Evaluation of Northern Indiana Public Service Company's 2018 Integrated Resource Plan

Client: Citizens Action Coalition of Indiana

Authors: Liz Stanton, PhD, Bryndis Woods, Anna Sommer, and Chelsea Hotaling

March 2019

On behalf of Citizens Action Coalition of Indiana, Clinic Director and Senior Economist Liz Stanton, PhD, Researcher Bryndis Woods, and Anna Sommer and Chelsea Hotaling with Sommer Energy, LLC, published an evaluation of Northern Indiana Public Service Company's (NIPSCO) 2018 Integrated Resource Plan (IRP). IRP's are filed with the Utility Commission to demonstrate that utilities’ decisions to retire and/or add electric generation resources are in the public interest. While technical, these evaluations provide an important benefit to utility customers and the Indiana public more widely. Third-party review of these and other utilities filings is critical to vet for errors, uncover questionable or self-serving assumptions, and make hidden value-judgments transparent. We commend NIPSCO's IRP proposal to retire its remaining coal-fired generating units by 2028 and replace all its coal capacity with renewable capacity, and acknowledge the substantial leadership demonstrated by NIPSCO in its current IRP analysis including: conducting an all-source Request for Proposals for new generation capacity, transparently discussing its model input forecasts, outputs and assumptions, and good-faith engagement with stakeholders.

This testimony is part of a joint AEC and Anna Sommers LLC series of comments on Indiana utility Integrated Resource Plans (IRPs) on behalf of Citizens Action Coalition of Indiana and Earthjustice. 

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Updated Costs of Community Choice Energy Aggregation in Boston

Client: Barr Foundation

Authors: Tyler Comings, Bryndis Woods and Myisha Majumder

February 2019

On behalf of the Barr Foundation, Senior Researcher Tyler Comings, Researcher Bryndis Woods, and Research Assistant Myisha Majumder prepared a policy brief with updated electric CCE and basic service rates for towns in Massachusetts with similar CCE programs to what has been proposed in Boston.

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Municipal Light Plant Report Card

Client: Massachusetts Climate Action Network

Authors: Eliandro Tavares

January 2019

On behalf of the Massachusetts Climate Action Network, Assistant Researcher Eliandro Tavares along with additional Applied Economics Clinic (AEC) staff reviewed data and calculations from Massachusetts Climate Action Network for their report card on Municipal Light Plants. AEC assisted in turning the data and calculations into graphs for this report card.

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A Critique of an Industry Analysis on Claimed Economic Benefits of Offshore Drilling in the Atlantic

Client: Southern Environmental Law Center

Authors: Tyler Comings, Ricardo Lopez, PhD, Bryndis Woods, and Tanya Stasio

December 2018

On behalf of Southern Environmental Law Center, Senior Researchers Tyler Comings and Ricardo Lopez, PhD, along with Researcher Bryndis Woods and Research Assistant Tanya Stasio, prepared a report on the impacts of proposed offshore oil and natural gas drilling in four southern states: Virginia, North Carolina, South Carolina, and Georgia. The report reviews the April 2018 study released by the American Petroleum Institute (API). Comings and other AEC staff determined that the API’s report inflated potential benefits of offshore drilling and failed to consider key costs and risks.

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Testimony Regarding the Joint Statewide Three-Year Energy Efficiency Plan for Massachusetts, 2019-2021

Client: Conservation Law Foundation

Authors: Liz Stanton, PhD

November 2018

On behalf of Conservation Law Foundation, Clinic Director and Senior Researcher Liz Stanton provided testimony regarding the joint statewide three-year energy efficiency plan for Massachusetts for years 2019 to 2021. The testimony provided an independent review of the petitions filed by the Massachusetts gas and electric energy efficiency program administrators to assess their consistency with the Green Communities Act (GCA), the Global Warmings Solutions Act (GWSA), and other prior Department Orders.

