Rulemaking - Informal Comment Period on Clean Energy Transformation Rule

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Comment From: WPUDA

5/26/20 @ 5:05 AM

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Comment From: BPA

5/26/20 @ 5:03 AM

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Comment From: WPUDA

5/26/20 @ 4:58 AM

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Comment From: Douglas PUD, Klickitat PUD, Re... (Dave Warren)

5/25/20 @ 3:47 PM

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Comment From: Tacoma Power (Lisa Rennie)

5/25/20 @ 9:20 AM

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Comment From: NW Energy Coalition (Joni Bosh)

5/25/20 @ 8:52 AM

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Comment From: Puget Sound Energy (Kara Durbin)

5/25/20 @ 6:33 AM

Please see attached.

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Comment From: Snohomish PUD (Clark McIsaac)

5/22/20 @ 8:56 AM

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Comment From: Climate Solutions (Vlad Gutman-Britten)

5/22/20 @ 8:28 AM

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Comment From: Cowlitz PUD (Steve Taylor)

5/22/20 @ 5:28 AM

Please find the attached comments related to the Clean Energy Transformation Rule from Cowlitz Public Utility District No. 1.

Steve Taylor

Director of Regulatory & Regional Affairs

Cowlitz PUD

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Comment From: Front and Centered (Deric Gruen)

4/20/20 @ 7:38 AM

Please see attached letter.

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Comment From: PacifiCorp (Jacob Goodspeed)

4/14/20 @ 5:53 AM

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Comment From: Seattle City Light (Meg Andres)

3/27/20 @ 4:33 AM

See attached Comments on Department of Ecology rulemaking on Clean Energy Transformation Act, Energy Transformation Projects

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Comment From: Puget Sound Energy (Kara Durbin)

3/24/20 @ 7:00 AM

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Comment From: The Washington Public Utility ... (Nicolas Garcia)

3/23/20 @ 9:34 AM

During the March 16 conference call on the Department's rulemaking for Energy Transition Projects, stakeholders were asked to provide comment by today, March 23. Attached please find comments by the Washington Public Utility Districts Association.

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Comment From: Alliance of Western Energy Con... (Tyler Pepple)

3/23/20 @ 2:26 AM

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Comment From: Dave Warren

2/24/20 @ 1:03 AM

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Comment From: Snohomish PUD (Clark McIsaac)

2/21/20 @ 10:06 AM

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Comment From: Washington Public Utility Dist... (Nicolas Garcia)

2/21/20 @ 9:56 AM

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Comment From: Ameresco (Jeremy Keller)

2/21/20 @ 4:56 AM

Please allow investing in and "banking" of greenhouse gas reductions from energy transformation projects prior to 2030. The intent of the legislation is clearly to drive emission reductions as soon as possible. Allowing banking will enable the mark...↓etplace for projects. In addition, the 15 year window between 2030 and 2045 where Energy Transformation Projects are applicable is too small for many large capital intensive projects where they might be financed typically instead over a 20 year period. Could you please clarify what an "investment" is defined to be? Would a long term contract for the green house gas reduction benefits from a project qualify as an investment? Or does the utility have to own the energy transformation project? Allowing non-utility ownership of the projects will facilitate independent project development and in some cases bring lower cost debt to the projects. Are utilities limited to implementing energy transformation projects inside their service territory? I.e. would PSE be able to invest in an ETP inside Cascade Natural Gas Service territory as long as it's inside the state of WA? We recommend that utilities are allowed to invest in ETP's outside their service territory to facilitate competition in the market place. Why is the submission of Protocols and projects limited to an electric utility or delegated agent? I don't see language for this restriction in the legislation. Allowing independent project developers to submit protocols and projects will again allow competition in the market place. Independent project developers have more experience and staff for developing energy projects than the utilities do. Allowing an independent developer to have a project evaluated by ecology without a utility co-sponsor will reduce development risk for the utility and allow a project to compete for multiple utility investments. The electric utilities are not always at the forefront of innovation or technology and tend to be more risk averse than independent project developers. Enabling independent project developers to work independently of the utilities will bring more solutions and projects to the state and drive down the cost of emission reductions from energy transformation projects.

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Comment From: WRECA (Kent Lopez)

2/21/20 @ 4:08 AM

Comments from the Washington Rural Electric Cooperative Association are attached.

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Comment From: Kara Durbin

2/21/20 @ 3:26 AM

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Comment From: Mason County PUD No. 1 (Kristin Masteller)

2/20/20 @ 1:52 AM

Thank you for the opportunity to provide comments on Ecology's draft rule approach to implementing standards for energy transformation projects under CETA. Mason County PUD No. 1's comments are attached. Kristin Masteller General Manager

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Comment From: PacifiCorp (Jacob Goodspeed)

2/11/20 @ 5:43 AM

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Comment From: Avista Corp (Jennifer Smith)

1/30/20 @ 3:07 AM

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Comment From: Snohomish County PUD (Clark McIsaac)

1/24/20 @ 12:35 PM

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Comment From: NW Energy Coalition (Joni Bosh)

1/24/20 @ 8:31 AM

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Comment From: Powerex Corp. (Connor Curson)

1/24/20 @ 7:32 AM

Please find attached Powerex Corp's comments with respect to the draft rule language for Chapter 173-444 WAC (emission content calculation for electricity), as presented at the January 14th, 2020 Department of Ecology Clean Energy Transformation Act ...↓