Like many cities, Bellevue is updating its required sustainability plan this year. Like the previous plan, much of the focus is on climate change. Like the state and many other cities, Bellevue has fallen far short of meeting its own climate goals. And since the last plan was adopted, the state put a comprehensive climate plan in place, making the patchwork efforts of cities duplicative and unnecessary.
The city council has the opportunity to make Bellevue's sustainability plan more effective by focusing on those areas the state is not addressing and prioritizing efforts that make the city better for residents as well as the environment. We offered a few ideas on how the updated sustainability plan could improve on and learn from past failures.
You can read our comments in their entirity below, but there are four key takeaways:
- The previous sustainability plan failed to meet its targets - even after COVID cut city emissions dramatically - becuase the focus was on government control and projects that didn't yield environmental benefits.
- Now that the state has a comprehensive climate policy, the city should not focus on reducing CO2 emissions unless those projects save more money than they cost. City-level projects simply duplicate state efforts, adding cost but yielding no additional CO2 reductions.
- The city should either eliminate or modify its existing climate goals. If councilmembers want to keep climate targets, the goals should be based on effectiveness not absolute reduction targets that have been ignored anyway. For example, the city could set a goal to reduce emissions only when the cost is below the level of the state's CO2 tax - saving money and cutting emissions.
- Focus on projects that make Bellevue a better place for people and wildlife. Spending millions to cut tiny amounts of CO2 that are already covered by the state's plan is a waste of resources. Instead, funding could go to improving the tree canopy, reducing runoff that harms salmon in Lake Sammamish and Lake Washington, and funding other local environmental efforts. Those projects have real, tangible impact for the community.
My full comments are below.
September 8, 2025
To: City of Bellevue
Subject: 2026-2030 Sustainable Bellevue Plan Update
A lot has changed since Belleuve’s last sustainability plan, including dramatic shifts in virtual work, numerous new state climate policies, among other changes. Most notable, however, is the fact that Bellevue has consistently failed to achieve its climate goals and is far from meeting the next goal in 2030, as even city staff admit. A major reason for that failure is that past plans have been unrealistic.
As the city updates its sustainability plan, it should take those factors into account and see the new plan not merely as an opportunity to adjust the plan but to learn from the past failures and meaningfully change the approach to how the city addresses environmental issues. It is time for the city to eliminate wasteful subsidies and regulations, end the duplication of policies where the state is already acting, and focus on efforts that make Bellevue more livable.
I have worked on climate and environmental policy in Washington state for a quarter century, as a staff member of the Washington State Department of Natural Resources, a member of the Puget Sound Salmon Recovery Council, as an environmental policy analyst and author of two books on environmental policy. I advocated for a revenue-neutral carbon tax and every year I invest in projects that cut my personal carbon footprint to zero or near zero.
Over 25 years, I have watched cities and the state make the same mistake again and again by focusing on climate symbolism rather than environmental effectiveness. The result – not just in Bellevue, to be fair – has been a consistent pattern of failure.
According to the city’s climate dashboard, Bellevue’s community-wide GHG emissions have increased nine of the last 12 years. In 2023, the most recent year with data, emissions were 35 percent above the city’s target. To meet the 2030 goal, Bellevue would have to reduce emissions between 2024 and 2030 by the equivalent of 1.6 COVID-level reductions. Emissions would have to decline by more than eight percent a year for every year between 2024 and 2030. Citywide emissions have not declined since 2020, making that rate of reduction virtually impossible.
Given the fact that it has been extremely difficult for the city to reduce emissions at all, let alone at the rapid pace required by the current targets, the updated sustainability plan should adopt three policies that can help the city become more effective at promoting environmental stewardship during the next five years.
First, focus on things that directly benefit city residents and are within the city’s control. For example, improving the tree canopy, promoting clean water for fish, and improving transportation infrastructure to reduce traffic congestion are all key responsibilities of the city and would improve the lives of all Bellevue residents as well as fish and wildlife.
Second, dramatically change or remove CO2 reduction as a goal of the sustainability plan. When the last plan was adopted, there was no comprehensive statewide climate policy. Since 2023, the state has put a hard cap on statewide emissions. Adding city regulations and spending would simply duplicate state climate efforts for additional cost. The city should focus its resources on areas not already addressed by existing state policy. At the very least, the existing goals should reflect realistic goals or, better yet, be based on what is economically feasible. For example, the city could commit to reducing CO2 emissions as long as the cost is below the state’s CO2 price under the Climate Commitment Act.
Third, if city officials are required to show they are doing something to reduce CO2 emissions, even if those efforts duplicate state efforts, the plan should require that city-funded projects yield the greatest reduction in CO2 emissions for every dollar. This is the approach followed by Amazon, Microsoft and other companies looking to effectively reduce CO2 emissions. The draft sustainability plan includes some programs that are extremely expensive, yielding extremely small amounts of CO2 for the cost. If the plan is serious about meeting “the urgency of the moment,” wasting resources on efforts that yield little benefit to the climate and environment is not defensible.
