Updated Massachusetts Battery Storage Measures: Benefits and Costs

Client: Clean Energy Group

Author: Liz Stanton, PhD

April 2019 Update

AEC-2019-04-WP-02

On behalf of the Clean Energy Group, Clinic Director and Senior Economist Liz Stanton, PhD, prepared an update to the Applied Economics Clinic’s July 2018 white paper on the same topic. 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.

Link to White Paper Update

Link to Project Page

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Comments on Cleco Power's Draft 2019 Integrated Resource Plan

Source: Wind Power Engineering

Client: Sierra Club

Authors: Sierra Club with assistance from AEC (Tyler Comings, Bryndis Woods, Ricardo Lopez, PhD, and Eliandro Tavares)

April 2019

Senior Researcher Tyler Comings, Researcher Bryndis Woods, Senior Researcher Ricardo Lopez and Assistant Researcher Eliandro Tavares assisted Sierra Club in comments on Cleco’s Draft 2019 Integrated Resource Plan. The Sierra Club concluded that Cleco failed to evaluate the economics of all of its existing resources as part of the IRP and also encouraged Cleco to pursue the company's preferred portfolio, including the addition of wind and solar resources.

Link to Comments

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Avoided Emissions of 100,000 renters in MA 2019-2021 Energy Efficiency Plan

Photo from Schochet Companies

Client: Clean Water Action

Author: Ricardo Lopez, PhD

March 2019

On behalf of Clean Water Action, Senior Researcher Ricardo Lopez, PhD provided a memo that estimates how much energy could be saved from including 100,000 renters in Massachusetts’ 2019-2021 Energy Efficiency Plan programs.

Link to Memo

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Testimony in NIPSCO's 2019 Rate Case

Client: Citizens Action Coalition of Indiana

Author: Liz Stanton, PhD

March 2019

On behalf of Citizens Action Coalition of Indiana, Clinic Director and Senior Economist Liz Stanton, PhD provided written testimony in Cause No. 45159 to respond to specific critiques of North Indiana Public Service Company's 2018 Integrated Resource Plan, offered by Indiana Coal Council Emily Medine, Indiana Coalition for Affordable and Reliable Electricity witness Charles S. Griffey, and Peabody COALSALES LLC witness Michael J. Nasi.

Link to Comments

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Testimony on NIPSCO's Petition for Approval of Jordan Creek Wind Farm PPA

Client: Citizens Action Coalition of Indiana

Authors: Liz Stanton, PhD

March 2019

On behalf of Citizens Action Coalition of Indiana, Clinic Director and Senior Economist Liz Stanton, PhD, provided written testimony in Cause No. 45195 on the consistency of Northern Indiana Public Service Company's (NIPSCO) 2018 Integrated Resource Plan (IRP) with acquiring a renewable energy power purchase agreement (PPA) with Jordan Creek Wind Farm. Dr. Stanton testified that the Jordan Creek PPA is consistent with NIPSCO's 2018 IRP, and that it is also consistent with the timing for procuring wind resources in the IRP's preferred portfolio.

This testimony is one of three AEC testimonies on three Indiana utility commission dockets (two filed and one upcoming) on behalf of Citizens Action Coalition of Indiana, pertaining to Northern Indiana Public Service Company's (NIPSCO) proposed acquisition of wind energy through power purchase agreement (PPA) and/or joint ownership. 

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Testimony on NISPCO's Petition for Approval of Roaming Bison Wind Farm PPA

From Roaming Bison website

Client: Citizens Action Coalition of Indiana

Authors: Liz Stanton, PhD

March 2019

On behalf of Citizens Action Coalition of Indiana, Clinic Director and Senior Economist Liz Stanton, PhD, provided written testimony in Cause No. 45196 on the consistency of Northern Indiana Public Service Company's (NIPSCO) 2018 Integrated Resource Plan (IRP) with acquiring a renewable energy power purchase agreement (PPA) with Roaming Bison. Dr. Stanton testified that the Roaming Bison PPA is consistent with NIPSCO's 2018 IRP, and that it is also consistent with the timing for procuring wind resources in the IRP's preferred portfolio.

