Author: Tyler Comings
July 2022
AEC Senior Researcher Tyler Comings filed direct and rebuttal testimony on Consumers Energy's Integrated Resource Plan (IRP) before the Michigan Public Service Commission. Mr. Comings argued with the economics of the company's proposal to acquire three affiliate gas plants, and also supported the company's plan to retire its Campbell coal units by 2025.
Authors: Tyler Comings and Joshua R. Castigliego
July 2022
AEC Senior Researcher Tyler Comings and Researcher Joshua Castigliego co-authored an expert report (along with Energy Futures Group) on the Minnesota Power (MP) Integrated Resource Plan. The report presents an alternative to MP's plan to procure a share of a new natural gas combined cycle plant--showing that additional renewable, storage and demand-side resources provided a lower-cost solution than new gas for the utility.
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.
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.
Media Coverage - NJBiz - June 9, 2022
Media Coverage - NJ Spotlight News - June 8, 2022
Media Coverage - Asbury Park Press - June 8, 2022
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.
Media Coverage - NJBiz - June 9, 2022
Media Coverage - NJ Spotlight News - June 8, 2022
Media Coverage - Asbury Park Press - June 8, 2022
Image Credit: Saur Energy International
Client: Green Energy Consumers Alliance
Author: Joshua Castigliego
May 2022
On behalf of the Green Energy Consumers Alliance, Researcher Joshua Castigliego provided Applied Economics Clinic expert testimony to Track 2 of Dockets 21-90 and 21-91 before the Massachusetts’ Department of Public Utilities. In his testimony, Mr. Castigliego investigated co-locating renewable power generation (e.g., solar PV) and/or energy storage at electric vehicle (EV) charging stations as a technology-based approach to alleviating the financial barrier that utility demand charges pose to the widespread deployment of direct current fast charging (DCFC) stations across the Commonwealth. His analysis demonstrates that co-location with renewables and/or energy storage has the potential to lower the average cost per EV charge (depending, in part, on the utility’s rate structure), which would alleviate the financial barrier for EV charging stations due to demand charges. Mr. Castigliego demonstrates that utility demand charges can work hand in hand with the co-location of renewables and energy storage to synergistically combat the financial barrier and increase overall deployment of DCFC stations in Massachusetts. To obtain those benefits, the electric distribution companies and the Department must take the impact of co-location into consideration when constructing and approving demand charge rate structures.
Link to Testimony (DPU Docket Nos. 21-90 and 21-91)
Clients: We Act for Environmental Justice and Alliance for a Green Economy
Author: Liz Stanton, PhD
May 2022
On behalf of We Act for Environmental Justice and Alliance for a Green Economy, AEC Senior Economist Liz Stanton, PhD filed testimony on issues related to greenhouse gas emissions and compliance with New York’s Climate Leadership and Community Protection Act in Consolidated Edison’s 2022 rate case before the New York State Public Service Commission (Case 22-E-0064/65). Dr. Stanton found a significant discrepancy between the Company’s planned greenhouse gas emission reductions and the State’s established climate goals. Dr. Stanton also outlines potential solutions to eliminate this discrepancy and ensure Consolidated Edison’s emissions reduction plan adheres to New York State law.
Clients: GreenRoots Inc., and Conservation Law Foundation
Author: Liz Stanton, PhD
May 2022
On behalf of GreenRoots, Inc. and Conservation Law Foundation, AEC Senior Economist Liz Stanton, PhD filed testimony on Eversource Energy’s proposed East Eagle Street Substation in East Boston with the Commonwealth of Massachusetts Energy Facilities Citing Board (Docket No. EFSB 22-01). Dr. Stanton examined Eversource Energy’s rationale and found the company failed to provide sufficient evidence for the need for a new gas substation. Dr. Stanton highlights that Eversource’s justification for the proposed substation has changed over time without providing additional forecasts or data indicating such a substation is necessary to meet current consumer demand.
Client: Environmental Defense Fund
Authors: Tanya Stasio, Joshua Castigliego, Chirag Lala, and Liz Stanton, PhD
May 2022
On behalf of the Environmental Defense Fund, Researchers Tanya Stasio, Joshua Castigliego, Chirag Lala, and Director and Senior Economist Liz Stanton, PhD make recommendations for Florida Power and Light (FPL) to assist the utility in embracing the clean energy transition and reduce risks to ratepayers and its parent company, NextEra Energy's, shareholders.
