(6) In 1956, the Supreme Court held in Federal Power Commission v. Sierra Pacific Power Company, 350 U.S. 348 (1956), that the Commission must ensure protection of the public interest when exercising its authority to set just and reasonable rates. (7) The restructuring of the electricity industry in the Federal Power Act was intended to promote competition among electricity providers, resulting in lower electricity rates to consumers, higher quality services, and a more robust national economy. (8) Prior to restructuring, utility commissions were frequently asked to consider other societal benefits when setting rates, including access to energy, rate equity between different classes of customers, and environmental concerns. (9) According to the Environmental Protection Agency, in 2017, emissions from the power sector contributed the second highest share of greenhouse gas emissions by economic sector. (10) The benefits of competition will not be achieved if some competitors enjoy an advantage resulting from externalization of environmental costs, permitting them to charge prices for electricity that do not reflect the full economic and environmental cost of production. (11) Despite the Environmental Protection Agency’s finding of endangerment, emissions of greenhouse gases into the air, which endanger public health and threaten the quality of the air, land, and water of the United States, are externalities that are not frequently or uniformly reflected in the price charged for products such as electricity across the United States. (12) The disparity in regulatory treatment between electric generating units with above-average greenhouse gas emissions and those with little to no greenhouse gas emissions provides a significant competitive advantage for high greenhouse gas emitting energy generating units over their competitors. (13) States and State commissions should be encouraged to incorporate the cost of greenhouse gas emissions into wholesale rates for electricity. 4. Certain rates unjust, unreasonable, unduly