Comments on Avoided Emissions from Energy Recovery in EPA’s Waste Reduction Model (WARM) v16

AEC’s Emissions Measurement Inventory Tool (AEC-EMIT)

Author: Joshua R. Castigliego

December 2023

To support AEC’s emissions accounting work, Researcher Joshua R. Castigliego developed a spreadsheet-based tool—AEC's Emissions Measurement Inventory Tool (AEC-EMIT)—that provides users with an interface to build a greenhouse gas emissions inventory (and 20-year emissions projections) for a specific geographic region. Users can customize the tool by selecting greenhouse gases, sectors, subsectors, scenarios, sensitivities, and other information specific to their inventory. Users are also provided a dashboard to toggle select assumptions and parameters (e.g., global warming potentials, scenarios, and sensitivities, etc.). Summary tabs aggregate results across sectors and can be used to provide disaggregated sub-sector-specific results.

AEC-EMIT was utilized for AEC’s analysis on Puerto Rico’s 2019 and 2021 Greenhouse Gas Inventories Report.

Space Heating with Heat Pumps: The Need for Alternative Rate Designs in Massachusetts

Client: Green Energy Consumers Alliance (GECA)

Author: Joshua R. Castigliego, Elisabeth Seliga, Elizabeth A. Stanton, PhD

December 2023

On behalf of the Green Energy Consumers Alliance (GECA), Researcher Joshua R. Castigliego, Assistant Researcher Elisabeth Seliga, and Senior Economist Elizabeth A. Stanton prepared a white paper that presents a preliminary assessment of costs to customers heating with air-source heat pumps, and discusses the need for alternative electric rate designs to make heating electrification cost effective in Massachusetts. An “operating cost gap” is a measure that can be used to determine whether switching from one heating system to another would be a cost-effective choice for a given household. The “cost gap” is the difference between current and expected future operating costs and can be used to compare different heating systems. A household looking to electrify its heating system by switching from a gas-fired furnace to electric heat pumps will include this operating cost gap in its decision-making. AEC’s analysis finds that an average-sized Massachusetts home heating with air-source-heat pumps (ASHPs) versus gas-fired heating results in an operating cost gap, under current gas and electric rate schedules, between $166 and $605 over the 6-month heating season between November and April.

Alternative rate designs have the potential to close the operating cost gap between heating technologies, which would make ASHPs a cost-effective heating option relative to fossil-fuel heating systems like gas-fired furnaces. By exploring and implementing alternative rate designs, Massachusetts would be able to make ASHPs more attractive to consumers, which would stimulate the widespread adoption of electric heat pumps and support its decarbonization efforts in the buildings sector.

AEC's Heating Electrification Assessment Tool (AEC-HEAT) was utilized in this analysis to estimate the heating component of a residential customer's energy usage

Link to White Paper

Link to AEC-HEAT [Excel Workbook]

AEC's Heating Electrification Assessment Tool (AEC-HEAT)

Client: Green Energy Consumers Alliance (GECA)

Author: Joshua R. Castigliego, Elisabeth Seliga

December 2023

On behalf of the Green Energy Consumers Alliance (GECA), Researcher Joshua R. Castigliego and Assistant Researcher Elisabeth Seliga developed a spreadsheet-based tool—AEC's Heating Electrification Assessment Tool (AEC-HEAT)—that (1) compares heating costs for various resource types and (2) evaluates the impact of new space heating electrification on regional peak electric use during the winter heating season.

AEC-HEAT houses two Dashboard tabs (i.e., Heating Costs Dashboard and Load Profile Dashboard) to provide users with an interface to evaluate impacts associated with space heating electrification. Users can customize the tool by selecting parameters from drop-down menus or inputting their own data values. AEC-HEAT is currently equipped to perform assessments specific to Massachusetts but has the ability to evaluate other jurisdictions pending data availability. AEC-HEAT's User Guide and Methodology document provides an overview of the tool as well as the methodological approach, parameters, and data requirements.

AEC-HEAT was utilized in the analysis for AEC’s December 2023 white paper, Space Heating with Heat Pumps: The Need for Alternative Rate Designs in Massachusetts.

