WA Energy Strategy says it improves physical fitness, decarbonizes energy, and protects people from earthquakes

*Note: The footnotes indicated in this excerpt can be found on the original blog post at the link below.

Decarbonization. Increased physical activity. Energy equity. Protection of communities in the subduction zone.

Those are all goals or benefits cited in the energy strategy proposed by the Washington state Department of Commerce. Last Friday we submitted comments to the second draft of the strategy, noting several problems, including the fact that the plan imagines it can see 30 years into the future (it can’t) and the support for a low-carbon fuel standard violates the principles of equity and effectiveness the strategy claims to support.

Below is the full text of our comments. We are waiting to comment on on additional reference cited by the plan but not made available by the comment deadline.


Re: 2021 Washington State Draft Energy Strategy

The Washington Policy Center submits these comments for consideration as part of the draft Washington State 2021 Energy Strategy. Washington Policy Center is an independent, non-profit research and education organization with members living in communities across Washington state.

We have several concerns about the current language and a few suggestions about ways the strategy can more effectively provide the energy the people of our state need for the next few decades, while reducing the state’s CO2 emissions and keeping energy affordable for small business owners, homeowners and working families. …

Low Carbon Fuel Standard (LCFS)

The Energy Strategy should remove its endorsement of a low carbon fuel standard because it contradicts many of the goals identified earlier in the document.

First, although the Energy Strategy says it “searches for the lowest cost path to reduce emissions,” a low carbon fuel standard is one of the most expensive strategies. In California, which has the most experience with an LCFS, it costs $200 per metric ton of CO2.[4] This amount is dramatically higher than existing alternatives found in the Regional Greenhouse Gas Initiative, where the price is $7.41,[5] and the European market, where the price is at an all time high but is still only $37.90.[6] It is also higher than the EPA’s Social Cost of Carbon, which is currently $42 but increases to only $69 in 2050.[7] An LCFS is not only an expensive and ineffective way to reduce CO2 emissions, but it does more harm than good according to the Obama Administration’s EPA.

To put this in context, Governor Inslee released a policy brief on climate strategy in December 2018 that noted that, when fully implemented, an LCFS would reduce the state’s CO2 emissions by 1.7 million metric tons. Using the current price of carbon projects from certified organizations like the Bonneville Environmental Foundation, it would cost $17 million to meet that level of reduction.[8] Using an LCFS it would cost the people of Washington about $340 million, plus the cost of administering the program.

Second, the Energy Strategy cites the governor saying “social equity and environmental justice” are goals. The LCFS also violates these objectives. The experience in California shows that most of the investments to comply with the LCFS are in wealthy communities – primarily EV charging stations – along with potential air quality improvements.

Using data from the California Air Resources Board about the location of LCFS-compliant EV charging stations, we found that 43% of charging stations were located in the top three wealthiest deciles. By way of contrast, the poorest three deciles received only 22% of the charging stations.[9] This is not only a transfer of dollars into wealthy communities, it also means the air quality benefits from electric vehicles are concentrated in those wealthy communities.

Additionally, the improvement in air quality is extremely small. The Puget Sound Clean Air Agency found the reduction in PM 2.5 is “small in comparison” to reductions from federal vehicle standards.[10] Additionally, The Department of Ecology, in research cited by the Puget Sound Clean Air Agency this year, found the LCFS would reduce PM 2.5 by about one percent over ten years.[11]

If the state is truly serious about reducing CO2 emissions using the “lowest cost,” while promoting equity, and improving air quality, the draft Energy Strategy should remove support for an LCFS which violates all of these principles, especially by imposing negative impacts on the poor.

Recommendation: Instead of an LCFS, which has proven to be costly, ineffective, and regressive, the state should move exiting climate-related expenditures into the CO2-reduction market.

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