CCLP provides comments on the PUC’s proposed new rules

CCLP provides comments on the PUC's proposed new rules

by Milena Tayah| Feb 19, 2026

Equity work, Programs, Public Utilities, Research and Policy Analysis, Testimony

On Tuesday, February 17, 2026, Milena Tayah, Policy Advocate at CCLP, provided comments on the Public Utilities Commission's (PUC) proposed new rules[1] for how it evaluates the effects of its planning, rates and programs on different communities.[2]

Good morning your honor,

My name is Milena Tayah, and I am a Policy Advocate at Colorado Center on Law and Policy, a nonpartisan, nonprofit organization advancing the rights of every Coloradan. We focus on food, health, housing, and income through litigation, legislation, research and policy analysis to ensure that all Coloradans have what they need to succeed.

I want to start by thanking the commission for the opportunity to provide open comment today. We have been reviewing the rules and regulations[3] for today and have a few comments to help determine next steps.

Rule 1008 - Utility Language Accessibility:

We are happy to see the inclusion of utility language accessibility. Our only concern involves allowing utilities to put the cost back upon the consumers for language accessibility. We believe that this cost should be absorbed by the provider and not the community. We recommend removing any terms that allow for the utility entity to recoup any costs from consumers to provide language accessibility services.

Rule 1604 - Equity Impact Proceedings:

Utilities have expressed concerns and difficulties on stakeholding disproportionate communities on applications and programs. While it can be seen as difficult, it should be seen as a benefit. Stakeholding has the goal to ensure that all voices, perspectives, and experts are at the table based on the issue at hand. We at CCLP have seen first-hand how failing to stakehold important policies or programs has caused additional problems.

For example, the Colorado Department of Health Care Policy & Financing (HCPF) attempted to implement the Nurse Assessor and Skilled Care Acuity Assessment, an assessment that would help determine the appropriate level of care and associated hours for pediatric members[4] seeking skilled care services. The program was implemented with minimal stakeholding. After implementation, case managers, county workers and community advocates came to HCPF and shared their concerns with how the assessment was impacting people's ability to access medically necessary services.

Not talking to the people who are impacted by the assessment does not make sense. Money spent on programs that have no buy-in or stakeholding is a poor investment and could even risk litigation. More broadly this affects people's real lives, so why not include them in the discussion?

Colorado has many advocacy organizations that investor-owned utilities can reach out to about stakeholding processes:

• Energy Outreach Colorado
• Southwest Energy Efficiency Project
• Colorado Cross-Disability Coalition
• 350 Colorado
• 9to5 Colorado
• Conservation Colorado
• Healthy Air and Water Colorado
• Together Colorado
• Western Resource Advocates
• And, of course, Colorado Center on Law and Policy

Stakeholding and meeting with impacted communities is an important part of implementing any program. To ensure it works well and is successful, their perspectives and experiences are important prior to implementation. The investment in stakeholding is worth the success of any program or application created by investor-owned utilities. It is incredibly important for any investor-owned utilities to document any engagement in reports to ensure all people and organizations have been appropriately outreached and provided the opportunity to engage. We highly recommend keeping this section in the rules.

Thank you for your time. I am happy to answer any questions you may have.

**********

[1] Equity Proceedings No. 25R-0468ALL, https://puc.colorado.gov/equity-initiatives/equity-framework

[2] https://puc.colorado.gov/press-release/colorado-public-utilities-commission-announces-february-public-comment-information

[3] https://www.dora.state.co.us/pls/efi/efi_p2_v2_demo.show_document?p_dms_document_id=1052358&p_session_id=

[4] https://docs.google.com/document/d/1nNYeffbTnWZZomxBKRRlOpjbqI1GTr1tuE1fH3eQbtA/edit?tab=t.0#heading=h.3drtpflytw1n

Recent articles

CCLP testifies against Direct Primary Care cost-shift onto Medicaid patients

Feb 18, 2026

Lessons from the Public Health Emergency Unwind in Colorado

Feb 17, 2026

CCLP testifies in support of the Worker Protection Act

Feb 11, 2026

CCLP testifies at the PUC Commissioner Panel

Feb 4, 2026