Link to User Guide and Methodology

Distributed Energy Storage: The Missing Piece in North Carolina's Decarbonization Efforts

Client: Clean Energy Group (CEG)

Author: Tanya Stasio, PhD, Elisabeth Seliga, Deja Garraway, Bryndis Woods, PhD, Elizabeth A. Stanton, PhD

December 2023

On behalf of the Clean Energy Group (CEG), Researcher Tanya Stasio, Assistant Researcher Elisabeth Seliga, Researcher Deja Torrence, Senior Researcher Bryndis Woods, and Senior Economist Elizabeth A. Stanton prepared a report that identifies distributed energy storage as the missing piece in North Carolina's decarbonization efforts. Distributed energy storage can provide load management to help meet peak electric demand and reduce the need for costly and polluting fossil fuel peaker plants. When paired with solar PV, distributed energy storage batteries can provide clean backup power to improve energy resilience while reducing home energy bills.

To support North Carolina’s decarbonization efforts and equity goals, this report makes three key policy recommendations for increasing incentives and lowering barriers to distributed energy storage deployment:

Approve and expand utility deployment of equitable distributed solar and distributed energy storage pilot programs.
Create statewide financial incentives for residential and community-based distributed solar and behind-the-meter battery installations.
Establish equity, climate, and energy performance-based metrics and targets for electric utilities.

Link to the Report

Testimony on Kentucky Power 2023 Rate Case

Client: Mountain Association, Appalachian Citizens’ Law Center, Kentuckians for the Commonwealth, and Kentucky Solar Energy Society

Author: Tyler Comings

December 2023

AEC Senior Researcher Tyler Comings filed testimony before the Kentucky PSC on behalf of Joint Intervenors (Mountain Association, Appalachian Citizens’ Law Center, Kentuckians for the Commonwealth, and Kentucky Solar Energy Society). Mr. Comings recommended that the utility's return on equity (ROE) should not be increased because of several flaws in its estimate of the ROE; and that the utility had exaggerated its level of financial distress.

Comments on Xcel Colorado's Electric Resource Plan

Client: Sierra Club

Author: Tyler Comings

December 2023

Senior Researcher Tyler Comings (along with Telos Energy and Strategen Consulting) assisted Sierra Club and NRDC in comments on Xcel Colorado's Electric Resource Plan. The comments argued for rejecting a proposed biomass project and instead adding more solar and battery resources than what Xcel included in its preferred plan. The comments also discussed the risks of Xcel's planned new gas procurement: in particular the utility's assumption that new gas units could become carbon-free, but not incorporating all of the costs required to achieve that status.

Link to Comments

Testimony on DTE Electric Company 2023 Rate Case

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

Author: Tyler Comings

December 2023

AEC Senior Researcher Tyler Comings filed testimony before the Michigan PSC on the DTE Electric Company (DTE) 2023 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 followed through on its recent plan to retire Monroe units 3 and 4 in 2028.

Economic Impacts of Offshore Wind in Connecticut

Client: Connecticut Roundtable on Climate and Jobs (CRCJ)

Author: Chirag T. Lala, Joshua R. Castigliego

October 2023

On behalf of the Connecticut Roundtable on Climate and Jobs (CRCJ), Researchers Chirag Lala and Joshua Castigliego prepared a policy brief that assesses the economic impacts associated with installing and operating 2,000 megawatts (MW) of offshore wind resources in Connecticut to meet the State’s 2030 target. The benefits of wind procurement need not flow to Connecticut’s economy if neighboring states undertake industrial development efforts and Connecticut does not. AEC’s analysis finds that a concerted policy effort to develop Connecticut’s offshore wind industry would allow the addition of these offshore wind resources to create a total of 39,880 in-state job-years (i.e., one job-year is the equivalent of one person working full-time for one year) between 2024 and 2049 as well as an estimated $5,529 million in state economic output and $4,190 million in labor income

Link to Policy Brief

Testimony on OVEC Power Plants Subsidies and Ohio Consumer Charges

Client: Office of the Ohio Consumers’ Counsel

Author: Elizabeth A. Stanton, PhD

October 2023

On behalf of the Office of the Ohio Consumers’ Counsel, Senior Economist Elizabeth A. Stanton submitted expert testimony concerning subsidy charges related to OVEC power plants. She emphasized the need for close scrutiny by the Public Utilities Commission of Ohio (PUCO) to ensure that these charges are prudent, in the best interests of consumers, and compliant with PUCO orders. Dr. Stanton's recommendation is to disallow the collection of imprudently incurred OVEC costs from the Company's customers.

