Comments on Massachusetts Decarbonization Roadmap

Client: Conservation Law Foundation

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

Updated April 28, 2020

In February 2020, the Massachusetts Executive Office of Energy and Environmental Affairs requested public feedback on setting a 2050 emissions limit that will achieve the Commonwealth’s 2050 goal of net-zero emissions. On behalf of Conservation Law Foundation, this Applied Economics Clinic white paper provides eight recommendations for the Commonwealth as it works to set its 2050 emission targets. We argue that Massachusetts should set an ambitious 2050 emissions reductions target that builds in flexibility to account for truly recalcitrant emissions via carbon sinks, distinguishes the state as a national leader on climate, clearly defines and limits the use of carbon sinks until the Commonwealth approaches full decarbonization in 2050, considers the context of global climate change and local impacts, is in line with the best available science, and uses modeling tools that are able to consider a full range of emission reduction technologies.

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Cost of Capital and Asset Return for Workers' Compensation Insurance in Massachusetts

Author: Tyler Comings

AEC Senior Researcher Tyler Comings prepared an advisory filing for the State Review Board (SRB) of the Massachusetts Division of Insurance. Mr. Comings estimated the cost of capital and asset rate of return for the industry for use in regulated rates of workers' compensation insurance. All parties reached an agreed upon change in rates, which was accepted by the Division of Insurance (Docket No. R2019-01). 

Comments on Ameren Missouri Integrated Resource Plan

Client: Sierra Club

Author: Tyler Comings

April 2020

AEC Senior Researcher Tyler Comings assisted the Sierra Club with comments on the Ameren Missouri Integrated Resource Plan (IRP) process. The comments recommend that Ameren fully address environmental compliance costs and emissions impacts, conduct rigorous economic modeling of its coal fleet, and reasonable cost assumptions for existing and new resources. 

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New England Housing Costs: Rent as a Share of Income

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

March 2020

Researcher Bryndis Woods, Senior Economist Liz Stanton, PhD and Assistant Researcher Eliandro Tavares prepared a presentation that assesses housing costs as a share of income across the New England states. We find that, across New England, lower-income households bear a greater rent burden than higher-income households. Between 2011 and 2017, some households’ rent as a share of income has risen, as a result of falling incomes and/or rising rents that can lead to displacement.

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Running Behind: New York State's Renewable Transformation

Client: Earthjustice

Authors: Bryndis Woods, Sagal Alisalad and Liz Stanton, PhD

March 2020

On behalf of Earthjustice, Researcher Bryndis Woods, Assistant Researcher Sagal Alisalad and Senior Economist Liz Stanton, PhD prepared a report that reviews New York State’s past progress on its new climate law as it applies to the electric sector. We find that the state has its work cut out for it in meeting its ambitious targets regarding: renewable energy development, energy efficiency, and greenhouse gas emissions reductions. Given historical trends in these areas, New York will need to dramatically scale up its efforts, beginning immediately, to reach its goals. Importantly, we also find that solar, wind and solar plus storage technologies are feasible and immediately available, and that currently planned gas capacity is at odds with the state’s renewable energy and emission reduction goals and will, therefore, impose unnecessary costs on New York consumers.

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Health and Cost Benefits of Energy Efficiency Policies

Client: Green Energy Consumers Alliance (GECA)

Authors: Bryndis Woods, Hannah Brown and Myisha Majumder

March 9, 2020

On behalf of the Green Energy Consumers Alliance (GECA), Researcher Bryndis Woods and Research Assistants Hannah Brown and Myisha Majumder prepared a policy brief that assesses the impact of various efficiency policies on energy savings. We find that, on average, the more fully policies account for the benefits of energy efficiency, the more energy they save; states that account for participant health benefits, societal health benefits or mandate the implementation of all cost-effective efficiency measures save more energy than states that do not. In states that do not consider participant and societal health benefits, fewer efficiency measures are implemented—leaving both energy savings and benefits on the table.

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New Orleans' Renewable Portfolio Standard: Cost-Effective, Reliable, Resilient

Client: Alliance for Affordable Energy

Authors: Liz Stanton, PhD, Bryndis Woods, Eliandro Tavares and Sagal Alisalad

March 2020

Clinic Director and Senior Economist Liz Stanton, PhD, Researcher Bryndis Woods, and Assistant Researchers Eliandro Tavares and Sagal Alisalad prepared a report that addresses Entergy New Orleans’ (ENO) critiques of the Energy Future New Orleans Coalition's July 2019 Resilient Renewable Portfolio Standard (R-RPS) proposal to achieve a 100 percent renewable electric generation by 2040. ENO incorrectly claims that the R-RPS would: be prohibitively costly; harm grid resiliency, and harm grid reliability. AEC’s analysis of the R-RPS found the plan to be affordable, would provide substantial resiliency benefits, and would reliably provide New Orleans’ energy needs.

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AEC Climate and Social Equity Framework

Authors: Liz Stanton, PhD and Bryndis Woods

March 2020

AEC’s climate and social equity framework offers guidance on how to incorporate considerations of social equity in climate planning. Every community will face different climate and social equity changes, and will need its own tailored approach to achieve the best outcomes. The framework can be used as a jumping off point, a discussion piece to spark ideas, or a to do list.