This report is one of three AEC publications on behalf of Conservation Law Foundation and other stakeholders in the Massachusetts Energy Efficiency Advisory Council.

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Review of Proposed CAFE and CO2 Standards

Client: California Attorney General Office and California Air Resources Board

Authors: Liz Stanton, PhD, Ricardo Lopez, PhD and Bryndis Woods

October 2018

AEC-2018-09-WP-01

On behalf of the state of California Attorney General's office and the California Air Resources Board, this Applied Economics Clinic white paper assessed the National Highway Traffic Safety Administration (NHTSA) and the U.S. Environmental Protection Agency's (EPA) August 2018 Notice of Proposed Rulemaking regarding “The Safer Affordable Fuel Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks”. If approved, the Proposed Rulemaking would revise CAFE and CO2 standards, making them less stringent. Clinic Director and Senior Economist, Liz Stanton, PhD, Senior Researcher Ricardo Lopez, PhD, and Researcher Bryndis Woods found that several of NHTSA/EPA's assumptions and conclusions are unfounded.

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Clinic Director Liz Stanton Presents at WNE Law Symposium

Authors: Liz Stanton, PhD

October 26, 2018

Clinic Director and Senior Economist Liz Stanton, PhD presented at the Western New England (WNE) Law Review Symposium on October 26, 2018. The Symposium aimed to facilitate conversation about how to build and reinforce smart, self-reliant and sustainable communities in the face of anthropocenic disruption. Dr. Stanton spoke about energy decisions made at the home, corporate, and regulatory levels.

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Testimony on Consumers Energy Integrated Resource Plan (IRP)

Consumers Energy J.H. Campbell coal plant, Source: mlive.com

Clients: Michigan Environmental Council, Natural Resources Defense Council and Sierra Club

Author: Tyler Comings

October 2018

Senior Researcher Tyler Comings filed testimony on the Consumers Energy IRP in Michigan. Mr. Comings concluded that Consumers did not adequately evaluate the potential for retiring two coal units, Campbell 1 and 2, prior to 2031. He found that the Company failed to consider enough replacement options for the units as part of its preferred plan. Modeling requested by Mr. Comings (run by Witness George Evans) showed that retirement of the two units in 2023 would save ratepayers money. 

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Report on Indiana’s 2018 Draft Statewide Analysis of Future Resource Requirements for Electricity

Client: Citizens Action Coalition of Indiana

Authors: Elizabeth A. Stanton, PhD, Ricardo Lopez, PhD, Bryndis Woods, and Tanya Stasio of the Applied Economics Clinic and Anna Sommer of Sommer Energy, LLC

September 2018

On behalf of Citizens Action Coalition of Indiana for use in its comments on the Draft Statewide Analysis, Clinic Director and Senior Economist Liz Stanton, PhD, along with members of the Applied Economics Clinic staff created pursuant to the Indiana Code Title 8, Article 1, Chapter 8.5, this AEC report compares the Draft Statewide Analysis to: 1) the Statutory Mandate (Indiana Code Ch. 8-1-8.5), and 2) to the IURC Director’s Comments and Suggestions.

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Testimony on the Economics of Karn Coal Units in Michigan

Source: Power Engineering

Clients: Michigan Environmental Council, the Natural Resources Defense Council, and Sierra Club

Tyler Comings

September 2018

On behalf of Michigan Environmental Council, the Natural Resources Defense Council, and Sierra Club, Senior Researcher Tyler Comings testified on two coal units (Karn 1 and 2) as part of the Consumers Energy rate case in Michigan. Mr. Comings concluded that non-essential capital investments for Karn Units 1 and 2 should be denied by the Commission. He discussed that the units have been shown to be uneconomic in past analyses performed by Consumers Energy and delaying a retirement decision would only cost ratepayers more.