Link to Missouri Comments

Evergy Integrated Resource Plan in Missouri and Kansas

Client: Sierra Club

Author: Tyler Comings, Joshua Castigliego

October 2023

Senior Researcher Tyler Comings and Researcher Joshua Castigliego co-wrote comments on Evergy's Integrated Resource Plan (IRP) that were filed with the commissions in Kansas and Missouri. AEC's comments focused on Evergy's bias towards choosing new gas replacement, including its assumption that new gas would become carbon-free at no cost. AEC also noted assumptions that were overly optimistic for Evergy's coal units and that the company's consideration of early retirement for some units was too limited.

Link to Kansas Comments

Equity and Justice in Rhode Island’s Climate Policy

Client: The Nature Conservancy (TNC) and the State of Rhode Island Department of Environmental Management (DEM)

Author: Bryndis Woods, PhD

September 2023

On behalf of The Nature Conservancy (TNC) and the State of Rhode Island Department of Environmental Management (DEM), Senior Researcher Bryndis Woods, PhD and other AEC staff provided two environmental justice (EJ) and equity-focused training sessions for Rhode Island’s Executive Climate Change Coordinating Council (EC4), the EC4 Advisory Board (AB), and the EC4 Science and Technical Advisory Board (STAB).

The presentations included: an equity baseline for Rhode Island, including maps of Rhode Island EJ communities; foundational training on EJ and equity concepts to develop a shared understanding and vocabulary; an EJ and equity framework that provides guidance for EC4, AB and STAB to meaningfully incorporate EJ and equity in their planning and decision-making; Rhode Island-specific equity examples, including equity opportunities and common pitfalls as they relate to economy-wide decarbonization efforts; EJ scenarios for participants to consider and discuss; and recommendations for participants that will help them proactively prioritize equitable outcomes.

Link to Presentation

Link to Direct Testimony

Testimony on Dominion's 2023 Integrated Resource Plan

Client: Clean Virginia

Author: Bryndis Woods, PhD

August 2023

Senior Researcher Bryndis Woods, PhD filed testimony before the Virginia State Corporation Commission on Virginia Electric and Power Company’s (“Dominion”) 2023 Integrated Resource Plan (IRP). Dr. Woods' testimony addresses failures by Dominion in its 2023 IRP to:

Meet the basic obligations of the Virginia Clean Economy Act including energy efficiency requirements, renewable energy requirements and fossil fuel retirement requirements;
Present useful modeling results: the Company fails to identify a preferred plan, a feasible least-cost plan, or present meaningfully distinct modeling results over the planning period;
Conduct a peak load sensitivity analysis that adequately accounts for uncertainties related to Dominion's load forecast, particularly anticipated load from data centers;
Account for federal regulations that impact its coal fleet or consider a reasonable social cost of carbon; or
Address environmental justice impacts of its resource planning decisions or conduct any stakeholder engagement as part of the 2023 IRP development.

As a result of these failures, Dr. Woods concludes that the Commission cannot find Dominion’s 2023 IRP to be reasonable and in the public interest, and provides specific recommendations for the Company’s IRPs moving forward.

Link to Testimony Corrections

Return to Publications

Testimonies and technical support regarding seven New Jersey utility energy efficiency and peak demand response planning and programs

Client: New Jersey Rate Counsel

Elizabeth A. Stanton, PhD

August 2023

On behalf of New Jersey Rate Counsel, Clinic Director and Principal Economist Dr. Liz Stanton drafted testimony in dockets for seven New Jersey utilities regarding their plans for their energy efficiency and peak demand response programs, focusing on: the size and cost of proposed programs and measures; building decarbonization planning and expected changes to total utility bills; full system cost accounting in building decarbonization program budgets; demand response roll-out and expected customer impacts; staff and other technical capacity to successfully implement budgeted programs; and other ratepayer impacts. These testimonies are not publicly available due to a settlement agreement.

