Public Comment Guidance for Tri-State Rulemaking 19R-0408E
TIPS: Please be sure to include the following items when submitting your public comment to the Public Utilities Commission (PUC):
● The rulemaking docket number: 19R-0408E
● If you know it: The name of the electric coop you belong to, e.g., United Power
ASKS: As part of the ongoing rulemaking (which takes place now through October 15th), energy consumers are asking the PUC to:
1) Require that Tri-State evaluate the cost of existing resources during its ERP to ensure that Tri-State is appropriately calculating the risks and costs of its expensive coal fleet.
2) Require that Tri-State utilize the Social Cost of Carbon in its ERP to account for the health and environmental impacts of carbon emissions from its power plants that cause climate change and negatively impact Colorado communities
3) Require that Tri-State consult with impacted workers to submit a workforce transition plan when proposing the retirement of an electric generating facility.
1) Clean energy is more affordable than coal. That’s why we need the PUC to require an evaluation of existing resources in Tri-State’s planning.
In order to fulfill it obligation to ensure that rates are just and reasonable, the PUC must evaluate the economics of, and the need for, a utility’s existing electricity resources, such as an existing coal plant. As the energy market continues to shift towards more affordable renewable energy generation, it is essential to ensure that Colorado ratepayers who depend on affordable, reliable electricity are getting the best deal. Technological advancements in solar and wind are reinventing power and energy, where traditional resources such as coal are no longer be the safest, healthiest or cheapest options.
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In 2019, a report by Strategen found that Tri-State’s Craig 3 and Craig 2 are the #1 and #3 most expensive coal units in the state of Colorado.
In 2018, a report by Rocky Mountain Institute found that Tri-State could save its co-op members $600 million by shifting from coal to low-cost renewable
In 2018, Vibrant Clean Energy found that retiring all of the remaining coal units in Colorado by 2025 would reduce system-wide costs by approximately $2.5 billion through 2040.
2) Climate action is needed to protect rural communities. That’s why we need Tri-State to utilize the Social Cost of Carbon in its planning.
The Social Cost of Carbon provides a monetary estimate of damages wrought by the greenhouse gases that cause climate change. Colorado businesses, families, and communities are already bearing the costs of climate change, through increased wildfires, hail storms, droughts, and other damages. A few examples of the costs that the state of Colorado and regular Coloradans are paying due to damage from climate change include:
● In 2018, wildfire suppression cost $130 million in Colorado, which excludes the 12,000 homes that were damaged, the 600,000 displaced people, and other expenses associated with the climate-induced disasters.
● The hailstorm that hammered West metro Denver on May 8, 2017 cost $1.4 billion in damages, making it Colorado’s costliest natural disaster. We can’t afford more hailstorms like this to be exacerbated by climate change.
● Boulder County estimates that by 2050, mitigating potential effects of climate change would conservatively cost anywhere from $96 to $157 million, which includes infrastructure, human, and natural sectors.
3) Colorado needs a just transition for impacted workers and communities, That’s why we need the PUC to require Tri-State to submit workforce transition plans.
As we move towards a clean energy economy, it is essential that we honor the hard work of generations of Coloradans working in the electric sector by ensuring a just transition away from fossil fuels for workers and communities. In May 2019, Governor Polis signed Senate Bill 236, which includes language that requires utilities to submit a workforce transition plan along with any filing that includes a proposal to retire an electric generating unit, like a coal or gas plant. Tri-State should have to submit a workforce transition plan when it chooses to retire coal units.
Want to Write a Public Comment? Here’s How:
1. Visit the PUC’s Google Form for Filing a Comment:
2. Select: “expressing an OPINION”
3. Choose the industry you are expressing an opinion about: Select “Electric”
4. Follow the directions on the next page that say, “Please continue by clicking on the following link:
5. Select: “Rulemaking and Investigations Initiated by Colorado Public Utilities Commission”:
6. Select “19R-0408E - Proposed Rules Implementing ERP for Wholesale Coops”
8. Write comment in text box, and attach any relevant attachments