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Mayor Durkan celebrates passage of Transportation Electrification Plan to guide Seattle City Light’s investments in an electrified transportation system

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Seattle City Light’s Transportation Electrification Strategic Investment Plan will guide equitable investments to electrify all forms of transportation

Mayor Jenny Durkan today applauded City Council’s passage of Seattle City Light’s Transportation Electrification Strategic Investment Plan, an important step in committing resources and making investments to modernize our electric grid and enable a once-in-a-century transformation of the Seattle area’s transportation ecosystem.

“We envision a future Seattle where the movement of people, goods and services in and around the city is electrified,” said Mayor Durkan. “This is an essential piece of Climate Action Plan, Drive Clean Seattle Initiative and the Green New Deal. With this plan, Seattle will lead the way to a healthy future that is carbon-neutral, equitable and modern, while supporting customer choice and fostering new economic and workforce opportunities.”

In 2019, the Washington State Legislature passed House Bill 1512, granting public utilities the authority, already established for investor-owned utilities, to offer incentives and services to their customers to electrify transportation. Development and adoption of the Transportation Electrification Strategic Investment Plan, required by the law, ensures City Light can capitalize on that new authority to use these future offerings,  our prior learnings and stakeholder engagement to ensure the benefits of transportation electrification are accelerated and maximized for all the communities we serve.

The plan sets the priorities for future programs and services and describes how the utility will bolster and modernize our electric grid to enable public transit charging, support freight and commercial fleets and provide flexibility for personal mobility. City Light centered this plan on three key values:

  • Equity – to ensure benefits are focused to support and uplift underserved communities.
  • Environment – to improve air quality and public health.
  • The grid – operating the electricity delivery system as a community asset to deliver public good.

It reflects City Light’s engagements with the cities in its service area, with communities it serves, and with partner agencies to further its modernization- and customer-focused missions, including ensuring that investment in transportation infrastructure results in equitable outcomes.

“Seattle must continue the hard work to address climate change, and owning Seattle City Light enables us to expand opportunities to use clean hydroelectric power to decarbonize our economy, including throughout our transportation systems,” said Councilmember Alex Pedersen, chair of the Council’s Transportation and Utilities Committee. “Adopting this thoughtful Electrification Strategic Investment Plan also builds upon the collaboration between Seattle’s executive and legislative branches of government, including the Green New Deal resolution and the new ‘Climate Note’ that requires us to consider all new legislation through the lens of climate change.”

A quickly growing electric vehicle (EV) market offers an opportunity for City Light to play an important role in reducing the climate and environmental impacts of our transportation sector, the region’s largest source of hazardous air pollutants. However, while personal vehicles – including cars, bikes and e-scooters – make up one part of the EV market, the largest benefits of transportation electrification are expected to accrue from modes that move large numbers of people – electrified transit buses and ferries – as well reduced emissions from vehicles that drive a large amount of miles, including commercial fleets, medium- and heavy-duty trucks, and other high-mileage vehicle drivers.

City Light’s planned strategic investments fall in two categories: program offerings, including customer-facing incentives, services, education and promotions; and electrification enablement, including the development of future-focused infrastructure needed to support transportation electrification.

“At Seattle City Light, we are redefining electricity services to meet the evolving demands of our customers and our rapidly growing metropolitan area,” said Debra Smith, City Light General Manager and CEO. “City Light envisions a utility of the future that is responsive to the wants and needs of community members most impacted by environmental inequities, operates a modernized grid that enables real-time smart technology interaction and provides economic opportunities through infrastructure investments and upgrades. A modernized electric grid will accelerate electrification of transportation and other sectors, allow for resource optimization and prepare the region to withstand growing climate impacts.”

City Light has been working on transportation electrification over the past five years, conducting in-depth transportation electrification analyses as well as piloting public and residential EV charging, partnering with regional public transit agencies, and launching time-of-day electricity rates to better understand potential impacts of this growing market. Based on these analyses, City Light anticipates both financial cost and benefit from the transition to transportation electrification. As more EVs charge within the service area, the utility sells more electric power. The retail revenue from the new sales are expected to be greater than the costs required to procure and deliver the additional electricity, eventually stabilizing rates and providing overall benefit to customers.