Since 2023, Dr. Stanton has also provided technical support to New Jersey Rate Counsel in various stakeholder processes related to New Jersey utilities’ energy efficiency programs and planning, including three-year plan development, Evaluation Measurement and Verification (EM&V), and Technical Resource Manual (TRM).

Puerto Rico’s 2019 and 2021 Greenhouse Gas Inventories Report

Client: Puerto Rico Department of Natural and Environmental Resources (DNER)

Authors: Liz Stanton, PhD, Joshua R. Castigliego, Chirag T. Lala, Sachin Peddada,
Jay Bonner, Eliandro Tavares, Sumera Patel, Alicia Zhang, Myisha Majumder,
David Jiang, and Jordan Burt; Ramón Bueno and Kari Hewitt

July 2023

On behalf of the Puerto Rico Department of Natural and Environmental Resources (DNER), AEC staff and partners prepared a report that presents the results for Puerto Rico’s 2019 and 2021 greenhouse gas emission inventories together with 20-year emissions projections under several scenarios and sensitivities. AEC established a methodology for conducting greenhouse gas emission inventories in Puerto Rico, which went through a comprehensive quality assurance and quality control process by an Expert Panel (established for this project and composed of experts in greenhouse gas emissions measurement and Puerto Rico climate and energy issues). Using AEC’s Emissions Measurement Inventory Tool (AEC-EMIT), AEC calculates net greenhouse gas emissions released in Puerto Rico’s seven emitting sectors: (1) Power Supply, (2) Direct Fuel, (3) Industrial Processes and Product Use, (4) Transportation, (5) Agriculture, (6) Forestry and Other Land Use, and (7) Waste Management.

Puerto Rico’s 2019 Climate Change Mitigation, Adaption, and Resiliency Law (i.e., Puerto Rico Act No. 33-2019) measures mandated emission reductions against an estimated 2005 emissions level of 53.3 MMT CO₂e and calls for a 50 percent reduction relative to 2005 emissions by 2025 (26.7 MMT CO₂e). Emission levels achieved in 2021 (34.3 MMT CO₂e) represent a 36 percent reduction in emissions from 2005 levels. With 14 percentage points and 4 years left to go, Puerto Rico must find another 7.7 MMT CO₂e to eliminate. Based on the Business-as-Usual projection in AEC’s analysis, Puerto Rico’s greenhouse gas emission levels will reach their mandated levels (50 percent of 2005 levels, or 26.7 MMT CO₂e) in 2035, 10 years later than the required 2025 target.

Based on the analysis presented in this report, AEC has identified several key recommendations to further facilitate Puerto Rico’s work towards achieving its ambitious and necessary decarbonization goals set out in Puerto Rico’s 2019 Climate Change Mitigation, Adaption, and Resiliency Law, including: (1) better data collection, (2) increased climate progress reporting (3) reprioritization in rebuilding its electric sector, and (4) a new focus in transportation planning.

Link to Report (English)

Link to Report (Español)

Return to Publications

Assessing TVA’s IRP Planning Practices

Norris Dam in Anderson County, Tennessee. Image Credit: Brian Stansberry / Creative Commons

Client: Prepared on behalf of the Southern Environmental Law Center

Authors: Chirag Lala, Elisabeth Seliga, Liz Stanton, PhD

July 2023

On behalf of the Southern Environmental Law Center, Researcher Chirag Lala, Assistant Researcher Elisabeth Seliga, and Senior Economist Liz Stanton, PhD published a report that compares the Tennessee Valley Authority’s (TVA’s) Integrated Resource Planning (IRP) processes in 2011, 2015, and 2019 to the actual changes in capacity additions and retirements made by TVA from 2011 to 2021. The paper also examines the site-specific planning process used by TVA to determine the replacements for the Cumberland Fossil Plant.

