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California Public Utilities Commission- Comments on Interim Greenhouse Gas Adder

We recently submitted comments to the California Public Utilities Commission on their proposal for an interim greenhouse gas adder. The proposal was for an adder that starts at $0 in 2017 and increases linearly to $250 in 2030. We support the use of a greenhouse gas adder and agree that an interim adder should be used as an input into a proposed societal cost test or modified total resource cost test. However, our comments suggest that the Commission instead use an adder based on the Interagency Working Group’s Social Cost of Carbon (“SCC”).

The SCC is the best available estimate of the value of each ton of carbon emission reductions, and will more accurately value the benefits that come from reductions of greenhouse gas emissions. Even if Staff chooses not to use the SCC as the adder, our comments recommend that the adder not start at $0.