Transportation electrification also offers significant opportunities to address the environmental inequities that exist in our region. Neighborhoods where marginalized populations are a relatively large share of residents are more likely to be located near the city’s major transportation routes, especially the city’s high-volume freight routes. City Light’s Transportation Electrification Strategic Investment Plan is a component of the City’s work to address these inequities and City Light will focus on the wants and needs of environmental justice communities, which includes Black, Indigenous, and people of color as well as immigrants, refugees, persons experiencing low incomes, English language learners, youth, and seniors, in advancing the transportation electrification plan.

In developing this plan, City Light engaged with more than 40 community leaders and stakeholder groups to align investment priorities with community needs, with a focus on environmental justice communities. This strategic plan defines the process for how City Light will collaborate with customers and communities to develop a portfolio of transportation electrification offerings, and develop metrics for success reflective of our customers. Following approval of the plan, City Light will do additional work with communities to co-create program offering designs.

City Light has closely collaborated with several other City departments – Office of Sustainability and Environment, Seattle Department of Construction and Inspections, Seattle Department of Transportation, Office of Planning and Community Development, Office of Economic Development, Department of Neighborhoods, Finance and Administrative Services – in development of this plan and a broader citywide transportation electrification strategy.

“City Light’s strategic investment plan is a critical component of the citywide transportation electrification strategy.  In order to achieve our ambitious climate goals, it is essential that the utility have authority to offer customer incentives and services for transportation electrification, as well as the authority to promote electric vehicle adoption and advertise the utility’s services,” said Jessica Finn Coven, Director, Office of Sustainability and Environment.

Visualizing Streamflow as Climate Changes

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As we continue to celebrate the 50th anniversary of the first Earth Day, we are highlighting City Light’s projects and initiatives that study and address the effects of climate change in our region. This is a guest post authored by Climate Change Research and Adaptation Advisor Ronda Strauch.

As the rain returns to the Pacific Northwest and waters our “victory gardens,” we are reminded of how precious water truly is. Seattle City Light is always mindful of this vital resource as it supplies nearly 90% of our customer’s power through hydroelectric generation. This generation is fueled by streams nourished with melting snowpack in the Cascades and Rocky mountain ranges. This year’s snowpack is at or just above average, providing one less worry in this time of heightened anxiety. But City Light knows this will not always be the case. Climate change is altering our snowpack and streamflows.
Thus, City Light is taking action to prepare for these changes by supporting research to better understand future streamflows. This research is being used to plan for operations and power management as the climate changes.

Skagit River flowing through the Diablo Dam

Over the past five years, City Light has worked with the University of Washington (UW) to model streamflows in the Skagit River watershed. This river provides a vital source of water for City Light’s Skagit Hydroelectric Project, which typically supplies about 20% of our customer’s power needs in the Seattle area. To co-produce usable science, City Light and the UW transformed the streamflow modeling into a new streamflow visualization in collaboration with Environmental Science Associates, Skagit Climate Science Consortium, Swinomish Indian Tribal Community and the Sauk-Suiattle Indian Tribe. This interactive tool is now available online at skagitclimatescience.org/projected-changes-in-streamflow/. 

Example visualization of monthly average streamflow for Ross Reservoir

As the climate warms and snowpack becomes more variable, agencies such as utilities want information on what to consider as they prepare for potential changes in streamflows. This easy-to-use tool provides data and graphs of modeled monthly and extreme (high and low) streamflow at 20 locations in the Skagit River watershed. It allows visualization of projected changes in streamflow between historical and future periods over the 21st century. Uncertainty in streamflows is shown through multiple global climate models and future scenarios of atmospheric greenhouse gas concentrations. The visualization and streamflow data can be used in City Light’s long-term planning, such as the Integrated Resource Plan and hydroelectric project relicensing, as well as in designs for long-lived infrastructure and resource projects that are adapted to future streamflows affected by changing climate. City Light is proactive in preparing for climate change by helping develop and using the best available science to adapt our operations to ensure sustainable power for our customers as the climate evolves.

