Rulemaking - Clean Fuel Standard Informal Comment Period #4

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Comment From: TES US Development (Alexandra Pieton)

12/17/24 @ 1:00 AM

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Comment From: Low Carbon Fuels Coalition (Robin Vercuse)

12/17/24 @ 1:00 AM

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Comment From: Infinium Operations, LLC (David Zaziski)

12/16/24 @ 1:00 AM

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Comment From: Washington State Dairy Federat... (Jay Gordon )

12/13/24 @ 11:06 PM

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Comment From: Promus Energy, LLC. (Dan Evans)

12/13/24 @ 9:48 PM

Please see comments attached.

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Comment From: The Transport Project (Sherrie Merrow)

12/13/24 @ 8:32 PM

Please see inserted file with comments from The Transport Project (formerly NGVAmerica).

Thank you.

Sherrie Merrow
The Transport Project Director of State Government Affairs

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Comment From: Growth Energy (Chris Bliley)

12/13/24 @ 6:46 PM

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Comment From: Electric Vehicle Charging Asso... (Brandon Wong)

12/13/24 @ 6:38 PM

Please find attached the Electric Vehicle Charging Association's comments to the Department of Ecology's Fourth Informal Comment Period for the Clean Fuel Standard Update.

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Comment From: bp America (Jim Verburg)

12/13/24 @ 6:26 PM

Dear Adam, and Ecology Staff.

We appreciate the opportunity to provide some brief comments regarding edits to definitions on the latest draft of the Clean Fuels Standard regulation released on November 26, 2024 which also includes changes made in t...↓

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Comment From: EV Realty (Jamie Hall)

12/13/24 @ 6:07 PM

Thank you for the opportunity to provide comments - please see attached.

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Comment From: Andrew Troske (Andrew Troske)

12/13/24 @ 6:05 PM

Please see attached letter from U.S. Oil & Refining Co.

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Comment From: Clean Energy (Ryan Kenny)

12/13/24 @ 5:43 PM

Thank you for considering the attached comments from Clean Energy concerning rule language changes to
the draft Clean Fuel Standard program.

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Comment From: Puget Sound Energy (Jessica Zahnow)

12/13/24 @ 5:27 PM

December 13, 2024

Attention: Adam Saul, CFS Rule Lead
Department of Ecology
Climate Pollution Reduction Program
P.O. Box 47600
Olympia, WA 98504-7600

RE: PSE informal comments on Ecology's Clean Fuel Standard updated draft rules revising Chapter 1...↓

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Comment From: Amp Americas (Cassandra Farrant)

12/13/24 @ 4:59 PM

Amp America appreciates the opportunity to submit comments in response to the proposed rulemaking for Clean Fuel Standard. Please see our comments attached.

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Comment From: Coalition for Renewable Natura... (Sam Wade)

12/13/24 @ 4:33 PM

Please see our comments attached.

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Comment From: Twelve Benefit Corporation (Ira Dassa)

12/13/24 @ 4:24 PM

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Comment From: Tesla, Inc. (Mal Skowron)

12/13/24 @ 3:53 PM

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Comment From: American Biogas Council (Jonathan Harding)

12/13/24 @ 3:50 PM

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Comment From: ZEEM SOLUTIONS (Daniel Schweizer)

12/13/24 @ 3:44 PM

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Comment From: Center for Resource Solutions (lucas grimes)

12/13/24 @ 3:42 PM

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Comment From: RPMG (Jon Costantino)

12/13/24 @ 3:37 PM

See attached RPMG Comments

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Comment From: POET, LLC (Paul Townsend)

12/13/24 @ 3:28 PM

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Comment From: Washington State Department of... (Kelly McLain)

12/13/24 @ 2:41 PM

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Comment From: 3Degrees Group Inc. (Lexi Concannon)

12/13/24 @ 2:31 PM

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Comment From: Electrify America (Elisia Hoffman )

12/13/24 @ 2:23 PM

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Comment From: Port of Seattle (Stephanie Meyn)

12/13/24 @ 2:12 PM

Dear Mr. Saul,
As previously expressed, the Port of Seattle has significant concerns with the proposed changes to the "regionality" requirements for renewable natural gas (RNG) in the proposed Clean Fuel Standard rulemaking, as well as the additional...↓ity requirements. The Port is very much in agreement with the principles of additionality for greenhouse gas reductions, but we feel the proposed manner in which this is addressed for RNG creates a very inequitable standard for reaching emission reduction targets.
From a regionality perspective, the Port would like to emphasize that only one third of natural gas that enters Washington stays in the state; about 65% of it continues south to Oregon and California. That means that >50% of flow is always in a southern direction and effectively means that any user of RNG in Washington state must be physically restricted to the south of a given project if they are to meet the proposed 50% requirement.
Given that the majority of the state's landfills and agricultural regions are to the south of population centers where fleets operate, this would cause almost all RNG produced in WA to be unqualified for the state's CFS. This is counter to the purported economic development aim of a "regionality" qualification for low carbon fuels. We suggest limiting regionality to interstate pipeline connectivity, but if the state insists on some kind of regionality, we suggest the use of a geographic range rather than within a particular flow direction.
Secondly, the additionality requirements proposed for RNG projects are out of line with the typical CAPEX/OPEX cost recovery for these types of facilities, as discussed with you by phone and follow-up email several months ago. Other low carbon projects such as solar have a much higher CAPEX requirement compared to OPEX. Thus, projects once built tend to keep running. RNG facilities are fundamentally different. While significant upfront capital investment is necessary, keeping these facilities operating entails a proportionally higher ongoing OPEX outlay on staffing, process energy procurement, logistics of feedstock procurement and digester cleanouts, maintenance, and replacement of rapidly amortizing assets such as compressors, etc.
If the additionality requirements were to be in line with the typical amortization of a new RNG facility, a 15 year timeline from commencement of operation would be much more reasonable.

Thank you for your consideration.

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Comment From: LoCI Controls, Inc. (Nicole Neff)

12/13/24 @ 1:51 PM

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Comment From: Western States Petroleum Assoc... (Antonio Machado)

12/13/24 @ 1:36 PM

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Comment From: Maas Energy Works (Dallas Spiecker)

12/13/24 @ 10:09 AM

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Comment From: ICCT (Nikita Pavlenko)

12/12/24 @ 7:16 PM

The attached comments are submitted by the International Council on Clean Transportation (ICCT). The ICCT is an independent nonprofit organization founded to provide unbiased research and technical analysis to environmental regulators. Our mission is...↓

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Comment From: Biotechnology Innovation Organ... (Gene Harrington)

12/12/24 @ 5:19 PM

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Comment From: SkyNRG Americas, Inc. (Kyle Mu... (Kyle Murphy)

12/12/24 @ 4:07 PM

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Comment From: Clean Fuels Alliance America (Cory-Ann Wind)

12/12/24 @ 1:57 PM

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Comment From: Smart Charging Technologies (Ma'n Altaher)

12/11/24 @ 2:18 PM

Please accept Smart Charging Technologies' comments related to eTRU registration and credit generation.

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Comment From: FirstElement Fuel (Matt Miyasato)

12/11/24 @ 10:10 AM

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Comment From: MA'N ALTAHER

12/02/24 @ 8:17 AM

On behalf of Smart Charging Technologies:

Regarding proposed amendment 173-424-300(1)(h)(iii)(I)"Edited to require eTRUs to be registered by facility, rather than individually" and the Reason for Change: "...and aligns with LCFS" update: 95483.2(b)(...↓

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