Complementing – not duplicating – state climate policy
Since 2023, the state’s Climate Commitment Act has put a cap on statewide CO2 emissions, imposing a rapidly increasing tax on greenhouse gas emissions to meet that target. In addition, the state has numerous other climate policies including a low-carbon fuel standard, a requirement that electricity is net-zero emissions by 2030, and laws to reduce landfill-related methane emissions, among many others.
Adding additional local policies on top of those comprehensive policies is extremely unlikely to add to total statewide reductions. Instead, city policies are likely simply to cut emissions that would have been reduced in some other way, but at higher cost to Bellevue residents. This is one problem with setting local targets in addition to statewide goals. In the same way that it would not make sense for Crossroads or Wilburton to have their own local climate targets, it makes no sense for Bellevue to have goals in addition to the state’s existing targets.
Some parts of the city or state may have a more difficult time cutting emissions. For example, Bellevue has seen a significant reduction in emissions and vehicle miles traveled from passenger vehicles since 2019, in large part due to the increase in virtual work. That level of reduction was not available to other parts of the state during that period, meaning Bellevue over-contributed to statewide emissions reductions since 2019.
Additional reductions related to virtual work are probably not available to Bellevue. In the future, however, other parts of the state may have opportunities for CO2-reduction not available to Bellevue. Setting climate targets for each city ignores these differences in opportunity and makes meeting state goals more expensive without improving environmental outcomes.
Bellevue leaders should also recognize that the city’s current climate targets are based on arbitrary political goals and not science. The existing goal of reducing CO2 emissions by 50 percent (an arbitrary number selected because it is divisible by five and sounds good) by 2030 (exactly at the end of a decade) compared to 2011 (a date chosen because that was when the city council chose to adopt the targets) is not a useful way to plan climate policy. No analysis was done to indicate whether the goal was feasible or cost-effective. Cutting emissions by 50% by 2030 sounds catchy, though.
Instead, the city would be much better off by setting targets based on the cost to reduce emissions compared to alternative approaches. The state’s current CO2 price is about $58 per metric ton of CO2. Spending more than that to cut emissions would mean the city is spending more to cut emissions than could be achieved in other ways. An even better metric would be the current market rate to invest in projects that reduce CO2 emissions of less than $10 per metric ton.
The city should also use the state’s existing tax on CO2 emissions as a guide to measure results. Projects that reduce the use of carbon-intensive energy calculated to save the city more than it costs would not only be financially responsible by reducing the amount of the CO2 tax paid by the city and residents, but would reduce emissions efficiently and effectively.
By way of comparison, using the existing arbitrary and unscientific targets will continue the city’s record of promoting approaches that are wasteful and continue to miss the targets.
Where Bellevue should put its resources
Based on those metrics of environmental effectiveness, many of the proposals in the existing sustainability plan are infeasible or wasteful. Others, however, are worthwhile and will make Bellevue more environmentally sustainable and a nice place to live.
Here is a look at just a few of the policies included in the plan and how they measure up.
The proposed “priority strategy” to “engage the community in greenhouse gas emissions reduction and climate resilience” doesn’t mean anything. Purportedly, the city has been doing that for the past 15 years and the results have been awful. Often, the money spent on such “engagement” efforts would be better spent to directly invest in CO2-reduction projects.
The plan encourages organizations and businesses to “track greenhouse gas emissions” and “develop a plan to reduce emissions.” This, however, is unnecessary. Washington put a price on CO2 emissions, so businesses are already working to reduce emissions simply by cutting energy costs. That is the purpose of putting a tax on CO2 emissions – to provide a financial signal and incentive to reduce emissions. That is already in place.
Regarding “Energy & Buildings,” the plan supports an effort to “Reduce residential energy use by addressing natural gas consumption and energy efficiency through programming and partnerships, such as scaling the Energy Smart Eastside program.”
These programs, including installing heat pumps and other efficiency measures, yield tiny reductions in CO2 for the amount of money in the program. According to Energy Smart Eastside, they have installed 675 heat pumps which have contributed to avoiding 22,700 metric tons of CO2. That amounts to 33.6 MT of CO2 reduction by switching primarily from natural gas heating to electric heating and cooling.
Assuming their numbers are accurate, each $6,000 heat pump subsidy yields 33.6 metric tons of reduction, which is $178.57 per metric ton of CO2. That is triple the current state CO2 price and almost than 18 times as expensive as readily available projects to reduce CO2 emissions at $10 per metric ton. Assuming Energy Smart Eastside’s numbers are accurate, subsidizing heat pumps yields about 6 cents worth of environmental benefit for every dollar spent. That is extremely wasteful and is not an effective way to cut emissions.
Sometimes supporters of such projects justify the cost by claiming they also help low-income households cut energy costs. Once again, there are already programs funded by the state and utilities to do this, so it is unclear that low-income households would receive much, or any, benefit. Even if they did, it might make more sense simply to have the city pay the utility bills of low-income families. That would be a win-win – more CO2 reduction and less cost to low-income families.
