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Comments to Montana PSC on Petition for Rulemaking on Consideration of Climate Impacts

In February, a coalition of public-interest organizations filed a petition for rulemaking requesting that the Montana Public Service Commission consider climate change in its regulation of electric and gas utilities. The Petition for Rulemaking calls on the Commission to consider the impacts of climate change in its proceedings using the Environmental Protection Agency’s latest estimates of the social cost of greenhouse gases. 

In support of the petition, our comment offers the following insights:

  • The social cost of greenhouse gases is a well-established tool for valuing the incremental impacts of climate change per ton of greenhouse gas emissions.
  • Numerous U.S. states use the social cost of greenhouse gases in utility and public-service proceedings such as resource planning, ratemaking, and elsewhere.
  • EPA’s 2023 valuations reflect the most recent and robust government climate-damage estimates. However, they are widely regarded as underestimates due to omitted impacts, supporting the Petition for Rulemaking’s treatment of them as a floor for measuring climate effects.