Reason for submission: Reply comments supporting the adoption of a Social Cost Test when evaluating distributed energy resources
This filing represents the Clean Coalition’s reply comments regarding the adoption of a Social Cost Test for the consistent evaluation of distributed energy resources, including greenhouse gas value and use of a 3% “social discount” rate. These reply comments responded to utility opening comments opposing the use of a social discount rate and advocating for market discount rates to apply to future costs and benefits. The Clean Coalition offered an economic and philosophical rebuttal in our abbreviated comments. Costs associated with energy choices directly impact society at large, and decisions regarding energy options must reflect these costs in order to avoid inappropriate cross subsidies or transfers of cost responsibility between stakeholders.