City Light’s Comments on EPA Regulatory Reform

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Reform Task Force to take stock of existing regulations and to determine regulations that could be changed, replaced or repealed altogether.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




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 or by phone at 206-386-4586.

Seattle City (spot)Light: Crystal Raymond

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

Her expertise has been recognized by the NW Energy Coalition, receiving 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 Ph.D 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!

Driving Energy Efficiency in City Buildings

OSE and the City’s capital departments are working to shrink our energy use and reduce GHG emissions in City-owned facilities. Seattle’s Resource Conservation Management work is a fairly technical body of work but absolutely critical in terms of leading the way to meeting the Citywide goal for an 82% reduction in building-related GHG emissions by 2050. The aim of our Resource Conservation Management program is to ensure that our city-owned buildings are operating as efficiently as possible, with a near-term target to achieve a 20% reduction in energy use by 2020. Long-term this puts us on the path to significantly reducing the GHG emissions of the City-owned building portfolio.

OSE works across City departments to identify and implement priority energy efficiency projects that complement the efforts of individual departments and that accelerate progress toward greater effiency and reduced GHG emissions. This focused efficiency work means that we are on track towards meeting our 20% energy reduction goal. From 2008 through 2015 we have achieved a nearly 9% reduction in energy use across the City’s buildings, which corresponds to a 15% reduction in our building related carbon emissions in that same timeframe.

In 2017-2018, we will be continuing dedicated efforts to improve efficiency and reduce emissions through the following actions:

  • Building tune-ups: operational improvements for our largest buildings. This work is part of our commitment to complete mandated Building Tune-Ups in advance of the compliance deadlines for the private market. Those over 200,000 square feet are under way and due to be completed by October 2017.
  • Parking Garage LED lighting upgrades
  • Building Stairwell LED lighting upgrades
  • Advanced Rooftop Unit Control upgrades, and
  • Comprehensive energy upgrades at 10 individual buildings.

For more information about Seattle’s resource conservation management work, please contact Wes Hoppler,


Training to help with Building Tune-Ups compliance


To help prepare energy service providers and on-site building operators for the new Seattle Building Tune-Ups mandate, the Seattle Office of Sustainability and the Environment has partnered with the Northwest Energy Efficiency Council (NEEC) to offer a Building Operator Certification Course Level II this spring.

The training BEGINS MARCH 2, 2017 and runs through June 8. The course is being offered at the discounted rate of $1,395.

 Building Operator Certification (BOC®) helps building engineers, maintenance supervisors and others in the skilled trades advance their skills in energy efficient operation of commercial buildings. BOC Level II is primarily for operators who have been certified at BOC Level I and who want more advanced training.  Complete course descriptions, and eligibility requirements, can be found at:

For the full course schedule, and to register, go to:

When registering, choose the option for “Additional Registrant (from same facility in same course series)”.   Classes will be held at the Smart Buildings Center located at 1200 12th Ave S., Seattle.

Want to learn more about Seattle Building Tune-Ups and eligibility to be a Qualified Tune-Up Specialist?  Go to:

OSE Releases Final Rule for Seattle Building Tune-Ups Requirement

OSE is pleased to issue OSE Director’s Rule 2016-01 which implements the Seattle Building Tune-Ups Ordinance adopted in March 2016. The Director’s Rule further explains the Tune-Ups requirement, and is the result of more than a year of collaboration with stakeholders to make this new policy clear and workable, with a focus on saving energy and flexibility for building owners. OSE thanks the Tune-Ups Technical Working Group and the dozens of other building owners, managers and energy management experts who helped shape these requirements.

The Rule clarifies the following: tune-up assessment components, corrective actions, and reporting; compliance extensions and exemptions; qualifications for tune-up specialists; and buildings and spaces subject to the requirement. This final version has several edits to address public comments received on the draft Rule, which was released in November. Highlights of the changes include:

  • The size threshold for tenant spaces with tenant-owned equipment that are not required to be tuned-up was increased from 2,500 to 5,000 square feet.
  • References to costs and payback periods were edited to make it clear that cost calculations are not required.
  • One Alternative Compliance Pathway – that of demonstrating at least $1/square foot of investment in energy conservation measures over three years – was removed from Section 9 “Exemptions” because of the challenges in identifying a form of evidence about actions taken, energy savings, and associated costs.
  • Additional certification and license options were included as eligible qualifications for a Tune Up Specialist in Section 12.

Seattle Building Tune-Ups phases in a periodic tune-up requirement for nonresidential buildings 50,000 square feet or larger (excluding parking), beginning in 2018 with buildings 200,000 SF or greater due first. Tune-ups aim to optimize energy and water performance by identifying no- or low-cost actions related to building operations and maintenance, focusing on actions that typically pay back within three years and generate 10-15% in energy savings on average. The legislation is a key piece of Seattle’s Climate Action Plan, our roadmap to achieving carbon-neutrality, by helping ensure buildings don’t use energy and water wastefully.

Support for Mid-Size Buildings to Comply with Seattle Building Tune-Ups

We’re recruiting up to 100 buildings (less than ~100,000 SF excluding parking) to jump-start their Tune-Up through the new Building Tune-Up Accelerator Program Benefits will include enhanced technical support and financial incentives to help comply with the Seattle Building Tune-Ups requirement. This funding will sunset after 2018, so contact us now if your building is due in 2020 or 2021. Trainings for service providers and in-house facility managers will also be offered on the Accelerator Program in mid-2017. Email or call 206-233-7184 for more information.

Questions about the Seattle Buildings Tune-Up Requirement?

Visit for more information, or contact Christie Baumel at (206) 233-7173, or