CCA Market Notice: Unspecified electricity imports and opt-in registration

Unspecified electricity imports   

On Nov. 18, 2024, Ecology published a CCA Market Notice about 2024’s Senate Bill (SB) 6058, including an explanation of its effects on importers of unspecified electricity. The information below further clarifies the effects of SB 6058 on emissions reporting and Cap-and-Invest Program requirements for importers of unspecified electricity. 

• For calendar year 2025, the reporting threshold for electric power entities (EPEs) who are not already obligated to report their emissions to Ecology will remain at 10,000 metric tons of carbon dioxide equivalent (MT CO2e). (per WAC 173-441-030(3)(a)) 

• Effective Jan. 1, 2025, EPEs who report their emissions to Ecology and report annual emissions exceeding 0 MT CO2e associated with unspecified electricity imports will be covered by the Cap-and-Invest Program. (per RCW 70A.65.080(1)(c)(i)(B)) 

• Effective Jan. 1, 2025, EPEs who report their emissions to Ecology and report annual emissions exceeding 0 MT CO2e associated with unspecified electricity imports will be required to obtain third-party verification of their reports, as covered entities. (per WAC 173-441-085) 

• Effective Jan. 1, 2025, EPEs who report their emissions to Ecology and report emissions exceeding 0 MT CO2e associated with unspecified electricity imports must submit sufficient compliance instruments to Ecology to cover at least 30% of all their covered emissions for the previous calendar year by Nov. 1, 2026, and each year thereafter. (per WAC 173-446-600(3)) 

• Reporters who have any compliance obligation incur compliance obligations for all their greenhouse gas emissions reported under Chapter 173-441 WAC, except as specified in (per WAC 173-446-040(2) through (4).) 

• The Cap-and-Invest Program coverage threshold for EPEs who only import specified electricity will remain at 25,000 MT CO2e (per RCW 70A.65.080(1)(c)(i)(A)). 

• The Cap-and-Invest Program coverage threshold for EPEs who only import specified and/or qualifying unspecified electricity purchased from a federal power marketing administration, such as the Bonneville Power Administration, will remain at 25,000 MT CO2e. (Per RCW 70A.65.080(1)(c)(i)(C)) 

Opt-in entity registration 

Entities whose greenhouse gas emissions are not above the Cap-and-Invest Program’s coverage thresholds can request to opt-in to compliance obligations for their greenhouse gas emissions as “opt-in entities.” 

Opt-in entities must attest they will report emissions to Ecology that are covered under Chapter 70A.65 RCW and subject to Chapter 173-446 WAC. Upon approval of their opt-in requests, opt-in entities are subject to the same requirements in Chapters 173-441 and 173-446 WAC as covered entities.