City Light’s Comments on EPA Regulatory Reform

Read the full text of Seattle City Light's letter to the Environmental Protection Agency regarding potential changes to existing environmental regulations.

On February 24, 2017, President Donald Trump issued Executive Order 1377, “Enforcing the Regulatory Agenda.” The Executive Order sets forth a “policy of the United States to alleviate unnecessary regulatory burdens placed on the American people.” As part of the Executive Order, each federal agency was directed to create a Regulatory Reform Task Force to take stock of existing regulations and to determine regulations that could be changed, replaced or repealed altogether.

On April 11, 2017, the Environmental Protection Agency (EPA), under the direction of EPA Administrator Scott Pruitt, announced a solicitation of public comments on existing EPA regulations. Seattle City Light was happy to oblige. Among other things, City Light is concerned about the possible repeal, replacement or modification of EPA regulations and programs that relate to greenhouse gases and climate change.

The full text of Seattle City Light’s comments to the EPA follows below.

May 15, 2017

DOCKET ID NO. EPA-HQ-OAR-2017-0190

EPA DOCKET CENTER
U.S. ENVIRONMENTAL PROTECTION AGENCY
1200 PENNSYLVANIA AVENUE, N.W.
WASHINGTON, D.C. 20004

RE: SEATTLE CITY LIGHT COMMENTS ON EXISTING FEDERAL ENVIRONMENTAL REGULATIONS

Seattle City Light (SCL) appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency (EPA) efforts to reform existing EPA regulations that affect SCL. SCL is the municipally owned electric utility of the City of Seattle. We provide electricity to residential, commercial, and industrial customers in Seattle and several surrounding suburban cities and communities. Ninety percent of Seattle’s electricity is generated through hydroelectric operations, half of which is owned and operated by the utility. We are also the second largest preference customer of the Bonneville Power Administration. The focus of our comments is on EPA regulations and programs that relate to climate change and greenhouse gas (GHG) emissions.

SCL considers addressing climate change through regulating GHG emissions to be an urgent and vitally important issue. We have long been an industry leader in addressing GHG emissions. We made a commitment to and have achieved carbon neutrality in our power deliveries and operations every year since 2005. SCL has achieved these major changes while maintaining an affordable and reliable power system. This has been accomplished by divesting ownership in a coal plant and other fossil fuel projects, investing in new renewable power, and increasing our long-standing energy efficiency programs. For any remaining GHG emissions that we are responsible for and are unable to eliminate from operations and power deliveries, we mitigate for through the purchase of certified carbon offsets.

SCL operations and infrastructure are affected by climate change and will continue to be so in the future. Impacts of climate change on mountain snowpack and glaciers that supply much of the water for the Pacific Northwest’s hydroelectric projects poses a threat to Seattle and the region’s ability to continue to prosper in the coming years. Since the middle of the 20th century, snowpack in the mountains of Washington alone has declined by approximately 25%. Furthermore, snowmelt in our region is now occurring earlier than in past years, resulting in changes in both the timing and amount of hydropower generation available throughout the year. In a warming climate, extreme weather events like rain storms, floods, droughts, wildfires, and heat waves are also likely to become more frequent and intense further threatening our operations and the integrity of our infrastructure.

SCL has supported EPA’s work to address climate change and control GHG emissions by providing both written and oral comments on the Endangerment Findings, the Tailoring Rule and the Clean Power Plan. We continue to support the Clean Power Plan and believe that addressing climate change through the regulation of GHG emissions is critically important. Utilities across the nation have provided input to the EPA to develop the Clean Power Plan into a sound, actionable, and cost-effective rule that will effectively regulate GHG emissions. SCL believes the Clean Power Plan is a needed and implementable step that will help reduce emissions from the electric power sector.

One of the most potent GHGs, Sulphur Hexafluoride (SF6), contributes to global warming at a rate of 23,000 times that of carbon dioxide. SF6 gas is widely used in the energy delivery equipment of the nation’s electric utilities. Safe and effective management of this potent GHG in energy delivery equipment is critical to avoid accidental releases of SF6 gas to the atmosphere. In this regard, EPA’s Office of Atmospheric Programs (OAP) has provided an important national leadership role through the establishment and implementation of the SF6 Partnership Program. SCL has benefited and continues to benefit from the partnership’s biennial meetings which provide open forum for information exchange between EPA regulatory staff, the SF6 equipment manufacturers, the SF6 gas suppliers, SF6 service vendors, and other U.S. electric utilities with more years of experience implementing and managing the SF6 inventory and reporting programs. We value and support the continuation of the SF6 Partnership Program as a means of improving our ability to manage this important GHG.

In closing, we urge the EPA to continue to protect human health and the environment and to consider carefully the consequences of dismantling or modifying any established regulations and programs before taking any action to do so.

Thank you for the opportunity to provide these comments. If you have any questions, please do not hesitate to contact Lynn Best by e-mail at Lynn.Best@seattle.gov or by phone at 206-386-4586.