Ameren Missouri Rate Case

Photo Credit: Missouri Department of Natural Resources

Client: Sierra Club

Author: Tyler Comings

April 2023

Senior Researcher Tyler Comings filed testimony before the Missouri Commission on Ameren Missouri's rate case. Mr. Comings argued that Ameren should be considering earlier retirement of its coal units, especially given pending environmental regulations and lower-cost clean replacement options. He also recommended that Ameren be asked to identify capital costs that could be avoided should they be retired earlier than currently planned.

 Link to Testimony

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Carbon Capture, Utilization, and Storage and Louisiana’s Power Sector

Image Credit: Chad Davis, CC by 2.0

Client: Union of Concerned Scientists (UCS) and Louisiana Against False Solutions Coalition

Authors: Chirag T. Lala, Joshua R. Castigliego, Sachin Peddada, Liz Stanton, PhD

April 2023

On behalf of the Union of Concerned Scientists (UCS) and the Louisiana Against False Solutions Coalition, Researchers Chirag Lala and Joshua Castigliego, Assistant Researcher Sachin Peddada, and Senior Economist Liz Stanton, PhD prepared a report that assesses the viability of carbon capture, utilization, and storage (CCUS) as a decarbonization strategy in Louisiana’s power sector. AEC staff finds that CCUS is vulnerable to damage, poses risks to human health, safety, and the environment, and has a limited emissions reduction potential.

To fully understand and mitigate the risks associated with CCUS, decision-makers must assess (1) how and to what extent CCUS could negatively impact surrounding communities, (2) what policies, rules and regulations are required to ensure that CCUS deployment is conducted in a safe and responsible manner, and (3) which applications are most appropriate for CCUS versus other decarbonization alternatives. To identify the most appropriate role that CCUS could play in Louisiana’s decarbonization efforts, decision-makers must take into consideration the technical and economic feasibility, emissions reduction potential, and safety of CCUS infrastructure compared to that of alternative decarbonization strategies.

 Link to Report

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Impact of Refinery Row on the City of Corpus Christi

Client: Indigenous Peoples of the Coastal Bend

Authors: Tanya Stasio, PhD, Sachin Peddada, Elisabeth Seliga, Jordan Burt, Liz Stanton, PhD

March 2023

On behalf of the Indigenous Peoples of the Coastal Bend (IPCB), this Applied Economics Clinic (AEC) report summarizes the economic impact of the petroleum industry in Nueces County, Texas and the negative impacts of the polluting facilities located in the City of Corpus Christi and its “Refinery Row” district. While major petroleum companies have promised economic benefits, Corpus Christi's petroleum refineries employ less than 2 percent of the City's workforce. In the absence of more stringent reporting requirements and enforcement actions, Refinery Row releases high levels of harmful pollutants with minor consequences while nearby neighborhoods suffer higher rates of asthma and cancer prevalence rates than other areas in Corpus Christi. 

This report was funded through AEC's Pro Bono Fund, which provides pro bono analysis, research, testimony, policy briefs, or detailed reports to Environmental Justice groups on topics including energy economics, climate and other environmental impacts, and diversity, equity, and inclusion analysis.

Link to Report

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Comparing Connecticut's Electric Vehicle Charging Program with Others from around the United States

Prepared on behalf of Connecticut Office of Consumer Counsel

Authors: Bryndis Woods, PhD, Sachin Peddada, Jay Bonner, Liz Stanton, PhD

March 2023

On behalf of the Connecticut Office of Consumer Counsel, this Applied Economics Clinic (AEC) white paper reviews the potential for electric vehicle (EV) charging programs to provide net benefits to consumers in Connecticut and fourteen other states. AEC finds that Connecticut’s EV charging programs are well-positioned to provide net benefits to consumers and meet the state’s EV and electric vehicle supply equipment deployment goals. Connecticut stands out as a leader due to the detailed nature of its EV and EV charging deployment goals, the inclusion of alternative rate structures to incentivize public EV charging stations, the availability of incentives to cover up to 100 percent of EV charging “make-ready” costs, and enhanced incentives for underserved communities (inclusive of low-income populations). AEC also finds, however, that Connecticut’s EV charging program could be strengthened by adopting best practices from other states’ programs, such as by setting more ambitious EV and EV charging deployment goals, working to target EV charging in as equitable a fashion as possible, and by offering ongoing incentives for EV charging.

Link to Report

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Electric Justice: A Toolkit for the Mid-Atlantic Region

Prepared on behalf of PJM Cities and Communities Coalition

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

Energy decisions affect everyone, but local communities and businesses often lack the time and resources needed to engage in grid operator decision-making. On behalf of the PJM Cities and Communities Coalition, AEC Researcher Tanya Stasio, PhD, Assistant Researchers Elisabeth Seliga and Sachin Peddada, and Senior Economist Liz Stanton, PhD developed a report to assist coalition members and other consumer groups in advocating for greater equity in PJM Interconnection decision-making. This resource was developed with the invaluable input of representatives of organizations that sponsored the Fix the Grid campaign in New England, which is focused on rejecting fossil fuels and calling for a just and democratic energy grid.

