Evergy Kansas IRP Comments

Client: Sierra Club

Authors: Senior Researcher Tyler Comings and Researcher Joshua Castigliego

Senior Researcher Tyler Comings and Researcher Joshua Castigliego assisted the Sierra Club in comments on the Evergy Kansas Integrated Resource Plan (IRP). AEC had several criticisms of the Evergy plan, including that the company 1) failed to choose one of its alternative plans that was lower-cost and had accelerated coal unit retirements; 2) failed to conduct true optimization of coal unit retirements; 3) inflated the costs of new renewable resources; and 4) failed to consider any battery storage.

Link to Comments

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Boston Tree Equity Analysis

Client: GreenRoots and Speak for the Trees

Authors: Tanya Stasio, PhD, Elisabeth Seliga, Elizabeth A. Stanton, PhD

Boston’s trees provide shade, cooling, and flood protection, and are an important tool for mitigating climate change impacts—like increased precipitation, sea level rise, and higher temperatures. The distribution of trees across and within Boston neighborhoods determines which communities benefit from these protections and which are left bearing the brunt of climate change impacts.

On behalf of GreenRoots and Speak for the Trees, Researcher Tanya Stasio, PhD, Assistant Researcher Elisabeth Seliga and Senior Economist Liz Stanton, PhD examined the distribution of tree coverage, pollution, high temperatures, and socioeconomic disparities in the City of Boston in order to identify communities where tree planting efforts could offer the most equitable results.

AEC recommends that equitable tree planting efforts be concentrated in neighborhoods where there is both the greatest opportunity for planting trees in an otherwise tree scarce area and a high concentration of socially vulnerable populations: South Boston, East Boston, Dorchester, and Roxbury.

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Expert Memo: Review of Memphis Light, Gas, and Water RFP Update and Staff Power Supply Recommendation

Client: Southern Environmental Law Center (SELC)

Authors: Elizabeth A. Stanton, PhD, Joshua R. Castigliego, Myisha Majumder, Eliandro Tavares, Sachin Peddada

AEC staff conducted an assessment of Memphis Light, Gas, and Water (MLGW)’s 2020 Integrated Resource Plan on behalf of the Southern Environmental Law Center, finding multiple instances of biases in favor of gas resources and against renewables and batteries. In light of these discoveries, AEC staff recommend that the biases be addressed prior to the MLGW Board making a decision on power supply alternatives.

Link to Memo

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Bringing Equity into Energy Reliability Decisions

Client: Environmental Defense Fund

Authors: Bryndis Woods, PhD, Sachin Peddada, Sagal Alisalad, Jordan Burt, Elisabeth Seliga, Tanya Stasio, PhD, Eliandro Tavares, Grace Wu, Elizabeth A. Stanton, PhD

AEC staff prepared a report on behalf of the Environmental Defense Fund that analyzes the connection between issues of energy system reliability and equity. This data-driven report utilizes case studies of advocates’ for more equitable energy systems real-world experiences to assess how decision-makers should account for equity when making decisions regarding system reliability. The report concludes with recommendations for future decision-making in energy system reliability, including strengthening consumer and community representation. A common theme across the real-world experiences of the advocates discussed in this report is the ways in which community engagement efforts in energy system decision-making often fall short of creating real change in energy sector decisions, and environmental justice and other under-resourced and underserved communities are often left out and left behind in decisions that directly disproportionately harm the health and wealth of their communities.

Link to Full Report

Link to Press Release

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Evergy Missouri IRP Comments

Client: The Sierra Club

Authors: Senior Researcher Tyler Comings and Researcher Joshua Castigliego

Senior Researcher Tyler Comings and Researcher Joshua Castigliego assisted the Sierra Club in comments on the Evergy Missouri Integrated Resource Plan (IRP). AEC had several criticisms of the Evergy plan, including that the company 1) failed to choose one of its alternative plans that was lower-cost and had accelerated coal unit retirements; 2) failed to conduct true optimization of coal unit retirements; 3) inflated the costs of new renewable resources; and 4) failed to consider any battery storage.

Link to Comments

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Testimony on the DTE Electric Company Rate Case

Clients: Michigan Environmental Council (MEC), Natural Resources Defense Council (NRDC), Sierra Club (SC) and Citizens Utility Board of Michigan.

Authors: Senior Researcher Tyler Comings

AEC Senior Researcher Tyler Comings filed testimony before the Michigan PSC on the DTE Electric Company (DTE) rate case on behalf of Michigan Environmental Council (MEC), Natural Resources Defense Council (NRDC), Sierra Club (SC), and Citizens Utility Board of Michigan. Mr. Comings recommended disallowance of capital investments that could be avoided if DTE's coal units retired earlier than currently planned--as well as disallowance of other capital projects that were not justified.

