Rulemaking - Chapter 173-446 WAC, Climate Commitment Act Program

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Comment From: Kathleen Washienko

7/12/22 @ 2:11 PM
Dear Mr. Grice,

I'm so proud that Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a long-time Seattleite and mother, I'm excited to see the benefits including deep reduction...↓

1) Maintain the integrity of the cap. The ultimate goal of the CCA is reach our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

2) CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

3) CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.
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Comment From: Carolyn Treadway

7/12/22 @ 2:09 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.
No attachments

Comment From: Alex Fay

7/12/22 @ 2:04 PM
CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When d...↓

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.
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Comment From: Patrick Conn

7/12/22 @ 1:57 PM
Dear Mr. Grice,

Washington has now made a historical commitment to the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, improved air quality, investments in clean ...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

There is NO TIME LEFT for equivocation in the face of UNRELENTING REPUBLICAN PARTY TRUMP SOCIALLY-SICK POLITICALLY CORRUPT OBSTRUCTION and ENVIRONMENTAL RAPE and DESTRUCTION, all for personal gain, and now SCOTUS'S BLATANT CHRISTIAN BALD-FACED BIASED HYPOCRITICAL THEOCRATIC USURPATION OF OUR FORMALLY CIVIL JUDICIARY CONTINUED WORSHIP OF 'TRUMP FAMILY VALUES' and RAPE, PILLAGE, AND PLUNDER DEMIGOD-LIKE INDIFFERENCE TO ANYTHING OR ANYONE BUT THEMSELVES. If the human race, and the rest of this planet is to survive much longer, HUMANS MUST REVERSE OUR ECO-DEVASTATION NOW!

Thank you for considering my comments.
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Comment From: Marian Wineman

7/12/22 @ 1:55 PM
Dear Mr. Grice,

Washington successfully passed the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident climate activist of the state, I can't wait to see the benefits including deep reductions in climate p...↓
CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

I appreciate your attention to my comments.

Sincerely,

Marian Wineman
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Comment From: Jaime Sasse

7/12/22 @ 1:43 PM
Dear Mr. Grice,
Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓
CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.
CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.
CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.
Thank you for considering my comments.
Sincerely, Jaime Sasse
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Comment From: Ariana Ylvisaker

7/12/22 @ 1:43 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

- CCA rules must maintain the integrity of the cap. The goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

- CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have endured the most air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

- CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.

Sincerely,
Ariana Yvisaker
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Comment From: Andrea Learned

7/12/22 @ 1:42 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

*CCA rules must maintain the integrity of the cap.* The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

*CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color.* For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

*CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities.* The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

I'm a Seattle resident who advises corporate sustainability leaders and global NGOs on understanding and amplifying the emissions-reductions solutions like supporting a less car-focused culture and supporting healthier, more plant-based food to reduce animal agriculture methane. I'd so love to see my own state keep taking the lead on true climate action commitment. Thank you for considering my comments.

Sincerely, Andrea Learned
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Comment From: David Randall

7/12/22 @ 1:42 PM
Our climate is now crashing as proven by the consistent adverse weather conditions across much of the United States, ie. increase tornados, increased temperatures that threaten human health, drought, forest fires and a predicted unusually active hurr...↓
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Comment From: New World Communications (Art Johnson)

7/12/22 @ 1:40 PM
Dear Good Folks at Dept of Ecology - New World Communications is my own diverse, African American equity-creating, inclusive, near-zero carbon footprint 21st-century remote consulting practice and virtual enterprise providing world-class, big-reach, ...↓

Therefore, let's connect and explore moving forward in an even more timely and mission-critical way, as the climate clock keeps ticking down. For more info, visit us at: https://www.newworldcom.com/

Art Johnson
Contract Sr.Instructional Designer / Chief Learning Officer / CEO
New World Communications
Lynnwood, WA - 425-780-6872 (Virtual office) and 206-920-8067 (Cell direct)
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Comment From: Virginia Davis

7/12/22 @ 1:27 PM
Thank your for the opportunity to comment on the Climate Commitment Act (CCA). As a Washington state resident, I endorse the objectives including deep reductions in climate pollution, improved air quality, investments in clean transportation and clea...↓

* The rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

* Investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

* The implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you,
Virginia Davis
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Comment From: Nance Epstein

7/12/22 @ 1:24 PM
Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, improved air quality...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.

