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Comments to the Colorado Public Utilities Commission on Electric Resource Planning

We recently submitted comments about to the Colorado Public Utilities Commission, which is reviewing its rules on electric resource planning (“ERP”). Our comments aim is to ensure that a proper valuation of externalities is integrated into Colorado’s ERP process, and we suggest using the Social Cost of Carbon to monetize greenhouse gas externalities.

Our comments follow up on previous comments we made to the Commission, and also describe the increasingly common application of Social Cost of Carbon estimates in state-level resource planning. Since January 2018, several states, including California, Minnesota, New Jersey, and Washington, have taken steps to further incorporate such estimates into their policies. Most recently, the Nevada Public Utilities Commission updated their regulations to require that utilities monetize the Social Cost of Carbon for integrated resource plans. We encourage the Colorado Public Utilities Commission to model its own ERP rules revision after Nevada’s.