Link to Testimony

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Overburdened Communities and Power Plants in New Jersey

Authors: Sagal Alisalad, Tanya Stasio, PhD, Elisabeth Seliga, and Sachin Peddada, and Jordan Burt

Assistant Researcher Sagal Alisalad, Researcher Tanya Stasio, PhD, Assistant Researchers Elisabeth Seliga, and Sachin Peddada, and Research Assistant Jordan Burt prepared a policy brief on how New Jersey power plants disproportionately affect overburdened communities.

New Jersey environmental justice law defines overburdened communities as census blocks where at least a third of the household is low income, 40 percent of residents identify as racial-ethnic minorities, or 40 percent have low English proficiency. These communities are disproportionately affected by the pollutants emitted by power plants. AEC researchers explain that environmental justice initiatives will require full understanding of the impacts on vulnerable communities.

Link to Policy Brief

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Net Emissions Savings Benefit for a Battery Storage Facility in Wendell, Massachusetts

Image source: Borrego

Client: New Leaf Energy, Inc.

Authors: Joshua R. Castigliego, Chirag Lala, and Liz Stanton, PhD

August 2022

On behalf of New Leaf Energy, Inc., Researchers Joshua Castigliego and Chirag Lala, and Senior Economist Liz Stanton, PhD conducted analysis estimating the net change in carbon dioxide (CO2) emissions resulting from New Leaf Energy’s proposed battery storage facility located in Wendell, Massachusetts. AEC estimated net emission savings of this proposed battery storage project as the sum of “positive” CO2 emissions savings (i.e., reduced emissions) from the electric grid due to charging and discharging at specific times and “negative” CO2 emissions (i.e., increased emissions) due to land-use conversion from forestland to grassland. Combined these two effects result in substantial net emissions savings (i.e., reduced emissions) resulting from the proposed New Leaf Energy facility.

The proposed battery facility at the Wendell site would draw power from the grid during periods in which clean, renewable energy sources are a high share of total New England generation, and discharge energy at times when mostly fossil-fuel-powered generators are displaced by this added energy. By charging using low-emission generation and displacing fossil fuel generation while discharging power, new battery resources result in lower electric grid emissions.

This publication is an update to a study originally released in November 2021 (AEC-2021-11-WP-01).

Link to White Paper

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District of Columbia Public Service Commission Formal Case No. 1167 Affidavit regarding Washington Gas and Light Company's 5 and 30 Year Plans

Author: Liz Stanton, PhD

July 2022

In July 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 Washington Gas and Light Company’s (WGL) 5- and 30-Year Plans as part of Formal Case No. 1167. The affidavit addressed WGL Plans’ lack of accounting for justice and equity in planning, lack of planning for fuel sources, and the need for a new cost-benefit analysis to properly analyze WGL’s Plans.

Link to Affidavit

Link to Full Comments

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Entergy Louisiana IRP Comments

Author: Tyler Comings

July 2022

AEC Senior Researcher Tyler Comings co-authored comments (along with Sierra Club) on Entergy Louisiana's Integrated Resource Plan (IRP). The comments ask Entergy to include more reasonable costs for renewable and storage resources, to model more early retirement options for its coal units, and fully capture the costs of using hydrogen fuel.

Link to Comments

Link to Comments on Draft IRP

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Testimony on Consumers IRP in Michigan

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.

Link to Testimony

Link to Rebuttal Testimony

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Minnesota Power IRP Comments

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.

Link to Report

Link to Reply Report

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District of Columbia Public Service Commission Formal Case No. 1167 Affidavit regarding Potomac Electric Power Company's 5 and 30 Year Plans

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.

Link to Affidavit

Link to Full Comments

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Barriers and Opportunities for Green Jobs in New Jersey

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. 

Link to Report

Link to Presentation

Link to Press Release

Media Coverage - NJBiz - June 9, 2022

Media Coverage - NJ Spotlight News - June 8, 2022

Media Coverage - Asbury Park Press - June 8, 2022

Media Coverage - NJ101.5 - June 7, 2022

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Economic Impacts of a Clean Energy Transition in New Jersey

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.

Link to Report

Link to Presentation

Link to Press Release

Media Coverage - NJBiz - June 9, 2022

Media Coverage - NJ Spotlight News - June 8, 2022

Media Coverage - Asbury Park Press - June 8, 2022

Media Coverage - NJ101.5 - June 7, 2022

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Testimony on Demand Charge Alternatives in Massachusetts

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)

Media Coverage - GECA Blog Post - September 30, 2022

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Testimony on the Proceeding on Motion of the Commission as to the Rates, Charges, Rules and Regulations of Consolidated Edison Company of New York, Inc. for Electric Service

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.

Link to Testimony (Case 22-E-0064/65)

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Testimony on Eversource Energy's Certificate of Environmental Impact and Public Interest regarding the East Eagle Street Substation

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.

Link to Testimony (Docket No. EFSB 22-01)

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Risk Assessment of Florida Power and Light and NextEra Energy Clean Energy Transition Plans

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

Link to Report (updated May 16, 2022)

Link to Executive Summary

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Making Clean Energy Decisions in New England

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.

Link to Our Report

Press Release

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