Ronda Strauch joined Seattle City Light in July 2018 as a Climate Change Research and Adaptation Advisor in the Science Policy Unit of the Environment, Land and Licensing Business Unit. She recently obtained her PhD from the University of Washington in the Department of Civil and Environmental Engineering, specializing in landslide and hydrologic modeling. When time allows, Ronda enjoys gardening, hiking, kayaking, and mountain climbing.

Will Seattle’s Summer Be Smoky Again?

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This is a guest post authored by Climate Change Research and Adaptation Advisor Ronda Strauch as part of a quarterly new series called Climate Connections.

Last year, Seattle denizens experienced multiple days in a haze of smoke. Whirling winds pulled in smoke from wildfires burning outside of Puget Sound and even as far away as Siberia. And when there was no wind, smoke settled over the area like a blanket. Only the return of Seattle’s typical westerly winds allowed the smoke to clear. Will we be smoked out in Seattle again this summer? Many factors make it seem likely.

To begin with, we had a cold, dry winter. Spring kicked off with March precipitation at 37% of normal levels and days near 80°F, matching temperatures in Tucson at the time. The official start of the 2019 Washington wildfire season began in March, a very early onset. That month, 54 wildfires ignited in Washington and all but one were west of the Cascade Mountains, according to Washington Department of Natural Resources.

Smoke from wildfires blanketed the Seattle area in the summer of 2018.

This year’s weather so far has left us with a water deficit—and that means dry soils and dry forests. We are looking at a thirsty kickoff to the summer season. NOAA’s Climate Prediction Center is forecasting a warm, dry summer, consistent with a weak El Niño. The National Interagency Fire Center has issued an outlook for “above normal significant wildland fire potential” for Western Washington. Conditions are ripe for wildfire and smoke close to home, portending a possible repeat of a smoky Seattle summer.

Climate Change’s Connection to Smoke

While we can’t attribute a single smoke event to climate change, over the long-term, climate change can increase the odds of smoky conditions. As the climate continues to warm, the total area burned in Washington’s forests is estimated to increase fourfold by the 2040s. This is primarily because warming temperatures can lead to drier conditions and drier vegetation that easily ignites. These conditions will lengthen the fire season and thus, the duration of smoke production.

Declines in forest health linked to climate change can also increase the intensity of a fire, which in turn affects the chemistry, quantity and distribution of its accompanying smoke. There is uncertainty if smoke will impact Seattle, particularly coming from out of state.

Of course, there is a chance we may see no smoke this summer. Let’s hope for that.

How Smoke Affects City Light

Smoke can have numerous impacts on people and business, including City Light. Smoke leads to poor air quality, reduced visibility and damaged equipment.

Particles found in smoke make it difficult for City Light employees and contractors to breathe, particularly for those who live with asthma, chronic bronchitis or reduced lung functions. Reduced visibility due to smoke can also challenge inspections of City Light facilities, including transmission lines and dams, where clear visibility is required.

Also, here’s a little-known fact: heavy smoke can conduct electricity. Therefore, dense smoke near a transmission line can create a conductive path that can increase the potential for a “flashover.” Flashover or arc flash can occur with ionization of the air as voltage jumps across air gaps between powerlines or to the ground. Smoke is attracted to high voltages and can build fragile carbon bridges that conduct leakage currents.

Finally, smoke can settle on equipment and lead to reduced efficiencies or failure. A recent study of residential energy use during years with and without smoke in Seattle found that City Light’s load during summer was better predicted when considering air quality. This suggests that our customers might be buying air conditioners and purifiers when they can’t open their windows because of smoke.

City Light is Adapting

One positive effect of our recent smoky summers is that City Light now has some experience dealing with these smoke events. We have learned from them and can continue to implement adaptations to better cope with smoke. As a utility, there are actions we can take to reduce our vulnerability and prepare for the impacts of climate change.

