Tackling Extreme Heat: Recommendations for Strengthening Massachusetts Policy

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.

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.

Link to Rebuttal Testimony

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 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.

Link to Testimony

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

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

Distributed Energy Storage: The Missing Piece in North Carolina's Decarbonization Efforts

Client: Clean Energy Group (CEG)

Author: Tanya Stasio, PhD, Elisabeth Seliga, Deja Garraway, Bryndis Woods, PhD, Elizabeth A. Stanton, PhD

December 2023

On behalf of the Clean Energy Group (CEG), Researcher Tanya Stasio, Assistant Researcher Elisabeth Seliga, Researcher Deja Torrence, Senior Researcher Bryndis Woods, and Senior Economist Elizabeth A. Stanton prepared a report that identifies distributed energy storage as the missing piece in North Carolina's decarbonization efforts. Distributed energy storage can provide load management to help meet peak electric demand and reduce the need for costly and polluting fossil fuel peaker plants. When paired with solar PV, distributed energy storage batteries can provide clean backup power to improve energy resilience while reducing home energy bills.

To support North Carolina’s decarbonization efforts and equity goals, this report makes three key policy recommendations for increasing incentives and lowering barriers to distributed energy storage deployment:

Approve and expand utility deployment of equitable distributed solar and distributed energy storage pilot programs.
Create statewide financial incentives for residential and community-based distributed solar and behind-the-meter battery installations.
Establish equity, climate, and energy performance-based metrics and targets for electric utilities.

Link to the Report

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.

Link to Testimony

Link to Report (English)

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 (Español)

Return to Publications

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 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.

Link to Presentation

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

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.

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.

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.