An important subset of the utility sector has been scarcely explored for its ability to reduce carbon dioxide emissions: consumer-owned electric utilities significantly contribute to U.S. greenhouse gas emissions, but are often excluded from energy efficiency and renewable energy policies. They sell a quarter of the nation's electricity, yet the carbon impact of these sales is not well understood, due to their small size, unique ownership models, and high percentage of purchased power for distribution. This paper situates consumer-owned utilities in the context of emerging U.S. climate policy, quantifying for the first time the state-by-state carbon impact of electricity sales by consumer-owned utilities. We estimate that total retail sales by consumer-owned utilities account for roughly 568 million metric tons of CO 2 annually, making this sector the 7th largest CO 2 emitter globally, and examine state-level carbon intensities of the sector in light of the current policy environment and the share of COU distribution in the states. Based on efficiency and fuel mix pathways under conceivable regulations, carbon scenarios for 2030 are developed.