In accordance with a 2019 state law, the Colorado Public Utilities Commission released a summary of comments it received from electric utilities and other relevant organizations as they prepare to file plans to support “widespread” transportation electrification.

Senate Bill 77 directed public utilities to file with the PUC an application detailing how they would support vehicle electrification, which the commission would evaluate against safety, reliability, air quality standards, and the accessibility provided to low-income customers. The legislation set a deadline to file of May 15, 2020.

The commission asked six questions, prompting respondents to identify the states that have implemented cost-effective regulations and the information that utilities believe they should provide to inform the PUC’s evaluation of proposals. Approximately two dozen organizations filed comments, including Black Hills Colorado Electric, the Colorado Energy Office, the city and county of Denver, the Sierra Club, and Tesla.

Multiple entities cautioned against using a cost-benefit analysis for electrification pilot programs, pointing out that Senate Bill 77 did not specifically require that as a criterion. The bill, however, did direct utilities to aim toward maximizing benefits and minimizing costs in their proposals.

There was disagreement about whether utilities should own public charging stations, with Holy Cross Electric Association mentioning the disproportionate use of charging infrastructure depending on the ownership patterns of electric vehicles. Black Hills advocated for the PUC to consider whether utilities included plans for encouraging vehicle charging during cheaper, off-peak hours.

The state’s energy office argued that “at a minimum” utilities should have a strategy for enabling electric charging at airports, electrification of ride-sharing fleets, and electrified public transit. It pointed to Maryland, where that state’s public utilities commission approved a plan to install more than 5,000 public charging stations and a residential rebate program, as a potential model.

There was general agreement among respondents that utilities should estimate the effect of their plans on lowering greenhouse gas emissions from the transportation sector, which the legislation aims to reduce to 80% below 2005 levels by the year 2050.