Columbia regarding Washington Gas and Light Company’s (WGL) 5- and 30-Year Plans as part of Formal Case No. 1167. The affidavit addressed WGL Plans’ lack of accounting for justice and equity in planning, lack of planning for fuel sources, and the need for a new cost-benefit analysis to properly analyze WGL’s Plans.

Link to Affidavit

Link to Full Comments

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District of Columbia Public Service Commission Formal Case No. 1167 Affidavit regarding Potomac Electric Power Company's 5 and 30 Year Plans

Client: The Office of the People’s Counsel for the District of Columbia

Author: Liz Stanton, PhD

June 2022

In June 2022, Senior Economist and Director Liz Stanton, PhD, filed an affidavit with the Public Service Commission of the District of Columbia on behalf of the Office of the People’s Counsel for the District of Columbia regarding materials submitted by Pepco as part of Formal Case No. 1167. The affidavit addressed Pepco’s lack of accounting for equity in planning and distribution, discrepancies between Pepco and Washington Gas and Light Company’s (WGL) climate plans, and lack of program reassessment and evaluation.

Link to Affidavit

Link to Full Comments

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Barriers and Opportunities for Green Jobs in New Jersey

Authors: Bryndis Woods, PhD, Joshua R. Castigliego, Elisabeth Seliga, Sachin Peddada, Tanya Stasio, PhD, Liz Stanton, PhD

June 2022

Senior Researcher Bryndis Woods, PhD, Researcher Joshua Castigliego, Assistant Researchers Elisabeth Seliga and Sachin Peddada, Researcher Tanya Stasio, PhD, and Senior Economist Liz Stanton, PhD prepared a report that assesses New Jersey’s current clean energy workforce, identifies barriers to green jobs that impede access to—and equitable representation within—the clean energy sector, and provides recommendations regarding how the State of New Jersey can shape policy and regulations to enhance the equity, diversity and inclusion of its clean energy jobs. AEC staff find that there are important barriers to green jobs that reinforce existing inequities in New Jersey’s clean energy workforce, including: educational/experience barriers, logistical barriers, equitable access barriers, and institutional barriers. Achieving a future of clean energy jobs in New Jersey that is diverse, equitable and inclusive will require overcoming barriers to green jobs with intentional efforts targeted at marginalized and underrepresented groups, such as racial/ethnic minorities, women, low-income households, and people with limited English proficiency.

In a companion publication to this report—Economic Impacts of a Clean Energy Transition in New Jersey—AEC assesses the job and other economic impacts associated with achieving a clean energy transition in New Jersey over the next few decades. 

Link to Report

Link to Presentation

Link to Press Release

Media Coverage - NJBiz - June 9, 2022

Media Coverage - NJ Spotlight News - June 8, 2022

Media Coverage - Asbury Park Press - June 8, 2022

Media Coverage - NJ101.5 - June 7, 2022

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Economic Impacts of a Clean Energy Transition in New Jersey

Authors: Joshua R. Castigliego, Sagal Alisalad, Sachin Peddada, Liz Stanton, PhD

June 2022

Researcher Joshua Castigliego, Assistant Researchers Sagal Alisalad and Sachin Peddada, and Senior Economist Liz Stanton, PhD prepared a report on the economic impacts associated with a clean energy transition in New Jersey that aims to achieve the State’s climate and energy goals in the coming decades. AEC staff find that adding in-state renewables and storage, and electrifying transportation and buildings creates additional job opportunities, while also bolstering the state’s economy. From 2025 to 2050, AEC estimates that New Jersey’s clean energy transition will result in almost 300,000 more “job-years” (an average of about 11,000 jobs per year) than would be created without it. AEC also identifies a variety of additional benefits of a clean energy transition, including several benefits that are conditional on the design and implementation of the transition.

In a companion publication to this report—Barriers and Opportunities for Green Jobs in New Jersey—AEC discusses equity, diversity and inclusion in New Jersey’s clean energy sector along with barriers that impede equitable representation in New Jersey’s green jobs.

Link to Report

Link to Presentation

Link to Press Release

Media Coverage - NJBiz - June 9, 2022

Media Coverage - NJ Spotlight News - June 8, 2022

Media Coverage - Asbury Park Press - June 8, 2022

Media Coverage - NJ101.5 - June 7, 2022

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