Sincerely,
Nance D. Epstein
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Comment From: Vanessa Meraki

7/12/22 @ 1:23 PM
As a mother and educator in Washington state, nothing is more important to me than restoring our climate to a livable state. The Climate Commitment Act is a very good piece of legislation, and it must be implemented effectively. In order to do that, ...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of frontline communities, especially Black, Indigenous and communities of color. For too long, these communities have been subject to racist planning, policies, and practices that place us at risk for chronic disease and lower our quality of life. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be community led and maximize cobenefits, including thriving, ecologically sound economies, tribal sovereignty, Black liberation, and cultural autonomy.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and be led by overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council trusted community-based organizations, and community leaders to determine the best processes for collaboration.

We have no time to lose. The changes we make to decarbonizing can also address deeper social inequalities and public health issues, and we should take full advantage of this transformational moment in our way of life.
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Comment From: Deirdre Gabbay

7/12/22 @ 1:21 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.

Sincerely,
Deirdre Gabbay
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Comment From: Gregory Penchoen

7/12/22 @ 1:18 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.
No attachments

Comment From: Yonit Yogev

7/12/22 @ 1:15 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.
Sincerely,
Yonit Yogev
Olympia, WA
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Comment From: Coleen Anderson

7/12/22 @ 1:07 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

I pray that this program is successful in equitably lowering greenhouse gas emissions so that my grandchildren and future generations can look forward to a healthy, habitable future.

Thank you for considering my comments.

Sincerely,
Coleen Anderson
Yakima, WA 98902
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Comment From: Lorraine Johnson

7/12/22 @ 1:02 PM
Please act so that our state and world will survive.
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Comment From: Carl Olson

7/12/22 @ 1:02 PM
Effective, working rules are crucial to realizing the maximum benefit from the Climate Commitment Act.
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Comment From: Bobbie Morgan

7/12/22 @ 1:01 PM
Regarding ch. 173-446 WAC Climate Commitment Act Program:
Thank you to all who are working on this. I am deeply grateful for broad, effective and durable legislation and programs that help mitigate climate chaos. These are crucial efforts. The need is...↓
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Comment From: Ann Dawson

7/12/22 @ 12:54 PM
Attachments:

Comment From: Brenda Michaels

7/12/22 @ 12:53 PM
Dear Mr. Grice,
Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓
CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.
CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.
CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.
Thank you for considering my comments.
Sincerely, Brenda Michaels ___
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Comment From: Ra'id Khalil

7/12/22 @ 12:50 PM
It's about time we work on the mess you've created regarding climate change. Please move forward aggressively as we're running out of time on this major issue.
Regards.
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Comment From: Jamie Peltier

7/12/22 @ 12:49 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.

Best regards,

Jamie
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Comment From: Den Mark Wichar

7/12/22 @ 12:47 PM
Allow me to simply say that I fully support the Climate Commitment Act, and I urge you to take it as far as you can. It matters!
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Comment From: Noah Ehler

7/12/22 @ 12:46 PM
Dear Mr. Grice,

Washington made history by passing the country's strongest law capping carbon pollution, the Climate Commitment Act (CCA). As a resident of the state, I am eager to see the benefits including deep reductions in climate pollution, impro...↓

CCA rules must maintain the integrity of the cap. The ultimate goal of this law is to achieve our greenhouse gas limits and improve air quality, especially in overburdened communities. Ensuring that emissions do not exceed the cap is critical. When designing program details, maintaining the cap should be one of the primary goals.

CCA investments must prioritize significant improvements in air quality of overburdened communities, especially Black, Indigenous and communities of color. For too long, these communities have borne the brunt of air pollution and climate impacts. The CCA requires that a minimum of 35% of overall investments directly benefit these communities. These investments must be thoughtfully designed with community input to ensure benefits are meaningful.

