PUC staff and intervenors urge electrification study; debate continues over who should run programs and how to fund them

PUC staff, intervenors and state officials told the commission on Oct. 31 that an electrification study and a small pilot are intended to be complementary steps but will not, by themselves, answer all legal or incentive‑structure questions about utility‑led beneficial electrification.

Eric Haglund, section head of the PUC economics team, said staff supports a targeted study focused on Black Hills’ service territory to produce empirically grounded assumptions—participation rates, incremental costs, and installation needs—that could narrow the range of cost estimates offered by parties. "The hope is that a study provides some actual empirical evidence of efforts...what costs and potential benefits are available for BE in specifically in Black Hills service territory," Haglund said. He also acknowledged that legal and policy questions about utility incentives and authority might require a separate, non‑adjudicative proceeding.

Justin Brandt, testifying for Sweep, said his illustrative portfolio used a $2,000 per‑participant incentive based on a successful dual‑fuel program in Utah and recommended the commission consider third‑party program administration (Energy Trust of Oregon, Efficiency Vermont models) to avoid implementation failure if the utility is unwilling to run BE programs. "If the goal is to get to a place where we have a clean heat plan that we can move forward with and implement and begin making progress on emissions reductions, it's probably not optimal to pull the money from that study and push it into a different community," Brandt said in discussion of timing; he nonetheless said parties would support expanding pilots if the commission chose that path.

Keith Hay of the Colorado Energy Office told the commission CEO federal rebates are obligated and near launch; CEO intends to coordinate outreach. But Hay and Haglund agreed that securing utility buy‑in is essential to a successful pilot, and neither could guarantee a large rollout without the company’s active cooperation.

Why it matters: The settlements filed in this proceeding include both a small Rocky Ford pilot and a $300,000 electrification study intended to inform future plans. Parties disagree about whether a study or an expanded pilot will better advance emissions reductions and whether utility reluctance can be overcome by commission orders or by contracting with third‑party implementers.

Ending: Commissioners asked parties to consider contingency plans, stakeholder processes and realistic timetables if the commission wishes to turn a study budget into additional pilot activity, and to specify roles for third‑party implementers and public outreach in follow‑up filings.