The Colorado Public Utilities Commission is revising their electricity resource planning process. Our comments to the Commission suggest legal language for incorporating externalities, like the climate effects of greenhouse gas emissions, into the state’s electricity policy. We also explain why the Social Cost of Carbon, as developed by the federal government in 2016, is the best tool for incorporating the externalities of carbon emissions into policy.
Our response comments rebut the state electric utility’s faulty arguments against using the social cost of carbon in this process, and supports the use of cost-benefit analysis in determining the best policy option.