Adaptation includes using personal protective equipment (PPE) per guidance from our Safety, Health, and Wellness Division to minimize employee exposure to smoke. We can increase flexibility in our inspections to accommodate smoke delays. The advanced education of emergency responders on needed precautions while working near electrical equipment during dense smoke provides greater capacity for handling smoky conditions.

Additional preparation includes retrofits or adjustments to equipment that might be sensitive to smoke exposure. Securing contracts from our suppliers prior to needing materials will also better prepare us for potential smoke conditions.

As the public adapts to smoke through air conditioners and purifiers, City Light prepares through our long-term planning for shifting energy demand. Proactive planning and flexibility can reduce our vulnerability and minimize risks from smoke… Kind of like having a “plan B” vacation spot this summer. (Maybe one that’s less smoky.)

Resources for More Information

Washington Department of Ecology – Smoke & Fire Management and
Washington Air Quality Advisory

Washington State Department of Health – Smoke from Fires Q&A and Toolkit (many languages)

Washington Smoke Information –blogspot

Ronda Strauch joined Seattle City Light in July 2018 as a Climate Change Research and Adaptation Advisor in the Science Policy Unit of the Environment, Land and Licensing Business Unit. She recently obtained her PhD from the University of Washington in the Department of Civil and Environmental Engineering, specializing in landslide and hydrologic modeling. When time allows, Ronda enjoys gardening, hiking, kayaking, and mountain climbing.

Seattle City Light Announces Recipients of 2019 Wildlife Research Program Grants

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Since 1999, Seattle City Light’s Wildlife Research Grants Program (WRP) has funded more than 50 projects and distributed over $2 million in research grants to non-profit conservation organizations, universities and resource management agencies to study the wildlife that inhabits the North Cascades ecoregion.

The WRP is an element of City Light’s federal license for operating the Skagit River Hydroelectric Project in the North Cascades region, which requires the utility to collaborate with resource and land management agencies to select and fund original wildlife research projects.

Last week, WRP announced the recipients of four new research grants aimed at gaining a better understanding of wildlife and ecosystems in the North Cascades. The new grant recipients include the following:

Conservation Northwest – Testing a cloud-based computer application for agencies and organizations in U.S. and Canada to assess changes in habitat conditions for wolverines, which are susceptible to climate change.

Woodland Park Zoo and Washington State University – Developing a monitoring framework for wolverines, Canada lynx, and other carnivores in the North Cascades to aid in developing effective management strategies in the face of climate change.

Western Washington University – Assessment of survival and reproduction of mountain goats that were translocated into the North Cascades to bolster depleted populations.

Eastern Washington University – Evaluation of the role of beavers in reducing wildfire severity in riparian communities of the Methow River watershed where increased fire activity is expected as the climate changes.

The American Pika, a small creature that lives in the North Cascades and is a relative the to the rabbit.
WRP recently funded research on the American Pika and its sensitivity to
the effects of climate change. (Photo credit: J.D. Anderson)

These new grants will join the list of previously funded projects that have helped provide data crucial for agencies to make informed management decisions for rare or economically and tribally important species.

Several of the research projects funded through WRP have led to published articles in peer-reviewed professional scientific journals and conference presentations. While the grants may not always fully fund a project idea, they still support the research of lasting environmental impacts. Most notably: the effects of climate change on the region.

“We take great pride that these grants help lay the groundwork for vital research to take shape while also supporting undergraduate or graduate college students pursuing environmental degrees who will be our next generation of environmental stewards,” explains Ron Tressler, Wildlife Biologist at City Light. “The flora and fauna of the North Cascades ecosystem are a barometer for how the species will thrive during the next century with the impending effects of climate change, so these research projects are critical.”

The WRP is one of many programs City Light champions that studies and rehabilitates the region near its facilities across the state. For decades, City Light has led the way in acquiring lands along the Skagit River Watershed to protect vital salmon spawning habitats. Last year, City Light provided funding to research and forecast the recession patterns of glaciers in the North Cascades.

