EPRI Public Comments in Response to the Minnesota Public Utilities Commission Request for Comment on the Regulatory Cost of Greenhouse Gas Emissions for Gas Integrated Resource Plans

On August 25, 2025, the Minnesota Public Utilities Commission (‘The Commission’) published a notice of public comment soliciting public feedback on its proposed use of regulatory costs of greenhouse gas (GHG) emissions in utility resource planning (Docket Number E999/CI-07-1199; G008,G002,G011/CI-23-117; G999/CI-21-565). Under the proposal, state natural gas utilities would be required to assign costs to the GHG emissions associated with their plans and operations. This is a significant development with precedent setting potential for other states, as well as potential federal policy. To EPRI’s knowledge, this is the first time GHG pricing has been suggested in gas utility resource planning. As such, there are new technical issues that are important for The Commission, utilities, and the public to consider.

On November 21, 2025, EPRI submitted the public comments in this document to The Commission and the related public docket. EPRI has been studying topics directly related to the issues at hand for nearly twenty years and has over fifty years of research experience in the relevant underlying science. EPRI’s comments identify the following important technical considerations if applying the costs of GHGs in natural gas utility resource planning:

1. Communicating the distinction between the cost of GHGs and the social cost of GHGs
2. Designing a study to estimate ranges of costs of GHG values for Minnesota to capture local emissions transition opportunities
3. Accounting for natural gas emissions abatement policies to avoid additional costs in reducing GHG emissions
4. Clarification on whether non-CO2 GHGs are being considered and subsequent public input
5. Technology portfolios when applying regulatory costs in gas planning
6. Clarification on the types of emissions being considered and subsequent public input
7. Emissions leakage when applying regulatory costs in gas planning
8. Evaluation of natural gas price implications

EPRI’s public comments include a detailed discussion for each topic, as well as references to supporting research and resources.

EPRI’s public comments primarily draw on its extensive research related to the estimation and use of the social costs of greenhouse gases (EPRI’s Social Cost of Greenhouse Gases Scientific Initiative) and related to the development of corporate climate targets and strategies (EPRI’s SMARTargets Initiative).