What needs to be fixed before reauthorizing the Public Utilities Commission? The answer is simple: the process.

The last time the commission was reauthorized in 2021, lawmakers expanded its role in meaningful ways — particularly as Colorado accelerated its clean energy transition. The PUC was asked to do more, to carry more and to implement increasingly complex policy goals.

But the process governing how those decisions are made was not meaningfully modernized. That matters now more than ever.

Since the commission’s last comprehensive performance audit in 2014, it has been reauthorized twice — first in 2015, and again in 2021. Each time, the commission’s responsibilities were extended or expanded. But the underlying process — the transparency, accountability and structural guardrails that should guide those decisions — was not fundamentally updated.

As Colorado once again considers reauthorization, the central question should not just be what policies the commission will carry out — but whether the structure guiding those decisions has been updated to handle the weight being placed on it.

Because if the process wasn’t fixed in 2015, and it wasn’t fixed in 2021, what reason do we have to believe it will be fixed now?

What makes this moment even more consequential is the timeline proposed. The current reauthorization would extend the life of this structure until 2037 — locking in today’s regulatory framework across the terms of at least two future governors. That is not a routine extension; it is a long-term commitment to a system actively evolving, without first resolving the concerns already raised about transparency, accountability and real-world effects.

Reauthorization should not be used to cement a process that stakeholders across Colorado have said is not working.

Today, the commission is no longer operating solely as a regulator of utility service. In practice, it is increasingly positioned as the central implementer of the state’s energy policy framework. The legislature sets broad targets, but the commission is given growing authority to determine how those targets are achieved — through resource planning, infrastructure decisions and cost allocation that affect communities across the state.

At the same time, many of the guardrails that would traditionally accompany that level of authority remain limited or dependent on modeling assumptions rather than real-world outcomes. Cost protections are often evaluated through long-term projections, while households and businesses experience the effects in real time.

The result is a structure where the commission is not just regulating the system — it is, in many ways, designing it.

Throughout months of stakeholder discussions, participants from across the state — including energy providers, local governments, labor representatives and community leaders — raised consistent concerns about affordability, reliability, workforce effects and implementation timelines. Yet when draft policies emerged, many of those structural concerns remained largely unchanged.

That raises a fundamental question: if input from across Colorado did not materially shape the outcome, what role did the process actually serve? And more importantly — has that process changed at all? Because if it hasn’t, extending it to 2037 doesn’t solve the problem — it embeds it.

This trajectory concentrates decision-making authority in a way that blurs the line between policymaking and regulation — without adding the transparency that level of authority demands. It relies on modeling assumptions to define affordability, while households experience real costs in real time. And it moves forward without enforceable guardrails for workforce stability or host communities.

It also builds on recent policy decisions that have already begun to shift costs and system pressures onto households — particularly through the combined effects of electrification policy and changes to the gas system.

In Pueblo, where the early closure of a major generating station came with assurances of replacement investment, recent decisions have left that promise in question — while the economic effects are already being felt.

Before reauthorizing the Public Utilities Commission, lawmakers should pause and make targeted structural corrections. That includes reestablishing clear boundaries between policymaking and regulatory authority, requiring real-world affordability analysis that reflects cumulative rate effects, and embedding enforceable reliability standards before major system changes are approved. It also means incorporating workforce and community protections — including labor displacement analysis — and increasing transparency in the assumptions used to justify major decisions.

Because the issue in front of us is not whether Colorado will move forward with its energy transition — it will. The issue is whether the process guiding that transition has been modernized to meet the moment.

It has not. And until it is, we should not lock it in for another decade.

Sara Blackhurst is president of Action Colorado, a statewide organization focused on public policy, economic development, and leadership engagement across Colorado’s southern and rural communities.