SDSG Comments on Xcel Energy's Proposed Gas Infrastructure Plan

On January 20th, SDSG submitted written comments to the Colorado Public Utilities Commission (PUC) in relation to Xcel Energy's proposed Gas Infrastructure Plan (GIP), which is the company's proposal for expanding its methane gas network to deliver more gas to commercial and residential customers in Colorado. SDSG, along with numerous other Colorado based organizations, opposes the GIP as currently designed. Our comments focused on three major issues:

1) Colorado's state legislature passed binding "Clean Heat" targets for large-scale gas utilities, requiring a 41% reduction in Green House Gas Emissions by 2035. The gas network expansion in Xcel's GIP would make it nearly impossible for Xcel to meet those targets. Meaning either i) the State of Colorado would need to abandon its climate targets; or) Xcel would need to abandon its gas network infrastructure to meet the targets, creating expensive stranded assets that ratepayers would be reimbursing for decades to come. That's lose-lose.

2) There are numerous viable energy alternatives (so-called NPAs "Non-Pipeline Alternatives") to methane which Xcel's GIP failed to adequately consider. These technologies, such as heat pumps, are more energy efficient and are becoming cheaper thanks to subsidies. State officials have estimated that implementing NPAs could produce nearly $1 billion in economic benefits while avoiding about $5.1 billion in climate-related costs with greenhouse gas emissions.

3) Xcel's GIP failed to adequately calculate the Green House Gas Emissions that would be emitted due to expanded gas infrastructure. Additionally, Xcel failed to provide "Social Cost of Carbon" analysis in key parts of the GIP as required by Colorado Law. These costs would amount to billions of dollars and be borne by Colorado residents and Xcel ratepayers. Proper integration of the Social Cost of Carbon into Xcel's GIP would change the cost-benefit analysis of investment decisions in favor of renewable energy projects.

SDSG's Sydney Christian appeared before the Public Utilities Commissioners to deliver oral testimony, which summarized our written comments.

The PUC is holding an Evidentiary Hearing on the merits of Xcel's GIP through January 23rd. It is expected to make a final ruling on the GIP proposal by March 25, 2026.