Despite the fact that Colstrip owners in neighboring states are seeking to unplug from the plant as early as 2025, NorthWestern leadership continues to assume the plant will remain open until 2042. We cannot afford to wait 20 more years to start decarbonizing our energy system. Without retirements and with the additional gas capacity it's planning, North-Western intends to increase its emissions in the next decade, not decrease them. 4. Finally, NorthWestern Energy failed to include a single benchmark between now and 2050 to measure progress toward its net-zero goal in regards to electricity generation. In contrast, when the Western utility Xcel Energy released its net-zero plan in 2018, it set clear benchmarks for measuring progress, such as committing to reduce its carbon emissions to 80% of 2005 levels by 2030. If NorthWestern leadership is serious about decreasing emissions, the utility should commit to a steady emissions drawdown schedule and not wait until 2050 to determine whether it can meet its goal.