CCA's implementation process must collaborate with the Environmental Justice (EJ) Council and with overburdened communities. The rule should provide more clarity on how the Council and communities will be engaged in the development and implementation of the full program. Ecology should work with the EJ Council to determine the best processes for collaboration.

Thank you for considering my comments.

Sincerely, Noah Ehler
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Comment From: California Urban Forests Counc... (Nancy Hughes)

7/11/22 @ 9:55 AM
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Comment From: James Rehrmann

7/11/22 @ 9:22 AM
I wish to make a comment regarding the implementation of the state's Cap and Invest program.

Overall the program must
- ramp up requirements to cap emissions significantly and in a timely manner - more sooner is better
- provide for flexibility in the p...↓
- push supplementary programs - like electric vehicle charging infrastructure - that enable the planned pace of emissions reductions.

Thanks
Jim Rehrmann
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Comment From: Eric Strid

7/08/22 @ 3:20 PM
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Comment From: Ed Chadd

7/07/22 @ 4:10 PM
Please use the best available science and modeling when developing forest offset protocols for the CCA. I note the following concerns:
1. California's forest offset system has underperformed and incurred costs to the public:
a. "Systematic over-crediti...↓
b. "The Climate Solution Actually Adding Millions of Tons of CO2 Into the Atmosphere": https://www.propublica.org/article/the-climate-solution-actually-adding-millions-of-tons-of-co2-into-the-atmosphere
2. Any directive to consider the dictates of HB 2528 (as codified in RCW 70A.45.090) in the rulemaking must consider at the same time the best available science on the subject of forestry-related carbon sequestration, which contradicts much of the conclusions dictated by HB 2528:
a. Scientists' letter to the U.S. Congress re climate impacts of logging: https://sites.tufts.edu/gdae/files/2020/05/Forest-Letter-to-Congress.pdf
b. Proforestation Mitigates Climate Change and Serves the Greatest Good: https://www.frontiersin.org/articles/10.3389/ffgc.2019.00027/full
c. Proforestation is the optimal way to store forest carbon: https://www.mdpi.com/2073-445X/11/5/721
d. All forest sector emissions must be accounted for: https://iopscience.iop.org/article/10.1088/1748-9326/ab28bb
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Comment From: Mark McPherson

7/07/22 @ 2:28 PM
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Comment From: Annie Phillips

7/06/22 @ 9:43 AM
The rule must be strengthened to ensure benefits to overburdened communities are realized; the Tribes are properly consulted; the carbon market functions with transparency and integrity; and there is adequate information to guide adapt to new conditi...↓
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Comment From: Rosemary Moore

7/05/22 @ 5:08 PM
Public Comment on Proposed Program Rules (WAC 174-446) under the Climate Commitment Act
The Climate Commitment Act provides opportunities to reduce carbon, bring well-paying jobs to Washington, and invest in overburdened communities. The state legisla...↓
I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives to help achieve our climate goals in an equitable and just way.
However, it is essential to get these rules right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program.
I submit the following comments on these critical rules which will shape how our state's cap & invest program will be implemented.
The recent IPCCs have made it crystal clear that we cannot delay or water down actions to reduce Greenhouse gas emissions. As a parent and new grandparent, I am terrified of the future my adult children and their children will face in the not so distant future.
I urge you to strengthen these rules in the following ways:
• Program design and Overburdened Communities: The statute is clear that the program should benefit overburdened communities and not cause environmental harm. Yet, the program rules do not clearly articulate how this will be achieved. This is a gap that should be filled, starting with the following changes:
o Clarify Ecology's role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs), regardless of when they become a covered entity, on overburdened communities;
o Establish an explicit review process for how overburdened communities are impacted and ensure Ecology has information required to conduct that review;
o Clarify Ecology's role in evaluating the impact on overburdened communities and for achieving environmental benefits from the program.