This testimony is one of three AEC testimonies on three Indiana utility commission dockets (two filed and one upcoming) on behalf of Citizens Action Coalition of Indiana, pertaining to Northern Indiana Public Service Company's (NIPSCO) proposed acquisition of wind energy through power purchase agreement (PPA) and/or joint ownership. 

Link to Testimony

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Comment on National Grid's Proposed Off-Peak Charging Rebate

Client: Green Energy Consumers Alliance (GECA)

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

March 2019

Applied Economics Clinic (AEC) replicated the calculations described in National Grid’s proposed off-peak charging rebate. AEC’s estimates of summer and winter off-peak charging rebates — using the methodology and data described in detail by National Grid — resulted in values similar but not identical to those presented by the Company. AEC concludes that the rebate levels proposed by National Grid represent a reflection of the reduced cost of service for off-peak charging and not a cross-subsidy. In addition, this comment raises several categories of potential additional peak to off-peak cost differentials and sources of charging revenue omitted in National Grid’s charging rebate methodology, including avoided transmission and distribution costs, avoided emissions costs, and funding for energy efficiency programs.

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Comments on Xcel Energy Minnesota's 2018 Mankato Proposal

Photo of Mankato Energy Center from POWER Engineering news article

Client: Sierra Club

Authors: Sierra Club with assistance from AEC (Tyler Comings, Liz Stanton, PhD, and Eliandro Tavares)

March 2019

On behalf of Sierra Club, Senior Researcher Tyler Comings, Clinic Director and Senior Economist Liz Stanton, PhD and Assistant Researcher Eliandro Tavares assisted with comments on Xcel Minnesota's proposal to acquire the Mankato natural gas plant. The Sierra Club concluded that the proposal should be denied because it was not economically justified and ran counter to the utility's greenhouse gas emission goals.

Link to Comments

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Duke Energy Integrated Resource Plans in North Carolina

Client: Southern Environmental Law Center

Authors: Tyler Comings, Bryndis Woods, Liz Stanton, PhD, and Eliandro Tavares

March 2019

Senior Researcher Tyler Comings, Researcher Bryndis Woods, Director and Senior Economist Liz Stanton, PhD and Assistant Researcher Eliandro Tavares prepared a report on Duke Energy's 2018 Integrated Resource Plans (IRPs) in North Carolina on behalf of Southern Environmental Law Center and its clients, Natural Resources Defense Council, Southern Alliance for Clean Energy and the Sierra Club. AEC concluded that Duke has failed to evaluate the economics of its coal units, even though many are operating infrequently, and has not encouraged competition from other resources. As a result, AEC found Duke's plans to be flawed and incomplete.

August 2019 Update: Based in part on AEC comments, North Carolina Utilities Commission orders Duke Energy to re-evaluate coal units in 2020 IRPs.

AEC's comments (prepared for Natural Resources Defense Council, the Sierra Club and the Southern Alliance for Clean Energy) stated that Duke's IRP analysis: "...fails to consider whether existing resources can be cost effectively replaced with new resources. Therefore, Duke has not performed a least-cost analysis to design its recommended plans.” The Commission agreed, stating that: "It does not appear from the information in the IRPs that DEC and DEP have fully considered early retirement of any of these coal plants by replacing their contributions with other alternative generation resources or with energy efficiency (EE) and demand-side management (DSM) resources."

The order is available here.

Link to Review

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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. 

Link to Evaluation

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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.

Link to Policy Brief

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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.

Link to Graphs

Link to Report

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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.

Link to Report

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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.

Link to Testimony

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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.

Link to White Paper

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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.

Link to Presentation

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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. 

Link to Testimony

Link to Rebuttal Testimony

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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.

Link to Report

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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.

Link to Testimony

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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.

Link to Publication

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