Take action: Keep us on the path to 100% clean

In 2019, the state legislature took historic action and passed the Clean Energy Transformation Act. This breakthrough climate law mandates coal-free electricity by 2026, 100% greenhouse gas-neutral electricity by 2030, and 100% greenhouse gas-free electricity by 2045, for all Washingtonians, and achieved in a way that advances equity and creates good jobs here.

Since then, WEC and our partners have been working with the Department of Commerce to write the rules for consumer-owned utilities to follow. They need to hear from you to make sure the rules drive climate progress in an equitable way. Submit your comment today!

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Subject:

Clean Energy Transformation Comments

Dear Department of Commerce,

Thank you for all the work the Department of Commerce has been doing to bring to fruition the Clean Energy Transformation Act.

I appreciate that the proposed rules set out on how consumer-owned utilities must plan, take action, and be held accountable to the 100% clean law, establishing integrated standards and setting up clear processes and requirements for performance reporting, compliance reporting and Clean Energy Implementation Planning.

Throughout the proposed rules, there is key strategic direction for utilities to ensure all customers are benefitting from the clean energy transformation through the equitable distribution of benefits and burdens, reduction of costs and risk, and energy security and resiliency. The proposed rules also provide key guidance to utilities around how to engage with the public in achieving clean energy transformation.

The 100% clean law also requires utilities to incorporate the social cost of greenhouse gas emissions into clean energy action planning and integrated resource planning. I suggest striking WAC 194-40-110(3), which states utilities “may assume that the social cost of greenhouse gas emissions cost adder does not affect short-term operations or dispatch decisions after energy resources are acquired and placed into service.” There is no reason to circumscribe how utilities could further apply insights gained from applying the social cost of greenhouse gases in planning to decision-making, and I am concerned this unnecessary limitation could compromise my utility’s adaptive management towards clean energy outcomes. This section is essential to get right so that utilities are using accurate cost assumptions in the 100% clean transformation.

I also suggest one clarifying edit at proposed WAC 194-40-200(3)(a)(ii) that simply carries over important language in proposed WAC 194-40-330:  if a consumer-owned utility revises its energy efficiency target, it must be sufficient to ensure pursuit of all cost-effective, reliable and feasible conservation and efficiency resources, and demand response. By making this update to the language, the rules will reinforce important statutory direction to maximize existing resources and investments.

Achieving this foundational law is crucial to meeting our new statewide greenhouse gas emissions limits in an equitable way that creates good jobs for generations to come. I urge you to keep the final rules strong, so that the 100% clean law is implemented in a way that is equitable and results in real climate action.

I support Washington’s clean energy transformation.  Thank you for your efforts to set our state on the path to an equitable future.

Sincerely, Your Name

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