Recently, City Light, in partnership with the Mountains to Sound Greenway, Seattle Public Utilities and the Northwest Natural Resource Group, received a $140,000 grant for an innovative pilot project that will replant portions of logged land now owned by City Light to grow a new forest that could be more resilient to climate change. This pilot project will inform future climate-adapted restoration practices for lands owned by City Light, Seattle Public Utilities and other owners in the region. The long-term goal of the reforestation effort is to establish a diverse forest that will be adapted to the climate of the mid to late 21st century. For City Light’s Chief Environmental Officer Lynn Best, these projects are vital to better understand how the ecological landscape in the Pacific Northwest will gravely affect both the utility’s customers and its energy production.

“Climate change is the greatest environmental challenge we face today. I am proud that City Light is doing its part to address climate change and protect the Earth.”

To learn more about City Light’s Wildlife Research Project and for a list of previous grant-funded projects, visit

seattle.gov/light/environment/wildlifegrant/.

Seattle City (spot)Light: Ronda Strauch

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Ronda Strauch joined City Light in July 2018 as part of the Environment, Land and Licensing business unit. As a climate scientist, she works on climate change research and adaption. “My goal is to better understand climate change, how it affects City Light’s business, and what strategic things can we do to reduce impacts and prepare for it,” Ronda explained.

Originally from San Diego, Ronda received a bachelor’s degree in environmental management from UC Davis. She also earned her master’s degree in forest ecology and a Ph.D. in civil environmental engineering from the University of Washington. “In grad school, I looked at climate change impacts on high elevation forests,” Ronda shared. “I focused on what happens after a wildfire because, when you think of it, you’re kind of starting with a clean slate. It was a hot topic at the time. The IPCC had just formed and I knew we needed to learn more about how change could impact our forests.” She continued studying climate change focusing on landslides in the North Cascades during her doctorate.

Learn more about Ronda and her adventurous hobbies (including building her own sea kayak) in this week’s (spot)Light. 

Ronda with the 17 ft kayak that she built with her husband

“I love getting outdoors to kayak.  I’ll kayak on the Snoqualmie River, but last Labor Day my husband and I went to Broken Group Islands on the outskirts of Vancouver Island. I have a smaller kayak for rivers and lakes and the 17-foot sea kayak that we built! It took about five months to make. It’s a kit from Pygmy Boats out of Port Townsend and it’s made from an Okoume plywood that’s thin and resistant to fungal attack. I named her Cuttlefish.”

“I’m also a mountain climber. I’ve done Rainier twice, Mount Adams several times, and Mount Olympus once. Mount Baker and Mount Hood are on my list. I tried Glacier Peak, but we got foiled by whiteout conditions. I’d like to try that again. Right now, I’m training for an ultra-marathon trail run which is crazy, but it keeps me active! It’ll be at Bryce Canyon in May.”

“Gardening is another favorite hobby of mine. I have this goal of getting every tree species in Washington to grow in my yard. I have most, actually! I live on the outskirts of Woodinville. It’s a nice forested area with a little over an acre. So, we tend to get lots of animals. Last year we had two black bears. We’ve also had bobcats – we live with wildlife!”

“In my career, I’ve also looked at climate change and how it affects transportation. I did that at King County Department of Transportation and as part of my graduate work. I focused on climate change wherever I went, in whatever job I’ve held. I get to carry on that work at City Light. My work entails keeping up on the science, advancing research that supports our data needs, and communicating that information such that climate change considerations are integrated into our everyday decisions.  I really enjoy meeting and interacting with City Light employees and appreciate how they embrace the duty of keeping the lights on – even when the snow comes or doesn’t come, wind blows, fire strikes, and the heat is on!”

Seattle City Light Funds Glacier Recession Research

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Glacier-fed Diablo Lake

Seattle City Light recently funded a study which researched and forecasted the recession patterns of glaciers in our region. The research article, titled “Glacier Recession and the Response of Summer Streamflow in the Pacific Northwest United States, 1960-2099,” explores the recent recession patterns of these glaciers whose melt and water flow will impact hydroelectric power generation, agricultural water supply, and the ecological health of the watersheds downstream. Along with funding a portion of the research, City Light advised on the scope of the project to provide insight into when streamflows were most important for power generation, recreation, and fish protection.

