The PUC is a regulatory commission that provides oversight of public utilities in Colorado, regulating rates and services. While cooperatives are subject to PUC oversight, their relationship with the PUC differs from that of a public utility in important ways. As such, cooperatives have been exempt from certain regulatory enforcement and procedural activities. The result of this policy difference is apparent in the generation mixes and resource planning of Tri-State and other Colorado utilities such as Xcel Energy: while Tri-State remains heavily invested in coal, Xcel recently made public commitments to achieve large-scale reductions in greenhouse gas emissions and announced plans to invest $2.5 billion in projects that will generate over 2000 megawatts of renewable energy in Colorado.
The PUC has previously found that it has jurisdiction over Tri-State's resource planning but has so far neglected to exercise that oversight. Tri-State instead conducts its own internal resource planning. We ask that the PUC mandate Tri-State's participation in the PUC's resource planning framework. While Tri-State reasons that it is difficult to comply with PUC processes because it operates in multiple states, the effect of this exception is compromised agency of member-owners and relevant stakeholders. In bypassing these procedures, Tri-State obstructs transparency around its resource planning and prevents adequate member engagement that is central to the cooperative structure. The PUC should compel Tri-State to submit its resource planning for review by state agency so that minimum best practices can be ensured and overall transparency increased. As ratepayers and member-owners of a Colorado utility, we would like Tri-State to be subject to the same oversight and regulation as other Colorado utilities. For example, a detailed economic analysis of coal assets owned by Tri-State, and comparative wholesale renewable energies should be a central component of Tri-State's resource planning.
Under current resource planning framework, Tri-State may conduct such an analysis but faces no compulsion to adhere to its findings. PUC enforcement is needed to ensure that Tri-State incorporates the best available information in its resource planning decisions.
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