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Comment on August 2018 Analysis of the Avoided Costs of Compliance of the MA GWSA

Source: Energy, Light, & Power

Author: Liz Stanton, PhD

September 2018

Clinic Director and Senior Economist Liz Stanton, PhD, reviewed a recent study of the Massachusetts-specific cost of complying with the Global Warming Solutions Act. The study, released in August 2018 as a supplement to the Avoided Energy Supply Component in New England: 2018 Report, finds a Massachusetts carbon cost of $35 per ton of carbon dioxide (plus the cost of energy supply). Dr. Stanton supports this assessment while updates and critiques for implementation in future assessments.

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Testimony on Vectren's Proposed Natural Gas Plant and Coal Retrofits

Source: Energy News Network

Clients: Citizens Action Coalition, Valley Watch, and Sierra Club

Tyler Comings

August 2018

On behalf of Citizens Action Coalition, Valley Watch, and Sierra Club, Senior Researcher Tyler Comings testified on Vectren's plan to install a new natural gas plant and retrofit an existing coal plant. Mr. Comings recommended that the plan be rejected. He found that the Vectren's plan was not least cost, nor least risk--even according to the company's own modeling. He concluded that the company was overbuilding capacity, exposing ratepayers to excessive market risk, and biased against alternative resources.

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Massachusetts Comprehensive Energy Plan: Comments on Stakeholder Meeting Presentation

Client: Conservation Law Foundation

Author: Liz Stanton, PhD

July 2018

On behalf of Conservation Law Foundation, Clinic Director and Senior Economist Liz Stanton, PhD, reviewed draft assumptions for Massachusetts 2018 Comprehensive Energy Plan modeling and produced a memo reviewing these assumptions. This memo was submitted as an attachment to Conservation Law Foundations comments on the Plan.

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Review of Massachusetts Efficiency Program Administrator's April 2018 Draft 2019-2021 Energy Efficiency Plan

Client: Conservation Law Foundation

Author: Liz Stanton, PhD

July 2018

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On behalf of Conservation Law Foundation, Clinic Director and Senior Economist Liz Stanton, PhD, prepared an Applied Economics Clinic white paper of Massachusetts efficiency program administrator's April 2018 draft 2019-2021 energy efficiency plan. The detailed review and assessment included testing the sensitivity of the Plan's benefit-cost ratios to changes in assumptions regarding the cost of carbon emissions and the value of non-energy benefits to low-income households.

This report is one of three AEC publications on behalf of Conservation Law Foundation and other stakeholders in the Massachusetts Energy Efficiency Advisory Council.

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Massachusetts Battery Storage Measures: Benefits and Costs

Client: Clean Energy Group

Author: Liz Stanton, PhD

July 2018

AEC-2018-07-WP-02

On behalf of the Clean Energy Group, Clinic Director and Senior Economist Liz Stanton, PhD, prepared an Applied Economics Clinic white paper. Dr. Stanton assessed the cost-effectiveness of battery storage in Massachusetts, using the Massachusetts' efficiency program administrators' benefit-cost ratio methodology and found that both single- and multi-family batteries are found to be cost effective.

This white paper is part of a series of AEC publications on behalf of Clean Energy Group analyzing costs and benefits of battery storage in Massachusetts.

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The Economic Impacts of Repealing Indiana's Energy Efficiency Resource Standard

Client: Citizens Action Coalition of Indiana

Bryndis Woods and Nina Schlegel

July 2018

On behalf of the Citizens Action Coalition of Indiana, Researchers Bryndis Woods and Nina Schlegel prepared an Applied Economics Clinic policy brief that analyzes energy efficiency savings, saved energy costs, and job impacts since the repeal of Indiana's energy efficiency resource standard (EERS) in 2015. The brief compares what happened as a result of the repeal with what would have been achieved had the program not been repealed. Ms. Woods and Ms Schlegel found that had EERS not been repealed: Indiana would have saved more energy, ratepayers would have saved millions of dollars, and many jobs would have been created. This policy brief serves as a companion to another AEC policy brief, entitled The Performance of Indiana Utilities’ Energy Efficiency Programs, that compares utility sales, energy efficiency savings and program costs over the period 2012 to 2019 across Indiana’s five investor-owned electric utilities.