Utilities across the United States are pursuing net-zero emissions targets while NextEra, the only large utility parent company that lacks an absolute carbon reduction goal, aims to reduce carbon intensity by 67 percent of 2005 levels by 2025. Moreover, FPL’s plans for the future are not aligned with NextEra’s emission rate reduction target. Based on AEC's assessment of FPL/NextEra’s transition plans and a review of electric utility climate plans, AEC offers seven recommendations for a new transition plan:
1. Coordinate NextEra and FPL transition plans
2. Establish short-, medium-, and long-term emission reduction targets, including a net zero target
3. Ramp up demand-side management efforts
4. Invest in energy storage technologies
5. Modernize the electric grid and increase renewable energy capacity
6. Consider multiple scenarios in future planning and reduce planning time horizon
7. Increase stakeholder and community engagement and continue to align plan with TCFD recommendations
Client: Community Action Works
Authors: Bryndis Woods, PhD, Sachin Peddada, Eliandro Tavares, Elisabeth Seliga, and Myisha Majumder
April 2022
On behalf of Community Action Works, AEC staff developed a report that identifies and examines six on-going clean energy and energy justice advocacy campaigns in New England. AEC profiles and assesses each campaign to determine which decision makers possess the authority to act on the advocates’ goals. These six campaigns include opposition to the proposed peaker plant in Peabody, MA; continued operation of New England’s last coal-fired power plant in Bow, New Hampshire; three existing peaker plants in Berkshire County, MA; a proposed gas-fired power plant in Killingly, CT; a proposed gas pipeline between Longmeadow and Springfield, MA; and an approved electric substation in East Boston awaiting construction. In addition to profiling each project, the report clarifies the key role the Independent System Operator of New England (ISO-NE), governors, and state legislatures play in developing New England’s energy mix.
Across all six campaigns, we find that advocates have more opportunities to pursue their goals while a project is still in its proposal phase; it becomes more challenging to shut down an energy project once it is operational. In addition, we recommend changes at ISO-NE that have the potential to render many polluting New England energy projects less competitive.
Client: HEET
Authors: Tanya Stasio, Joshua Castigliego, Sagal Alisalad, and Liz Stanton, PhD.
March 2022
On behalf of the HEET, Researchers Tanya Stasio and Joshua Castigliego, Assistant Researcher Sagal Alisalad, and Director and Senior Economist Liz Stanton, PhD explored the feasibility of injecting green hydrogen and/or upgraded biogas (also known as “renewable” natural gas) into Massachusetts’ existing gas supply as a building decarbonization strategy. AEC compared these alternatives to gas heating and modern electric heat pumps in terms of price, feasibility, supply, and safety, and found that upgraded biogas and green hydrogen are infeasible, expensive, and unsafe strategies for decarbonization of building heating. Moreover, a green hydrogen/fossil gas blend is not feasible before 2040; For a green hydrogen/fossil gas blend to be a viable heating fuel, gas utilities would need to replace all of Massachusetts’ leaky-prone pipes.
AEC also estimated annual home heating costs for an average Massachusetts home using different heating options and found that by the mid-2030’s heating with air-source heat pumps, ground-source heat pumps, and/or networked geothermal systems will be more affordable than heating with fossil gas.
Client: Massachusetts Climate Action Network
Authors: Bryndis Woods, PhD, Chirag Lala, and Joshua Castigliego
March 2022
On behalf of the Massachusetts Climate Action Network (MCAN), AEC staff developed a policy brief that presents risks that Municipal Light Plants (MLPs) should consider as they decide whether to retain their ownership shares in the Peabody peaking power plant or withdraw from the contract: 1) market risks, like capacity and fuel prices, and 2) climate/environmental risks. We find that while ownership in the Peabody peaker protects against some capacity market risks, it leaves MLPs open to a variety of other important risks, including uncertainty in future gas fuel prices. existing Massachusetts emissions regulations and Environmental Justice (EJ) community protection laws, and the potential for stronger EJ laws, new federal legislation, and/or regulatory changes that put fossil fuel-fired assets at a disadvantage.
Client: Green Energy Consumers Alliance
Authors: Liz Stanton, PhD and Joshua R. Castigliego
January 2022
On behalf of the Green Energy Consumers Alliance, Clinic Director and Senior Economist Liz Stanton, PhD and Researcher Joshua Castigliego provided Applied Economics Clinic expert testimony to Dockets 21-90 and 21-91 before the Massachusetts' Department of Public Utilities. In their testimony to Docket 21-91, Dr. Stanton and Mr. Castigliego reviewed and critiqued National Grid's methods and assumptions in setting a 3 to 5 cent per kilowatt-hour (kWh) rebate for its Off-Peak Charging Program. Dr. Stanton and Mr. Castigliego determined that National Grid is underestimating its rebate by excluding important benefits of off-peak charging such as avoided transmission and distribution costs, avoided emissions and emission costs, avoided reliability costs, avoided costs due to induced price effects, and non-energy benefits. Their analysis shows that including these benefits in a value for off-peak charging could raise National Grid's rebate by 10 cents per kWh from 3 to 5 cents per kWh to 13 to 15 cents per kWh. Similarly in Docket 21-90, Dr. Stanton and Mr. Castigliego examined a possible off-peak charging rebate for Eversource by modeling avoided energy and capacity costs based on National Grid’s methodology, and offering an illustrative methodology for inclusion of other off-peak charging benefits. In the absence of a rebate, EV owners are currently being overcharged for the energy used to charge their vehicles; implementing a rebate value that includes a complete set of benefits would eliminate a cross-subsidy from EV owners to non-EV owners while at the same time providing an incentive to adopt critical emission reductions in the transportation sector.