Link to Framework

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Testimony on Algonquin Gas Transport Agreement

Client: Town of Weymouth

Author: Liz Stanton, PhD

February 2020

On behalf of the Town of Weymouth, Clinic Director and Senior Economist Liz Stanton, PhD provided Applied Economics Clinic expert testimony to Docket 19-132 before the Massachusetts' Department of Public Utilities. In her testimony, Dr. Stanton examined whether National Grid's proposed Atlantic Bridge Agreement meets the following criteria: (1) the public need for this capacity based on forecasted demand and available alternatives, (2) the public need for this capacity based on price, and (3) consideration of evidence relevant to the Global Warming Solutions Act ("GWSA"). Dr. Stanton concluded that National Grid failed to prove the necessity, cost-effectiveness, and GWSA compliance of the proposed Atlantic Bridge Agreement.

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A Whole New Ballgame: Indiana Coal and the New Energy Landscape

Client: Citizens Action Coalition of Indiana

Authors: Liz Stanton, PhD, Bryndis Woods, Joshua Castigliego, Eliandro Tavares and Sagal Alisalad

February 2020

Clinic Director and Senior Economist Liz Stanton, PhD, Researchers Bryndis Woods and Joshua Castigliego and Assistant Researchers Eliandro Tavares and Sagal Alisalad prepared a report on behalf of the Citizens Action Coalition of Indiana that responds to several myths that persist regarding claimed benefits of aging coal-fired generators over renewable wind and solar. The report finds that legacy power generation sources like coal are characterized by a lack of flexibility, making them costly and inconvenient to integrate with more modern renewables.

Link to Report

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Testimony on Indiana Michigan Power Company's Integrated Resource Plan

Client: Earthjustice

Author: Tyler Comings

January 2020

AEC Senior Researcher Tyler Comings filed testimony on behalf of Sierra Club on the Indiana Michigan Power Company (I&M) Integrated Resource Plan (IRP) in Michigan, focusing on two coal units (Rockport 1 and 2). Mr. Comings found that I&M was justified in proposing retirement  of Rockport 1 in 2028 and letting its lease expire for Rockport 2 in 2022. Mr. Comings found that there was additional savings from retiring the Rockport 1 unit even earlier than I&M was proposing: 2025 instead of 2028. He also recommended additional Commission oversight of the Company's share of output from the Kyger Creek and Clifty Creek coal units.

Link to Testimony

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Benefits of Net Zero Buildings: Comfort, Safety, Value, Climate

Client: Massachusetts Climate Action Network (MCAN)

Authors: Bryndis Woods and Eliandro Tavares

January 2020

On behalf of the Massachusetts Climate Action Network (MCAN), AEC has prepared a policy brief that presents a summary of the benefits of Net Zero buildings, such as enhanced health and comfort, home durability and safety, better value, and positive climate effects. A Net Zero building produces at least as much renewable energy in a year as it consumes, and the technology is currently ready for implementation.

Link to Policy Brief

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Testimony on the Public Service Company of New Mexico's (PNM) Plan for Replacing the San Juan Coal Units

Aerial photo of San Juan Generating Station, by Doc Searls

Client: Coalition for Clean Affordable Energy (CCAE)

Author: Tyler Comings

December 2019

AEC Senior Researcher Tyler Comings filed testimony on behalf of the Coalition for Clean Affordable Energy (CCAE) on Public Service Company of New Mexico's (PNM) plan for replacing the San Juan coal units with new resources. Mr. Comings testified that CCAE's replacement plan was a viable alternative and would invest more in the existing San Juan region than PNM's replacement plan. Mr. Comings also testified to flaws in PNM's resource evaluation that were addressed in developing CCAE's plan.

Link to Testimony

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Massachusetts Gas versus Massachusetts Climate Goals

Client: Gas Leak Allies

Authors: Liz Stanton, PhD, Bryndis Woods, Joshua Castigliego and Eliandro Tavares

December 2019

Prepared on behalf of Gas Leak Allies by Clinic Director and Senior Economist Liz Stanton, PhD, Researchers Bryndis Woods and Joshua Castigliego, and Assistant Researcher Eliandro Tavares, this Applied Economics Clinic policy brief demonstrates why Massachusetts cannot both continue to utilize gas for heating and meet legally mandated statewide emission reduction targets. There is a clear economic argument for focusing gas system investments on improving safety while transitioning away from gas to clean, highly efficient technologies as quickly as possible. Moving away from gas will make communities safer, save utility customers money, and meet the Commonwealth’s climate goals.