This policy brief is one of two AEC publications on behalf of Citizens Action Coalition and Energy Foundation that investigate the impact of Indiana's 2014 repeal of its energy efficiency program through passage of the Senate Enrolled Act 340.   

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Power Plant Nationality

Client: Global Development Policy Center, Boston University

Authors: Ricardo Lopez, PhD

July 2018

On behalf of the Global Development Policy Center at Boston University, Senior Researcher Ricardo Lopez identified Japanese-owned and US-owned power plants in the Platts database on behalf of the Global Development Policy Center at Boston University.

Testimony on Stranded Costs of Public Service Company of Colorado's Comanche 1&2 Coal Units

Source: Power Technology

Client: Sierra Club

Tyler Comings

March and July 2018

On behalf of Sierra Club, Senior Researcher Tyler Comings provided an Applied Economics Clinic testimony on March 2018 in Docket No. 17A-0797E. Mr. Comings provides an expert opinion on the Public Service Company of Colorado's application to accelerate the depreciation of Comanche Units 1 and 2 and the associated rate plan to offset this expense. He concludes that the accelerated depreciation of Comanche Units 1 and 2 and offsetting mechanism is in the public interest; the success of the Renewable Energy Standard Adjustment has afforded the Company the opportunity to offset the accelerated depreciation; and the Company's proposal is reasonable but should consider other options for future stranded assets. In his July 2018 surrebuttal testimony, Mr. Comings responds to criticisms raised in cross-answer testimony, concluding that the retirement of Comanche coal-fired Units 1 and 2 saves money and reduces risks to ratepayers.

Link to Tyler Comings' July 2018 Surrebuttal Testimony

Link to Tyler Comings' March 2018 Answer Testimony

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Massachusetts' Clean Energy Policy Overview

Client: Barr Foundation

Authors: Bryndis Woods, Nina Schlegel, and Liz Stanton, PhD

June 2018

On behalf of the Barr Foundation, Researchers Bryndis Woods and Nina Schlegel, along with Clinic Director and Senior Economist Liz Stanton, PhD, prepared an Applied Economics Clinic policy brief which detailed Massachusetts’ history of leadership in clean electric-sector policies. Beginning in the 1980s, through the electric “restructuring” laws and regulations of the 1990s, and then the 2008 Green Communities Act and Global Warming Solutions Act, Massachusetts policy-makers have laid the groundwork for today’s efforts to reduce greenhouse gas emissions while adding diversity to New England’s electric generating resources.  The 2018 ‘Act to Promote a Clean Energy Future’ continues this work, calling for accelerated renewable energy requirements, offshore wind and battery storage targets, and less stringent limits on rooftop solar installations.

Link to History of MA Energy Sector Policy Brief

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Massachusetts Clean Energy Bill Provisions Boost Jobs and Strengthen the State's Economy

Client: Barr Foundation

Liz Stanton, PhD, and Tyler Comings

June 2018

On behalf of the Barr Foundation, Clinic Director and Senior Economist Liz Stanton, PhD, and Senior Researcher Tyler Comings prepared an Applied Economics Clinic policy brief discussing the pending 2018 ‘Act to Promote a Clean Energy Future’, which includes a range of provisions to address climate change while strengthening the state’s innovation economy. The act includes accelerating renewable energy targets, creating aggressive offshore wind and battery storage goals, and removing limits on rooftop solar. Dr. Stanton and Mr. Comings' study of the economic impacts of these policies found benefits for Massachusetts including new jobs, a stronger economy, more renewable resources, and lower greenhouse gas emissions. At the same time, these policies would have little or no effect on consumers’ electric bills through 2030.

Link to Findings Policy Brief

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