Client: Sierra Club
March and July 2018
On behalf of Sierra Club, Senior Researcher Tyler Comings provided an Applied Economics Clinic testimony on March 2018 in Docket No. 17A-0797E. Mr. Comings provides an expert opinion on the Public Service Company of Colorado's application to accelerate the depreciation of Comanche Units 1 and 2 and the associated rate plan to offset this expense. He concludes that the accelerated depreciation of Comanche Units 1 and 2 and offsetting mechanism is in the public interest; the success of the Renewable Energy Standard Adjustment has afforded the Company the opportunity to offset the accelerated depreciation; and the Company's proposal is reasonable but should consider other options for future stranded assets. In his July 2018 surrebuttal testimony, Mr. Comings responds to criticisms raised in cross-answer testimony, concluding that the retirement of Comanche coal-fired Units 1 and 2 saves money and reduces risks to ratepayers.