Link to Policy Brief

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Report on Indiana Michigan Power Company 2018-19 IRP

Wildcat Wind Farm, Indiana

Clients: Citizens Action Coalition of Indiana and Earthjustice

Authors: Liz Stanton, PhD, Anna Sommer, Chelsea Hotaling, Chris Neme

December 2019

Clinic Director and Senior Economist Liz Stanton, PhD contributed to comments on Indiana Michigan Power Company's most recent Integrated Resource Plan (IRP), which are filed with the Utility Commission to demonstrate that utilities' decisions to retire and/or add electric generation 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. Important issues found in reviewing Indiana utilities’ 2016 Plans include biases both against retiring coal generation and against adopting new efficiency measures and renewable resources. This testimony is part of a joint AEC and Energy Futures Group series of comments on Indiana utility Integrated Resource Plans (IRPs) on behalf of Citizens Action Coalition of Indiana and Earthjustice.

Report on Indiana Michigan Power Company IRP

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Cost and Emission Impacts of Community Choice Energy: Renewable Energy Options for the City of Chelsea

Client: GreenRoots

Authors: Bryndis Woods, Sagal Alisalad, and Hannah Brown

November 2019

Researcher Bryndis Woods, Assistant Researcher Sagal Alisalad, and Research Assistant Hannah Brown present the cost and emission savings of different designs for Community Choice Energy (CCE) programs in the City of Chelsea, Massachusetts as compared to electricity purchased from the default utility. This policy brief concludes that all types of CCE programs save residents money on their electric bills, and that Chelsea has the potential to reduce its emissions by an additional 34 percent by 2030 if it chooses to pursue a CCE program that mandates 25 percent more renewable energy than Massachusetts law.

Link to Policy Brief

Link to Data

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Marginal Cost of Emissions Reductions in Massachusetts

Client: Green Energy Consumers Alliance (GECA)

Authors: Clinic Director and Senior Economist Liz Stanton, PhD, Research Assistant Tanya Stasio and Researcher Bryndis Woods

November 2019

Clinic Director and Senior Economist Liz Stanton, PhD, Research Assistant Tanya Stasio and Researcher Bryndis Woods prepared a white paper that estimates the per ton cost of the most expensive measure needed to reduce greenhouse gas emissions by 21 million metric tons (MMT) of carbon dioxide equivalent (CO₂-e) by 2030—as required by the Commonwealth’s Global Warming Solutions Act (GWSA). AEC projects that the most expensive (per ton of CO₂-e) measure needed to comply with the GWSA in 2030 will be residential and commercial thermal electrification: switching from burning gas to using electric heat pumps. The estimated cost of switching from gas to electric heat pumps in 2030 is $13 per ton of avoided CO₂-e. In total, 12.2 MMT of CO₂-e reductions in 2030 can be achieved at zero or net negative cost. An additional 64.0 MMT are available for under $50 per ton. In sum, there are sufficient cost-effective opportunities to meet and even exceed the reductions needed to stay on track with GWSA targets.

Link to White Paper

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Technosilvicultural Reclamation for Environmental Emission Sequestration

Clients: Home Energy Efficiency Team (HEET) and Speak for the Trees (SFTT)

Authors: Bryndis Woods and Liz Stanton, PhD

November 2019

Researcher Bryndis Woods and Clinic Director and Senior Economist Liz Stanton, PhD prepared a policy brief that compares two cutting-edge carbon dioxide emission sequestration (or storage) technologies on the basis of cost, history of success, near-term commercial viability, co-benefits, and potential risks: 1) Carbon Capture and Storage (CCS), and 2) Technosilvicultural Reclamation for Environmental Emission Sequestration (TREES). Our assessment finds TREES facilities to be competitive with, or superior to, CCS in all evaluation categories: TREES facilities are less expensive per ton of CO2 stored, have a longer history of success, stronger near-term viability, more robust co-benefits, and fewer risks than CCS.

Link to Report

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Testimony on Duke Energy Indiana's Coal Fleet

Client: Sierra Club

Tyler Comings

November 2019

Senior Researcher Tyler Comings filed testimony on the cost of Duke Energy Indiana’s coal fleet in Cause No. 45253 before the Indiana Utility Regulatory Commission. Mr. Comings concluded that the Edwardsport plant was uneconomic and should be retired as soon as possible. He also recommended disallowances of costs associated with the coal fleet, a requirement for evaluating earlier retirement of the units, and that the Commission open an investigation into Duke’s “self-commitment” of its coal units and the practice's impact on customers.

Link to Testimony

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Testimony on Puerto Rico Electric Power Authority (PREPA) Least Cost Integrated Resource Plan

Client: Environmental Defense Fund

Liz Stanton, PhD

October 2019

On behalf of Environmental Defense Fund, Clinic Director and Senior Economist Liz Stanton, PhD provided Applied Economics Clinic expert testimony to Docket 2018-0001 before the Puerto Rico Energy Bureau. In her testimony, Dr. Stanton recommended that the Energy Bureau reject Puerto Rico’s energy utility’s (PREPA) June 2019 IRP and require that the Utility submit a new IRP under a set of outlined instructions and conditions. Dr. Stanton concluded that PREPA must constrain all scenarios to follow Puerto Rican Law, must submit model runs with higher demand forecasts, must issue an all resource RFP for new generation and peak-shifting resources, and must hold stakeholder meetings for the general public for future IRPs, including meetings in Spanish.

Link to 2018-0001 Testimony

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