● Information to build in review and accountability:
o Information to guide evaluation of impacts: Ecology should require all covered entities to provide information about their impacts on overburdened communities and on tribal lands and treaty rights, the chemicals and pollutants they process and/or manage, and if there are any violations under any permits they hold.
o Information to guide program review: Ecology should require gas and electric producers and utilities to provide information on how they spend any revenue from the sale of no cost allowances.
o Best available technology: Ecology should require Emission-Intensive Trade-Exposed facilities (EITEs) applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by the facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.
o Publicly disclose and document: Ecology should publicly share and document data being used to establish baseline information, subtotal baselines, and allocations.

• Role of Environmental Justice Council: Per the statute, the Environmental Justice Council has an oversight role on the full program, including, but not limited to, linkage, protocols for offset projects and credits, designation of EITE industries, and administration of allowances. Yet the draft program rules do not provide adequate information to support this role or clarify Ecology's responsibilities for engaging with the Council. This is a gap that needs to be filled. The Council has the authority to determine its process for engagement with, and recommendations to, Ecology in this regard. This rule should be strengthened to:
o Include explicit language into the rule on how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.
o Track information about the environmental and health impacts of all EITE facilities to inform Council review.

• Offsets:
o Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution, 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.
o Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.
o Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.

• Tribal Treaty Rights: This rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes.
I look forward to Ecology's ongoing work to strengthen and finalize this rule as part of our state's work to meet our climate goals in an equitable and just way.
Thank you for taking the time to consider this submission.
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Comment From: GARY NUTT

7/05/22 @ 9:16 AM
This "Robin Hood" program to take money from people who are forced to pay higher prices for energy and give it to entities to use for so-called climate change mitigation is a farce and I do not support it. The money that Washington citizens are bein...↓
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Comment From: priscilla martinez

7/01/22 @ 7:39 PM
We need to take better care of what is left of our environment, for wildlife, marine life, plant life, and people.
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Comment From: Derek Benedict

7/01/22 @ 3:52 PM
The Climate Crisis is a clear and present danger to all forms of life on Earth. And the longer we wait, more species will go extinct, and the cost to clean up our planet will only grow exponentially.

Take strong and meaningful action now!
Attachments:

Comment From: P Elle

7/01/22 @ 9:52 AM
The statute is clear that the program should benefit overburdened communities and not cause environmental harm. Yet, the program rules do not clearly articulate how this will be achieved. This is a gap that should be filled, starting with the followi...↓

– Clarify Ecology's role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs), regardless of when they become a covered entity, on overburdened communities;
– Establish an explicit review process for how the program is impacting overburdened communities and ensure Ecology has information required to conduct that review;
– Clarify Ecology's role in evaluating impact of linkage on overburdened communities and for achieving environmental benefits of program.
nformation to build in review and accountability:

– Information to guide evaluation of impacts: Ecology should require all covered entities to provide information about their impacts to overburdened communities and to tribal lands and treaty rights, the chemicals and pollutants they process and/or manage, and if there are any violations under any permits they hold.
– Information to guide program review: Ecology should require gas and electric to provide information on how they spend any revenue from the sale of no cost allowances.
– Best available technology: Ecology should require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by the facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.
– Publicly disclose and document: Ecology should publicly share and document data being used to establish baseline information, subtotal baselines, and allocations.

Role of Environmental Justice Council: Per the statute, the Environmental Justice Council has an oversight role of the full program, including, but not limited to, linkage, protocols for offset projects and credits, designation of EITE industries, and administration of allowances. Yet the draft program rules do not provide adequate information to support this role or clarify Ecology's responsibilities for engaging with the Council. This is a gap that needs to be filled. The Council has the authority to determine its process for engagement with, and recommendations to, Ecology in this regard. This rule should be strengthened to:

– Include explicit language into the rule on how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.
– Track information about the environmental and health impacts of all EITE facilities to inform Council review.

Offsets:

– Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution, 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.
– Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.
– Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.

Tribal Treaty Rights:

– This rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes.

Thank you.
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Comment From: Elizabeth Tickman

7/01/22 @ 8:07 AM
My name is Elizabeth Tickman, and I am a constituent.