At the very least, before the city commits to putting more funding into such programs, they should show their math. What is the cost to reduce CO2 emissions of these programs? What is the cost benefit to low-income families? If subsidies for heat pumps yield only 6 cents on the dollar of environmental benefit, the city could easily make better use of the remaining 94 cents to help low-income families and the environment.
The plan also calls for the city to “support solar installations and storage on parking lots and buildings and with community solar projects.” This is one of the most wasteful ways to cut emissions.
According to the National Renewable Energy Laboratory, Western Washington is the worst place in the nation (outside Alaska) to install solar panels. Additionally, Lazard, which is the recognized expert in analyzing the cost of various sources of energy, notes that community solar and rooftop solar are the most expensive ways to generate electricity. Their 2025 “Levelized Cost of Energy” report released in June shows the cost of community and small-scale solar are more expensive than any form of energy except gas peaking, which is the most expensive. It is triple the cost of utility-scale solar and wind. Subsidizing the worst form of energy generation in the worst part of the country for it makes no sense.
Additionally, numerous studies show that strict “green building” standards fail to live up to their promises while increasing costs significantly. For example, a study from researchers at Oberlin College in 2021 found that LEED-certified buildings in Seattle reduced CO2 emissions by only five percent despite very high costs. Put another way, the annual CO2 reductions from 23 million square feet in 50 LEED-certified buildings in Seattle could be matched for less than $1,000 per year.
By way of contrast, using “demand response” can reduce CO2 emissions and actually save money. Demand response encourages people to use electricity when it is inexpensive and when energy is likely to rely on carbon-free sources of energy. Seattle City Light, Benton Public Utilities District and many other utilities across the country currently use this approach or will in the near future.
One reason that Bellevue, Seattle, King County and Washington state have all consistently failed to reduce emissions is that programs like Energy Smart Eastside have spent huge amounts of money without auditing or measuring the results. If the updated plan is serious about reducing emissions, it should require that projects are prioritized based on cost effectiveness. Heat pump subsidies and community solar fail any reasonable test of effectiveness. Demand response is likely to end up saving money.
The point is not to believe me – or the National Renewable Energy Laboratory, or Lazard, or Oberlin College, or even the city’s own numbers – showing that proposed strategies are likely to be wasteful and ineffective. Instead, the sustainability plan should require that spending be prioritized where it yields the greatest environmental benefit, allowing the city to see for itself where projects make sense.
Absent such a requirement, it would be clear that the purpose of the sustainability plan is not to help the environment but to choose feel-good projects that sound good politically.
It is time to put the city on a path to environmental success
If city leaders are interested in breaking from the consistent record of failure that has been emblematic of past plans, the 2026-2030 Sustainable Bellevue Plan should adopt three policies.
- Focus on projects that help Bellevue
Several of the recommendations make sense independent of CO2 emissions. Electricity demand response, increasing the tree canopy, reducing runoff into Lake Washington and Lake Sammamish, and improving road infrastructure all help make Bellevue a better place to live, help salmon and clean water, and make the city more resilient to storms.
As the price of natural gas and electricity increase due to the state’s taxes on CO2 emissions, the city and residents will – and should – find ways to become more energy efficient. How they do that will be unique for each family and company. Rather than government attempting to promote simplistic and costly programs like subsidizing heat pumps, the city should allow the state’s program to work and focus on spending resources that provide benefits to the city. - Eliminate or significantly modify the city’s arbitrary and unattainable CO2 targets
The existing goals are arbitrary, political goals which are unattainable and push the city to waste money in a vain effort to meet the targets. I sometimes hear that having goals is useful to give the city something to shoot for. This is clearly not the case since the city has never met the goals. Additionally, unrealistic goals encourage wasteful expenditures.
If the city wants to keep the existing goals or must have goals to meet requirements of the PSRC, city officials should set goals that are more realistic or based in metrics, such as cost effectiveness, that emphasize environmental effectiveness, not arbitrary targets.
For example, the city could change the target from reducing emissions by 50% by 2030 compared to 2011, to reducing emissions when the cost per MT of CO2 is below the current CO2 price set by the Climate Commitment Act. That would be cost effective and would take advantage of the existing state laws rather than needlessly duplicating efforts. - Set metrics of effectiveness for all CO2-reduction expenditures
If the city makes only one change to the updated plan it should be to set metrics of effectiveness for its projects and prioritize spending based on those metrics. Bellevue, Seattle, King County, Washington state and numerous other jurisdictions routinely miss climate targets because projects are chosen based on symbolic value, not environmental effectiveness.
According to the Washington State Department of Ecology, some of its climate projects cost up to $144,475 to reduce one metric ton of CO2 that could be achieved with $10 using publicly available and certified projects from organizations like the Bonneville Environmental Foundation. Without setting clear metrics and strict prioritization, the city may find itself in the same situation. Many of the most effective CO2-reduction strategies are the least politically popular and many that sound good, like rooftop solar, are ineffective. Without setting a strict standard of effectiveness, the city’s approach will follow the pattern elsewhere of funding feel-good programs that end up failing.
If you have any questions about the data or claims made in this letter, please contact me at tmyers@washingtonpolicy.org.