Link to Joint Testimony (DPU 21-90)
Client: City of Cambridge
Authors: Bryndis Woods and Liz Stanton, PhD
December 2021
Together with DNV GL and Sorensen Partners, AEC led the City of Cambridge's stakeholder engagement process to provide equity input on the City's 2021 update to its 2015 Net Zero Action Plan.
The Net Zero Task Force held five public, remote meetings between November 2020 and June 2021.
AEC provided equity guidance and input throughout the process as the Task Force worked to propose and evaluate adjustments to the Net Zero Action Plan.
Meeting 1, November 2020:
AEC presented on its Climate and Social Equity Framework and baseline equity considerations for the City of Cambridge.
Meeting 2, December 2020:
AEC provided guidance regarding the potential co-benefits of Net Zero Actions, including equity co-benefits.
Meeting 3, January 2021:
AEC answered stakeholders’ questions regarding equity.
Meeting 4, April 2021:
AEC presented on the equity implications of the proposed Net Zero Action Plan adjustments, including equitable action design and implementation.
Meeting 5, May 2021:
AEC presented on the “equity rating” assigned to each proposed Net Zero Action—equity ratings indicate whether each Action, as it currently stands, is likely to have equity impacts that are positive, neutral, or need to be addressed with additional action (“flagged”).
In January 2022, the City of Cambridge received City Council approval on its final Net Zero Action Plan.
Link to Final Cambridge Net Zero Action Plan
Client: Green Justice Coalition
Authors: Bryndis Woods, PhD, Sagal Alisalad, Eliandro Tavares, Myisha Majumder, and Liz Stanton, PhD
December 2021
On behalf of the Green Justice Coalition, AEC staff developed three white papers on equity measurement and how underserved communities will be served in the implementation of Massachusetts’ 2022-2024 Energy Efficiency Plan. The first paper, Equity Measurement for Massachusetts’ 2022-2024 Energy Efficiency Plan, builds on the equity recommendations of the Energy Efficiency Advisory Council’s (EEAC) Equity Working Group (EWG) and the Green Justice Coalition by describing metrics needed to evaluate progress towards equity goals. The second paper, Energy Efficiency and Equity Efforts Nationwide, provides examples from other jurisdictions around the nation on the state of equity programming in energy efficiency policies. The third AEC white paper, Targeting Underserved Communities in Massachusetts’ 2022-2024 Energy Efficiency Plan, is a detailed review of Massachusetts towns identified as underserved by the energy efficiency program administrators and their partners.
Link to White Paper 1: Equity Measurement for Massachusetts’ 2022-2024 Energy Efficiency Plan
Link to White Paper 2: Energy Efficiency and Equity Efforts Nationwide
Client: The Office of the People’s Counsel for the District of Columbia
Authors: Tanya Stasio, Bryndis Woods, PhD. Joshua R. Castigliego, Liz Stanton, PhD
December 2021
On behalf of the Office of the People’s Counsel for the District of Columbia, Researcher Tanya Stasio, Senior Researcher Bryndis Woods, PhD, Researcher Joshua Castigliego, and Senior Economist Liz Stanton, PhD examine a potential pathway for reducing emissions in the District of Columbia: equitable electrification–a transition away from fossil fuels while taking into consideration equity implications, in both existing and future decarbonization efforts.
A baseline equity analysis of the distribution of energy expenditures, median income and other vulnerability indicators reveals significant disparities across the District. To account for the existing disparities of income and access within the District and ensure beneficial electrification efforts are equitable, AEC identified the following priorities: (1) Ensuring that community engagement influences DC Public Service Commission and District Government decision-making regarding beneficial electrification programs; (2) Prioritizing beneficial electrification investments in neighborhoods impacted by environmental injustice and addressing common decarbonization barriers, and; (3) Ensuring that beneficial electrification programs do not increase the energy burden for EJ and other vulnerable communities.
Client: Clean Energy Group
Authors: Joshua R. Castigliego, Liz Stanton, PhD, Sagal Alisalad, and Eliandro Tavares
December 2021
On behalf of the Clean Energy Group, Researcher Joshua Castigliego, Senior Economist Liz Stanton, PhD, and Assistant Researchers Sagal Alisalad and Eliandro Tavares evaluated the value of winter reliability services and the opportunity to provide these services economically in New England using distributed battery storage. AEC finds that the value of winter peaking capacity services from distributed (customer-sited) resources is incorrectly assumed to be $0 in the battery program cost-benefit analyses that determine performance payments to battery storage owners.