Thank you for the opportunity to comment on this critical rule that will shape how our state's cap & invest program will be implemented. The Climate Commitment Act is the strongest carbon pricing p...↓

I care about this because I enjoy our delicious clean water and beautiful natural areas for hiking, biking, kayaking, snowshoeing and living in with my family. I would like my future generations to enjoy this lush environment as well.

The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the rules, and urge Ecology to strengthen the rule in the following ways:

Program design and Overburdened Communities: The statute is clear that the program should benefit overburdened communities and not cause environmental harm. Yet, the program rules do not clearly articulate how this will be achieved. This is a gap that should be filled, starting with the following changes:

– Clarify Ecology's role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs), regardless of when they become a covered entity, on overburdened communities;
– Establish an explicit review process for how the program is impacting overburdened communities and ensure Ecology has information required to conduct that review;
– Clarify Ecology's role in evaluating impact of linkage on overburdened communities and for achieving environmental benefits of program.

Information to build in review and accountability:

– Information to guide evaluation of impacts: Ecology should require all covered entities to provide information about their impacts to overburdened communities and to tribal lands and treaty rights, the chemicals and pollutants they process and/or manage, and if there are any violations under any permits they hold.
– Information to guide program review: Ecology should require gas and electric to provide information on how they spend any revenue from the sale of no cost allowances.
– Best available technology: Ecology should require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by the facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.
– Publicly disclose and document: Ecology should publicly share and document data being used to establish baseline information, subtotal baselines, and allocations.

Role of Environmental Justice Council: Per the statute, the Environmental Justice Council has an oversight role of the full program, including, but not limited to, linkage, protocols for offset projects and credits, designation of EITE industries, and administration of allowances. Yet the draft program rules do not provide adequate information to support this role or clarify Ecology's responsibilities for engaging with the Council. This is a gap that needs to be filled. The Council has the authority to determine its process for engagement with, and recommendations to, Ecology in this regard. This rule should be strengthened to:

– Include explicit language into the rule on how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.
– Track information about the environmental and health impacts of all EITE facilities to inform Council review.

Offsets:

– Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution, 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.
– Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.
– Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.

Tribal Treaty Rights:

– This rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes.

I look forward to Ecology's ongoing work to strengthen and finalize this rule as part of our state's work to meet our climate goals in an equitable and just way.

Thank you.
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Comment From: Logan Callen

6/30/22 @ 7:40 PM
Attachments:

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

6/30/22 @ 10:27 AM
Attachments:

Comment From: Jack Smith

6/29/22 @ 2:07 PM
As the government pursues collecting additional tax revenue and crafting more restrictive regulations, the residents of Washington deserve a moment of pause and consideration. As residents struggles with the highest inflation in more than 40 years, i...↓
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Comment From: Nikkole Hughes

6/27/22 @ 11:00 PM
Oh, good morning. My name is Nikkole Hughes. N-I-K-K-O-L-E H-U-G-H-E-S. And I'm here today on behalf of the Public Generating Pool, a trade association that represents 10 Washington consumer-owned utilities that own and operate generat-generating res...↓
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Comment From: Kjellen Belcher

6/27/22 @ 11:00 PM
Thank you. My name is Kjellen Belcher, spelled K-J-E-L-L-E-N B-E-L-C-H-E-R. And I'm commenting on behalf of Environmental Defense Fund. Thank you for the opportunity to comment on the proposed rules for the climate commitment acts cap and trade progr...↓
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Comment From: Anthony Wright

6/27/22 @ 11:00 PM
Um, actually Ed's letting me borrow his link. This is Anthony Wright, uh, city council, uh, for the City of Enumclaw. And my name is spelled A-N-T-H-O-N-Y W-R-I-G-H-T. Um, thank you for this, uh, this briefing and this opportunity to speak, um, as we...↓
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Comment From: Jacob Baughman

6/27/22 @ 11:00 PM
Thank you. My name's Jacob Baughman, J-A-C-O-B B-A-U-G-H-M-A-N. Uh, and I just have some brief comments to make. Uh, the current wording of the proposed rule dictates that non-utility-owned natural gas facilities are not automatically eligible for no...↓
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Comment From: Katie Fields