Through hydrological modeling, the study found that primarily temperature-induced shrinking of glaciers will increase throughout this century. The model showed that the glaciers in the North Cascades could nearly disappear by the year 2100 if greenhouse gas emissions are not curbed.

For Ronda Strauch, City Light’s climate change adaptation researcher and adviser, this research is vital to not only the health of the glaciers but shapes how utilities that generate power with hydroelectricity like City Light will continue their operations in the future.

“We look to research like this for future predictions of inflows into the reservoirs and how much hydroelectric power our utility will be able to produce,” explains Strauch. “We wanted to make sure that glacier activity was added to this hydrologic model used in this research to get a better picture of streamflow into our reservoirs. It could also guide our operational changes in the future, such as controlling water levels to reserve for the summer months. This will help us decipher the long-term consequences of these melting glaciers.”

One of the consequences is the potential lowering water levels along the Skagit River during late summer. In keeping with City Light’s commitment to environmental stewardship, such as supporting the salmon recovery plan that protects and restores the chinook, bull trout and other species listed under the Endangered Species Act in the Skagit Watershed, the utility is watching closely this kind of research to better understand the changes in climate the region will incur for decades to come.

“The future still has a lot of uncertainty to it,” said Strauch. “While it is not completely set, there are some aspects of the future that is clear. It’s our job as a utility to do what we can to ensure that future generations are prepared for the impacts. Our decisions help prepare for what the future will look like.”

Click here to read the abstract of the research article.

Innovative Pilot Project Seeks to Grow a Forest More Resilient to Climate Change

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An innovative pilot project will replant portions of logged land now owned by Seattle City Light to grow a new forest that could be more resilient to climate change.

Mountains to Sound Greenway Trust and its partners – City Light, Seattle Public Utilities and the Northwest Natural Resource Group — received a $140,000 grant to reforest portions of the Stossel Creek area in the Tolt watershed northeast of Carnation. The grant money is being provided by the Wildlife Conservation Society through its Climate Adaptation Fund, a program supported and established by a grant from the Doris Duke Charitable Foundation.

“Stossel Creek presents a unique opportunity to test innovative, new habitat restoration methods designed to increase resiliency to climate change for Western Washington forests,” said Jon Hoekstra, executive director of the Greenway Trust.

A volunteer from Mountains to Sound Greenway Trust clearing invasive brush.

Trees on the 154-acre site were harvested by a private land company in 2012. Since then, the site has experienced new plant growth, but with few trees. Invasive species have taken hold in some areas. City Light purchased the land in 2015 as part of its Endangered Species Act Early Action Plan to conserve and enhance habitat for steelhead.

Crews and volunteers will reforest the site with native conifer species, such as Douglas Fir and Western redcedar. Instead of using only subvarieties that are native to Washington, this project also will include trees sourced from southwestern Oregon that are better adapted to warmer temperatures and drier summers.

“The climate of the Stossel Creek area is projected to be similar to southwest Oregon’s by the end of the 21st century,” explains Crystal Raymond, a climate adaptation specialist who helped secure the grant while she worked for City Light. “Therefore, the trees adapted to southwestern Oregon are expected to be better suited to the Stossel Creek site as the climate warms. By increasing the tree genetic and species diversity, the site’s resiliency to climate change will increase over time.”

Work to control invasive plant species and site preparation at Stossel Creek will begin this spring and planting new trees will begin in the fall. After planting, the team will have several opportunities to monitor success and share lessons learned from the project.

This pilot project will inform future climate-adapted restoration practices for lands owned by City Light, Seattle Public Utilities and other owners in the region. The long-term goal of the reforestation effort is to establish a diverse forest that will be adapted to the climate of the mid to late 21st century.

Recently, KING 5 visited the site to cover the project. Click here to watch the story featuring City Light’s Denise Krownbell.

Statement Concerning Filing of Petition for Review Concerning EPA’s Mid-Term Evaluation of Vehicle Standards

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On Tuesday, Seattle City Light and other electric utilities filed a petition for review in the Washington, D.C., Circuit Court of Appeals, challenging the Environmental Protection Agency’s (EPA) determination that EPA’s existing greenhouse gas emission standards for cars and trucks are not appropriate and must be revised.