The value of winter electric capacity is treated by electric distributors as distinct from that same value in summer, and it has been dubbed “winter reliability” to distinguish it from “summer capacity.” When calculating customer performance payments, summer capacity services are valued, but winter reliability services are not. In this report, AEC introduces a winter reliability metric defined as the assurance of adequate electric capacity during periods of critical need, called—following ISO-New England’s convention—capacity scarcity condition (CSC) events. AEC calculated a “winter reliability value” measured as the net dollar value to supply any given peak supply technology (i.e., gas peaker or large-scale battery storage) on a per kilowatt-hour (kWh) basis during a CSC period.
Authors: Joshua R. Castigliego, Liz Stanton, PhD, Sagal Alisalad, Tanya Stasio, Eliandro Tavares
October 2021 (Updated November 2021)
Researcher Joshua Castigliego, Senior Economist Liz Stanton, PhD, Assistant Researcher Sagal Alisalad, Researcher Tanya Stasio, and Assistant Researcher Eliandro Tavares prepared a report reviewing the economics of power plants in the PJM region, focusing on the "capacity payments" given to owners of generating units that promise to be available if needed to generate power at times of peak customer demand. AEC finds that PJM has consistently overestimated its peak demand and as a result spent too much money on capacity payments, and generating units—including many in or near Environmental Justice (EJ) communities—are kept online despite being uneconomic and unnecessary to provide reliable electric service.
AEC adjusted PJM’s forecasts and market design to better represent customer demand and other market conditions, and estimated the prices that individual generating units bid into the 2021/22 capacity auction, which took place in 2018. The actual bids by power plant owners are not made public, so we model them based on available cost and revenue data. PJM’s overestimate of customer demand and costs of new generating units raises market clearing prices and capacity payments to power plant owners, resulting in what we call a “fat market” with payments made to unnecessary power plants and higher costs to customers. In place of PJM’s $140 per megawatt-day (MW-day) fat market clearing price, we estimate a clearing price of $100 to $104 per MW-day to serve customer needs without adding unnecessary costs. Our leaner, adjusted clearing price would lower customer bills without sacrificing reliable electric service and put an end to capacity payments propping up the bottom lines of uneconomic power plants, many of them in or near EJ communities.
Link to Report (Updated 11/30/2021)
Clients: Office of the California Attorney General and the California Air Resource Board
Authors: Liz Stanton, PhD, Gabriel Lewis, and Chirag Lala
October 2021
On behalf of the Office of the California Attorney General and the California Air Resource Board, this Applied Economics Clinic white paper examines the National Highway Traffic Safety Administration’s (NHTSA) Proposed Rulemaking for Model Years 2024-2026 Light-Duty Vehicle Corporate Average Fuel Economy Standards. The proposal would increase the stringency of Corporate Average Fuel Economy (CAFE) standards from their 2020 levels, setting the standards close to the path established in 2012. The NHTSA provides an estimate of the expected benefits in its 2021 Preliminary Regulatory Impact Analysis (PRIA), and it expects benefits in fuel savings, energy security, and drive value.Our analysis finds the estimated benefits to be a conservative estimate. Other benefits not included in the cost-benefit analysis would increase the net benefits and provide additional support for stricter fuel economy standards, if included in NHTSA’s comparison.
Client: American Council for an Energy-Efficient Economy (ACEEE)
Authors: Bryndis Woods, PhD, Liz Stanton, PhD, and Sagal Alisalad
October 2021
On behalf of the American Council for an Energy-Efficient Economy (ACEEE), this Applied Economics Clinic white paper recommends measures that cities and states can undertake to facilitate equitable energy efficiency evaluation and reporting of energy efficiency efforts, based on the results of our review of low-income energy efficiency efforts in ACEEE’s top-scoring cities and states in their 2020 City and State energy efficiency scorecards.
We find that the cities and states most highly-rated for energy efficiency offer programs for low-income community members, but fail to take critical actions necessary for equitable evaluation and reporting to facilitate equitable outcomes. Based on our review of these programs, we find that—while these programs have made important progress on addressing equity concerns by offering efficiency programming specifically to low-income households—more robust energy efficiency evaluation and reporting are needed to shine a light on city and state equity-focused energy efficiency programming and ensure that efficiency benefits are equitably distributed. We recommend three main improvements that would drastically enhance the ability to evaluate these programs for their equity-related impacts:
• Mandate disaggregated efficiency program performance reporting;
• Identify, track, and target vulnerable populations; and
• Integrate energy efficiency, climate, and equity planning and reporting.