November 19, 2017

EPA's Proposed Rule 111(d) a Step in the Right Direction

June 2, 2014

The Sacramento Municipal Utility District (SMUD) supports the release by the Environmental Protection Agency (EPA) of draft regulations to reduce greenhouse gases (GHG) under Section 111(d) of the Clean Air Act. SMUD has adopted a goal of reducing its GHG emissions to 10 percent of its 1990 levels by 2050 and welcomes progress towards GHG reductions at the national level.

'SMUD has shown that it's possible to establish a portfolio of zero-GHG energy resources and highly efficient natural gas power plants, along with investments in energy efficiency, to achieve reduced GHG emissions while maintaining reliable and affordable electricity service for its customers,' said SMUD General Manager and CEO Arlen Orchard. 'It's clear that climate change is a pressing environmental threat requiring national action to reduce carbon emissions, and we owe it to future generations to ensure the health of the planet.'

'Proposing and adopting flexible GHG regulations under Section 111(d) aligns with SMUD's vision to empower our customers with solutions and options that increase energy efficiency, protect the environment, reduce the impacts of climate change, and lower the cost to serve our region,' said Orchard. With investments in energy efficiency and renewable energy, SMUD has already reduced its GHG emissions by 20 percent relative to 1990 levels and its energy resource portfolio is around 50 percent carbon neutral.

Successful implementation of the proposed regulation will require a flexible final rule that allows states to meet carbon reduction goals and provides equivalency when it comes to California's greenhouse gas reduction efforts including the state's cap-and-trade program. It's important that the final EPA rule allows utilities such as SMUD to comply with national standards through existing California programs that are effective at reducing greenhouse gas emissions.

SMUD urges other California utilities and their industry associations to work with the governor and other state agencies to support the EPA taking strong action that includes, recognizes, and builds on what California has already done to begin reducing carbon emissions, including the implementation of AB32, the Global Warming Solutions Act, the state's cap and trade carbon trading program, and our investments in renewable energy, energy efficiency, and other carbon-reduction efforts.

SMUD looks forward to reviewing the proposed standards and sharing its views with industry partners, the EPA and California policymakers. SMUD intends to work closely with California policymakers and other California utilities to study and coordinate comments on the proposed regulations.

SMUD is encouraged by the state's regulatory process that balances the need for action to reduce carbon emissions with protection of electric customers. SMUD stands with Governor Brown and the California Air Resources Board in pushing for strong emphasis on energy efficiency and system wide GHG reductions.

'Constructive engagement and outreach by the EPA with states such as California is important to crafting a final rule that protects the environment while mitigating impacts on our customers,' said Orchard. 'SMUD urges the EPA to have flexible rules on how states would meet carbon reduction goals and to establish equivalency under the regulations for strong state efforts such as California's programs.'

About SMUD

As the nation's sixth-largest, community-owned electric service provider, SMUD has been providing low-cost, reliable electricity for more than 65 years to Sacramento County (and a small portion of Placer County). SMUD is a recognized industry leader and award winner for its innovative energy efficiency programs, renewable power technologies, and for its sustainable solutions for a healthier environment. SMUD is the first large California utility to receive more than 20 percent of its energy from renewable resources.