6/27/22 @ 11:00 PM
Thank you very much. My name is Katie Fields, spelled K-A-T-I E F-I-E-L-D-S. And I'm speaking on behalf of Washington Environmental Council. First off, I would like to thank Ecology for the opportunity to present comments. We appreciate all the work ...↓
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Comment From: Chance LaFleur

6/27/22 @ 11:00 PM
Chance LaFleur. City of Enumclaw City Council, C-H-A-N-C-E L-A-F- as in Frank, L-E-U-R. Um, thank you for the opportunity to speak. I appreciate being able to ad-advocate for our community's concern. I fear that this legislation and the subsequent Ec...↓
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Comment From: Robert Buckingham

6/27/22 @ 11:00 PM
Good morning. My name is Robert Buckingham, R-O-B-E-R-T, B-U-C-K-I-N-G-H-A-M. I am co-president of North Pacific Paper Company, NORPAC. And I'm speaking, uh, for the group today. We appreciate the opportunity to be here. We'd like to offer support an...↓
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Comment From: Rosemary Sweeney

6/27/22 @ 11:00 PM
Hi, my name is Rosemary Sweeney, uh, spelled R-O-S-E-M-A-R-Y S-W-E-E-N-E-Y. I'm testifying on behalf of myself. And, um, so, uh, in-in the informal questions I asked about, um, how the department was planning on ensuring that offsets were additional....↓
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Comment From: Monica Zazueta

6/27/22 @ 1:22 PM
Good afternoon Department of Ecology. I hope everyone is well. Thank you for the opportunity to comment on this critical rule that will shape how our state's cap & invest program will be implemented.

My name is Monica Zazueta and I am a concerned momm...↓

On June 12th I was on a zoom call with the director of Don't Look Up, Adam McKay. If you haven't seen it I highly recommend watching it, it's on Netflix. It tells the story of two astronomers attempting to warn humanity about an approaching comet that will destroy human civilization. The impact event is an aL-e-gory for climate change, and the film is a satire of government, political, celebrity, and media indifference to the climate crisis.

On that call also was Roger Hallam, he is a Welsh environmental activist, a co-founder of Extinction Rebellion, cooperative federation organisation Radical Routes and the political party Burning Pink and he received in his inbox on June 10th a conversation between the leading British scientist, Sir David king, one of the leading authors of the IPCC report and James Dyke, Rogers friend and James asked Sir David king,"so where do you think we are going to be by 2100?" And James was expecting to hear a political answer, well maybe this maybe that and Sir David king looks at him straight and says, "We're heading over 3° centigrade", and James says "we cannot get to their because that would mean the end of the coral reefs, that means no more amazon, and that means that so many people on the frontline are going to suffer because of the climate crisis, that's not going to happen is it?" And Sir David King said sadly "they are going to Die, billions of people are going to die."

I won't let that be the fate of my two boys and so many others, I just won't.

The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the rules, and urge Ecology to strengthen the Program design and Overburdened Communities part. The sta-choot is clear that the program should benefit overburdened communities and not cause environmental harm. Yet, the program rules do not clearly articulate how this will be achieved. This is a gap that should be filled, starting with the following changes:
1) Clarify Ecology's role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs), regardless of when they become a covered entity, on overburdened communities;
2) Establish an explicit review process for how the program is impacting overburdened communities and ensure Ecology has information required to conduct that review;
And 3) clarify Ecology's role in evaluating impact of linkage on overburdened communities and for achieving environmental benefits of program.

I look forward to Ecology's ongoing work to strengthen and finalize this rule as part of our state's work to meet our climate goals in an equitable and just way.

Thank you for all that you all do. I hope everyone's days are filled with laughter and love.