Link to Report

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Cumulative Impact Assessment of the North Brooklyn Pipeline Project

Prepared on behalf of Sane Energy and Alliance for a Green Economy

Author: Tanya Stasio, PhD, Jordan Burt, Elisabeth Seliga, Sachin Peddada, Elizabeth A. Stanton, PhD

The National Grid Phase 5 expansion of fossil fuel infrastructure and the Vaporizer 13/14 project at the Greenpoint Energy Center create a multi-pronged set of threats to the North Brooklyn communities.

AEC Researcher Tanya Stasio, PhD, Research Assistant Jordan Burt, Assistant Researchers Elisabeth Seliga and Sachin Peddada, and Senior Economist, Liz Stanton, PhD  have prepared a cumulative impact assessment on behalf of Sane Energy and Alliance for a Green Economy to highlight the existing and overlapping socioeconomic, environmental, and health-related burdens facing the communities living near the pending Phase 5 pipeline construction and vaporizer additions at the Greenpoint Energy Center. AEC finds that the Bushwick, Bedford, and Williamsburg neighborhoods would be impacted the most from these fossil fuel expansion projects and include densely populated communities with majority BIPOC and low-income residents.

Link to Report

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Testimony on The United Illuminating Company’s Proposed Clean Energy Transformation Initiatives

Prepared on behalf of The Connecticut Office of Consumer Counsel

Author: Elizabeth A. Stanton, PhD

On behalf of the Connecticut Office of Consumer Counsel, Senior Economist Elizabeth A. Stanton provided expert testimony to Docket No. 22-08-08 before Connecticut’s Public Utilities Regulatory Authority (PURA). In her testimony, Dr. Stanton reviewed The United Illuminating Company’s (UI) Application and proposed Clean Energy Transformation initiatives to assess whether they are consistent with Connecticut’s climate and clean energy policies, plans, and targets and in the best interest of ratepayers. Dr. Stanton concluded that UI has not provided enough information to adequately assess its proposed cost recovery for clean energy transformation initiatives. Dr. Stanton recommends that PURA should require electric distribution companies to do the following when seeking approval of proposed initiatives and programs: (1) submit benefit-cost analyses, (2) present comparative assessments, (3) engage in public stakeholder processes, and (4) evaluate performance based on specific metrics.

Link to Testimony

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Energy Storage Benefit-Cost Analysis

Prepared on behalf of the Clean Energy States Alliance

Authors: Bryndis Woods, PhD, Sachin Peddada, Elisabeth Seliga, Chirag Lala, Eliandro Tavares, Gabriel Lewis, Tsanta Rakotoarisoa, Elizabeth A. Stanton, PhD

Contributing Editor: Todd Olinsky-Paul, Clean Energy States Alliance

AEC staff prepared a report that provides a framework for state energy agencies contemplating a benefit-cost analysis (BCA) for battery storage on behalf of the Clean Energy States Alliance. AEC’s battery storage BCA framework provides guidance for state energy agencies preparing to conduct cost-effectiveness evaluation for battery storage, including information regarding: cost-effectiveness tests, discount rates, benefits, costs, sensitivity analyses, and stakeholder engagement.

Link to Report

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Testimony on Washington Gas Light Company’s Application to the District of Columbia

Prepared on behalf of the Office of the People’s Counsel for the District of Columbia

Author: Senior Economist Elizabeth A. Stanton, PhD

Senior Economist Elizabeth A. Stanton submitted testimony before the Public Service Commission of the District of Columbia on behalf of the Office of the People’s Counsel for the District of Columbia in response to the Washington Gas Light Company’s (WGL) application to the Public Service Commission of the District of Columbia for authority to increase existing rates and charges for gas service. Dr. Stanton found that the WGL proposals provided limited emission reductions and that in order to achieve the goal of 60% emission reduction by 2030, the District of Columbia needs WGL climate-related proposals to provide for serious emission reductions in the near-term.

Link to Testimony

Link to Surrebuttal Testimony

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Testimony on Indiana Michigan Power IRP

Client: Sierra Club

Author: Senior Researcher Tyler Comings

Senior Researcher Tyler Comings filed testimony before the Michigan Commission on the Indiana Michigan Power (I&M) Integrated Resource Plan (IRP). Mr. Comings found several major flaws with I&M's calculations which unfairly biased the results in favor of keeping its contracted power from some of the oldest coal units in the U.S. He also argued that this contract should be re-evaluated and that, in the event of its termination, related costs should not be passed on to ratepayers.

Link to Testimony

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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.

Link to Report

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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: Researcher Tanya Stasio, PhD, Assistant Researchers Sagal Alisalad, Elisabeth Seliga, and Sachin Peddada, and Research Assistant Jordan Burt

Researcher Tanya Stasio, PhD, Assistant Researchers Sagal Alisalad, 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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