Greenhouse Gas Compliance Strategy for a Public Power Utility

Helped a public power utility move from reactive to proactive carbon compliance under Washington's cap-and-invest program, from shaping state rules to allowance auction strategy.

Seattle City Light · Energy Market & Carbon Policy Intern, summers 2024–2026

At a glance

Role Carbon policy analyst supporting the utility's compliance strategy
Scope State rulemaking, market linkage planning, allowance auctions, emissions reporting
Methods Regulatory analysis, allowance market analysis, historical e-Tag analysis, reporting scenarios
Tools Excel, Python
Skills Cap-and-invest compliance, carbon markets, rulemaking comments, emissions accounting, stakeholder engagement
Result More than $1M saved for ratepayers

The question

Washington’s cap-and-invest program began in 2023 and its rules are still being written. Utilities typically account for emissions after the fact, a year after the trades that create them. The utility wanted a forward-looking approach: shape the rules, prepare for linkage with the California–Québec carbon market, and align trading with compliance so costs are not passed on to ratepayers.

Settlement prices at Washington's quarterly allowance auctions, from public Department of Ecology results.

What I did

The four workstreams, from shaping the rules to stress-testing reporting.
  1. Shaped state rulemaking. Represented the utility in Department of Ecology workshops and a regional public power carbon working group, and drafted comments on whether proposed rules were operationally feasible and trackable.
  2. Prepared for market linkage. Tracked the proposed linkage with California and Québec and wrote internal memos on how it would change auction participation, trading, and reporting.
  3. Developed auction strategy. Built the utility’s allowance auction strategy from public auction data and supply-demand analysis.
  4. Stress-tested emissions reporting. Analyzed three years of e-Tag data to estimate the compliance burden if Fuel Mix Disclosure reporting moves from annual to monthly or hourly netting of unspecified purchases against specified sales, and recommended changes to trading and tagging practices ahead of stricter rules.

What it shows

How the netting window changes what stays unspecified. Illustrative numbers, not utility data.
  • From regulation to data. Translates draft rules into quantified operational impacts.
  • Proactive compliance. Plans trades and procurement around compliance, instead of accounting for it after the fact.
  • Ready for finer reporting. Shows what a shorter netting window would mean before a rule requires it.
  • Built for ratepayers. Lowers compliance costs that would otherwise reach customers.

This page describes methods only. The utility’s positions, trading data, auction strategy, and findings are confidential. Contact me to discuss the approach in more detail.