Draft Sixth Power Plan Comment

Please accept the following brief comments from Republicans for Environmental Protection (www.rep.org) regarding the draft Sixth Northwest Power Plan. We commend the council for its impressive draft. A target of meeting all demand growth through 2030 with efficiency and renewables is a remarkable step forward for moving toward a more diverse energy economy that reduces long-term costs and risks, and ensures good stewardship of our natural heritage, while still supplying essential energy needs. Given that the Pacific Northwest already is saving some 200 average megawatts of energy per year through efficiency, the draft plan’s proposed efficiency target of 5,800 average megawatts by 2030 would raise the bar. It is, however, achievable, through a menu of actions, including strong utility programs, stronger codes and standards, and aggressive market transformation. We concur with comments that the Northwest Energy Efficiency Council offered at the September 30 Council hearing that more effort is needed to overcome market dislocations that result in consumers making a high level of economically irrational energy choices. Additionally, the draft should be strengthened to more clearly chart a path towards making the Northwest’s energy system less carbon-intensive. It is not enough to limit carbon emissions. It is essential to chart a path to reduce them. It would be safe to assume that in the not-too-distant future, there will be a price on carbon emissions aimed at reducing total greenhouse gas emissions. This price might be set by state and/or national legislation. If not by legislation, a price might be set by regulation. On September 30, the Environmental Protection Agency announced a proposal to regulate greenhouse gas emissions at new and modified industrial facilities through the Clean Air Act’s Prevention of Significant Deterioration provision. Looming ahead is EPA's proposed endangerment finding that could open the door to additional federal regulations. And if not by regulation, the price could be set through court action. On September 21, in Connecticut v. American Electric Power, the 2nd Circuit U.S. Court of Appeals ruled that eight states, New York City, and three land trusts may proceed with public nuisance litigation seeking court-imposed limits on greenhouse gas emissions. The lawsuit in question might be the first of many to be filed. To secure greenhouse gas emissions reductions that the best available science says is necessary to stabilize atmospheric carbon dioxide concentrations, carbon emissions from coal-fired generation must be sequestered, or else coal-fired generation must be replaced with less carbon-intensive resources. That is a critical energy choice that the Pacific Northwest faces. We urge the Council to equip the region with the information and a recommended strategy for making that choice responsibly. Thank you. Jim DiPeso Policy Director (253) 740-2066 jdipeso@rep.org