Rulemaking - Chapter 173-444 WAC, Clean Energy Transformation Rule

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Comment From: Dave Warren for Klick. PUD, Doug. PUD, and RHA

10/14/20 @ 12:51 PM
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Comment From: Connecticut Green Bank (Matt Macunas)

10/14/20 @ 9:10 AM
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Comment From: NW Energy Coalition (Joni Bosh)

10/14/20 @ 7:53 AM
Attached are comments and redlines for Rulemaking - Chapter 173-444 WAC
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Comment From: Climate Solutions (Vlad Gutman-Britten)

10/14/20 @ 7:39 AM
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Comment From: Avista Utilities (Kevin Booth)

10/14/20 @ 7:31 AM
See attached.
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Comment From: Puget Sound Energy (Brett Rendina)

10/14/20 @ 4:22 AM
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Comment From: Snohomish PUD (Clark McIsaac)

10/14/20 @ 4:06 AM
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Comment From: Solar Installers of Washington (Bill Will)

10/14/20 @ 3:22 AM
Oct. 14, 2020

Re: Draft CETA rules 173-444-080 - Procedures for Energy Transformation Projects
Comments from Solar Installers of Washington

Solar Installers of Washington, Inc. (SIW) is a statewide professional trade association established in October 2...↓

SIW is concerned that the provisions of this section that mandate third party verification in both the planning and implementation of ETP projects will produce cost burdens that will discourage electric utilities from using these projects to meet CETA targets.

Both in the design of the ETP criteria themselves in the draft rules as well as the current regulatory schema, other agencies (Commerce, UTC and the governing boards of public electric utilities) already have robust processes in place to ensure approved ETPs meet specific carbon reduction targets and overall CETA goals as well as comply with the existing regulatory framework. A duplicative layer of third party review may both slow implementation of ETPs by electric utilities and skew their internal cost calculations in a way that undermines their feasibility as a CETA compliance mechanism.

ETPs are designed to foster creative, innovative and cost-effective ways to reduce greenhouse gas emissions. An appropriate but less burdensome regulatory approach would help unleash that potential and meet the Legislative intent of "significant and swift" GHG emissions.

Respectfully submitted.

Dana Brandt, President
& Board of Directors
Solar Installers of Washington

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Comment From: WPUDA (Nicolas Garcia)

10/13/20 @ 3:22 AM
Please see the attached comments regarding Ecology's draft rules to implement criteria for the use of alternative Energy Transformation Projects.

Thank you,

Nicolas Garcia
Policy Director
The Washington Public Utility Districts Association
360-741-2683(O)...↓
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Comment From: Cowlitz Public Utility Distric... (Steve Taylor)

10/12/20 @ 3:13 AM
Attached please find comments from Cowlitz Public Utility District No. 1 regarding the CR-102 Proposed Clean Energy Transformation Rule.

Thank you for the opportunity to provide input.

Steve Taylor
Director of Regulatory and Regional Affairs
Cowlitz PUD
3...↓

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Comment From: NAVFAC Northwest (Matthew Hamilton)

10/05/20 @ 7:00 PM
Concern about the accounting of direct and indirect emissions. The output from one entity become an input to another entity, and this will lead to double counting of emissions. The indirect emission accounting may lead to litigation as in Chapter 173...↓
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Comment From: Angela Stenhouse

9/10/20 @ 8:05 AM
I think this is a worthy goal, and I would support it as long as hydro power is not excluded as a source of "clean energy" and it will not cause rates to increase over 15%.
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