AEC staff make several key recommendations for TVA’s 2024 Integrated Resource Planning Process: (1) TVA must set aggressive climate goals in line with the Paris Agreement and the Biden Administration’s executive orders on achieving carbon free electricity by 2035; (2) TVA must be transparent about its assumptions and modeling inputs; (4) TVA must select a portfolio with a more targeted preferred resource plan; (3) TVA must plan to utilize the grants, loans, and tax credits of the Inflation Reduction Act; (5) TVA must clarify how it demarcates “ownership” of solar and wind resource; (6) TVA should conduct an all-resource Request for Proposals (RFP) for new resources; (7) TVA must ensure its site-specific planning documents reflect the most recent IRP plans and use methods that do not contradict overall system- and other site-specific planning exercises.

Link to Report

Link to Environmental Group Comments on TVA IRP

Return to Publications

The Interconnection Bottleneck: Why Most Energy Storage Projects Never Get Built

Image Credit: Sara Levine | Pacific Northwest National Laboratory

Client: Clean Energy Group

Authors: Chirag Lala, Jordan Burt, and Sachin Peddada

May 2023

On behalf of the Clean Energy Group, Researcher Chirag Lala and Assistant Researchers, Sachin Pedadda and Jordan Burt prepared a report that assesses the obstacles preventing efficient interconnection of distributed energy storage resources. This Applied Economics Clinic (AEC) white paper identifies and explains these interconnection barriers in Massachusetts and makes recommendations to state agencies and working groups overseeing interconnection, distribution utilities, independent system operators, and the Federal Energy Regulatory Commission.

AEC staff make these five key recommendations to stakeholders: (1) Develop proactive, integrated, and system-wide interconnection planning that takes a systemic view of applications and separates hosting capacity upgrades from particular project or cluster applications and makes hosting capacity upgrades in anticipation of grid-needs and future interconnection volume. (2) Continuously iterate interconnection processes to build in regular improvements, examine effectiveness, and coordinate public and private stakeholders to tackle ad hoc coordination problems. (3) Tackle barriers and solutions comprehensively by integrating multiple solutions. (4) End cost causation by spreading distribution system upgrade costs over a broader set of stakeholders (including ratepayers) than just allocating those costs to the projects or clusters applying for interconnection. (5) Incorporate storage operational parameters into interconnection processes so that storage resources are assessed in a manner reflecting how they would reasonably be expected to operate once interconnected alone or in conjunction with technologies regulating bidirectional power flows and facilitating predictable charging and discharging.

Link to Report

Massachusetts MLPs Exemption from RPS: Impacts on Clean Energy

Client: Prepared on behalf of Massachusetts Climate Action Network

Authors: Tanya Stasio, PhD, Elisabeth Seliga, Liz Stanton, PhD

April 2023

On behalf of the Massachusetts Climate Action Network, Researcher Dr. Tanya Stasio, Assistant Researcher Elisabeth Seliga, and Senior Economist Dr. Liz Stanton prepared a presentation on the Massachusetts Municipal Light Plant (MLP) exemption from the Renewable Portfolio Standard (RPS) and the impact on clean energy in the Commonwealth. AEC finds that the MLP Greenhouse Gas Emissions Standard, and the RPS exemption, allow MLPs to remain at today's level of Class I renewable energy sources, resulting in substantially less clean energy in the Commonwealth than if MLPs were required to comply with the RPS.

This work was presented at the April 19th, 2023 MCAN Legislative Launch titled, "Advancing Clean Energy, Equity, and Innovation in Municipal Utilities." For more information, or to watch the recording of the event, visit the MCAN website here.

Link to Presentation

DTE Electric Company IRP

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

Author: Tyler Comings

April 2023

Senior Researcher Tyler Comings filed testimony before the Michigan Commission on DTE Electric Company's Integrated Resource Plan (IRP). Mr. Comings argued that two of the Monroe coal should be retired in 2032, as opposed to 2035 in DTE's plan. He helped develop an alternative plan that included earlier retirement of the coal units with clean replacement resources which was cheaper than DTE's plan.

Link to Direct Testimony

Link to Rebuttal

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.