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Comments to the Colorado Public Utilities Commission on Electricity Rule Changes

The Colorado Public Utilities Commission is amending its rules relating to utilities, electric resource planning, and renewable energy standards. We submitted comments explaining why the Commission should use Social Cost of Greenhouse Gases estimates to monetize the externalities of carbon pollution. Our recommendations include rule revisions and new language that will help include monetized estimates of climate impacts in all relevant decisionmaking. We also submitted comments and reply comments on additional rule revisions, building on our original comments to further describe how the Commission can best express and apply the Social Cost of Greenhouse Gases.

The Commission recently called for public input on approaches that could be used to value impacts of carbon emissions. Our comments detail how using Social Cost of Greenhouse Gases estimates advances the interests of Colorado’s ratepayers and citizens. We specifically recommend that the Commission apply the Interagency Working Group’s 2016 Social Cost of Greenhouse Gases, which are the best available estimates for monetizing climate damages. We propose language for incorporating monetized climate impacts, discuss alternative rule changes, and highlight the Commission’s legal authority for these changes.

Jason Schwartz recently provided testimony in a Colorado Senate hearing on a potential requirement for the Commission to weigh the social costs of pollution in its decisions.