Electrification of the transportation sector is a key strategy to help reduce greenhouse gas emissions and address climate change.

“City Light is making significant investments in electric vehicle infrastructure and charging facilities to help advance our customers’ adoption of clean vehicles and achieve emission reductions,” Interim General Manager and CEO Jim Baggs said. “We have already installed two fast charging stations and are working to install 18 more. We also are investing heavily in charging facilities for electric vehicles in the city’s fleet. These investments are part of our overall commitment to modernize the electric grid and continue delivering clean, reliable power to our customers.”

The determination we have challenged is an abrupt reversal of the conclusion EPA reached just 15 months earlier, when it found that the standards were appropriate based on a comprehensive technical assessment conducted in coordination with the Department of Transportation and California.

Late last month, EPA’s own Science Advisory Board voted to review the adequacy of the science cited by EPA in support of its reversal, after a board work group found that EPA had relied extensively on information that had not been adequately validated or peer reviewed.

City Light remains committed to moving forward in support of electric vehicles and opposes EPA’s reversal.  We will continue to support strong greenhouse gas emission standards that will accelerate the adoption of electric vehicles across the country and help mitigate climate change.

City Light’s Comments on EPA Regulatory Reform

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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.

Seattle City (spot)Light: Crystal Raymond

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It’s no secret that Climate Change Strategic Advisor Crystal Raymond has a great love of the outdoors. If her places of residence don’t give it away (she’s lived in Vermont and Utah along with Washington), you might guess it by her educational background, which includes a PhD and Master of Science in Ecosystem Ecology from the University of Washington and a Bachelor’s Degree in Natural Resource Management from the University of California, Berkeley.

Her expertise has been recognized by the NW Energy Coalition with the 4 under Forty award—which honors clean energy leaders who model the passion and knowledge needed to achieve a clean and affordable energy future. With Earth Day celebrated across the globe this past weekend, we couldn’t think of a more fitting person to feature in this week’s (spot)Light.

Crystal ice climbing in Ouray, Colorado

“I did a lot of camping in my childhood. My dad was an old-school recreation type who liked to hunt and fish. I grew up in rural Vermont in a town with about 750 people. We always had people on our land hunting for deer and fishing. That helped to develop my love for the outdoors, the natural environment, and a deep appreciation for natural resources.”

“I live in Mount Baker. It has good access to parks and Lake Washington. I do A LOT of outdoor recreational activities. Back country skiing is my favorite, but I also enjoy mountaineering, ice climbing, rock climbing. I go all over the Cascades—North Cascades, Snoqualmie Pass, Eastern Washington. I have a nine-month baby who my husband and I are now just taking out hiking. We’ve already taken him back country skiing. I’m excited to share my love of the outdoors with him and introduce him to all these fun sports.”

“I always wanted to do environmental science of some sort. I thought about doing it more on the political advocacy side, but when I got to college, I was more interested in the science and was drawn to the analysis of it all. When I did advocacy work, I always wanted to know more about the science behind the policies, so I moved from politics and law to a more science-based approach.”

“My job is to make sure the utility is prepared for the impacts of climate change—to understand how our operations and infrastructure might be affected. That includes warmer temperatures, but also more frequent natural hazards like wildfires and landslides as well as changes in snow pack and stream flow for our dams. It’s understanding how all the different parts of the utility can be affected and helping to come up with ways that we can prepare for that.”

“One of the ways we’re doing this is by supporting climate research and developing an adaption plan. I am forming a steering committee to help implement the plan. I’m building a team to get more input and engagement and make sure that the adaption plan is doing its job of helping other people in the utility get prepared for climate change.”

“My PhD advisor at the University of Washington gave me a strong sense of the importance of science in guiding what we do in that it can be neutral and unbiased—that having good science as a basis for what we do is important for the decisions we make.”

Thank you, Crystal, for the important work you do for our environment and for making such an impact at City Light these past four years!