Thank you.
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Comment From: Stacey Valenzuela

6/26/22 @ 11:00 PM
Stacey Valenzuela, S-T-A-C-E-Y V-A-L-E-N-Z-U-E-L-A, from Kenmore. The residents and environmental organizations count on ecology to protect our resources, air, water, and land. To really make a difference we need to stop our biggest sources. We need ...↓
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Comment From: Eric Pace

6/26/22 @ 11:00 PM
Eric Pace, E-R-I-C P-A-C-E. Grays Harbor Energy Center is one of the cleanest and most efficient carbon-emitting power plants in the state. So it is ironic that the proposed legi-legislation in the Climate Commitment Act has the stated goal of reduci...↓
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Comment From: Louise Kulzer

6/26/22 @ 11:00 PM
Thank you. My name is Louise Kulzer, L-O-U-I-S-E K-U-L-Z as in Zorro-E-R. One of the goals of the Climate Commitment Act is that impacts to overburdened communities not be increased. Yet there are no criteria in the rule, uh, for identifying overburd...↓
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Comment From: Monica Zazueta

6/26/22 @ 11:00 PM
Hi, my name is Monica Zazueta, M-O-N-I-C-A Z as in zebra-A-Z as in zebra-U-E-T as in tiger-A. Um, so, um, let's-- Let me get it up. Good afternoon, Department of Ecology. I hope everyone is well. Thank you for the opportunity to comment on this criti...↓
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Comment From: Arvia Morris

6/26/22 @ 11:00 PM
Hi, my name is Arvia Morris, and, uh, that's A-R-V-I-A Morris. V as in victory. Morris, M-O-R-R-I-S. And I'd like to, uh, talk a little bit about my concerns about, um, the offset programs and, uh, forestry. Basically, forests cycle carbon. They aren...↓
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Comment From: Eric Strid

6/25/22 @ 7:49 AM
Attachments:

Comment From: Wolf Lichtenstein

6/21/22 @ 11:00 PM
Yes, this is Wolf Lichtenstein, L-I-C-H-T-E-N-S-T-E-I-N. I'm the proprietor of Evergreen Carbon, a Washington State registered company. Um, my-my comment is on the DEBs, the direct environmental benefit. Um, eh, the-the-the rule itself is not clear w...↓
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Comment From: Tom Fagerness

6/21/22 @ 2:21 PM
Attachments:

Comment From: Wade Phillips

6/21/22 @ 10:57 AM
Attachments:

Comment From: Chris Sherin

6/20/22 @ 11:00 PM
Good morning. This is Chris Sherin and it's C-H-R-I-S S-H-E-R-I-N. Uh, I'm the plant manager at Grays Harbor Energy Center located in Elma, Washington within the port of Grays Harbor sets up the business park. Grays Harbor Energy's an independent pow...↓
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Comment From: Torie Mielke

6/20/22 @ 11:00 PM
Hi, thank you. Uh, my name is Torie Mielke, uh, T-O-R-I-E M-I-E-L-K-E. Um, I actually also work for Gray Harbor Energy in Elma, and, uh, Chris, uh, covered just about anything I would also like to cover. Um, I just want to reiterate that, uh, as the ...↓
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Comment From: Stephen Smith

6/20/22 @ 11:00 PM
Thank you. Stephen Smith. Uh, I'm with Phillips 66 company. Uh, my comment today would be I recommend, we recommend as Phillips 66, that as Washington ecology completes its program baseline, that they make that information public for the, uh, detail ...↓
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Comment From: Ross Hamilton

6/20/22 @ 11:00 PM
All right. My name is Ross Hamilton, uh, spelled R-O-S-S H-A-M-I-L-T-O-N. Uh, I also work at Grays Harbor Energy. I'm a lead control room operator here and, uh, not to beat a dead horse on Grays Harbor Energy, but, uh, I just wanted to reiterate some...↓
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Comment From: Heidi Cody

6/20/22 @ 10:56 AM
Attachments:

Comment From: Alex Fay

6/20/22 @ 6:47 AM
My name is Alex, and I am a constituent.

Thank you for the opportunity to comment on this critical rule that will shape how our state's cap & invest program will be implemented. The Climate Commitment Act is the strongest carbon pricing program in the...↓

I care about this because we need swift action to address the climate crisis and protect our most vulnerable people.

The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the rules, and urge Ecology to strengthen the rule in the following ways:

Program design and Overburdened Communities: The statute is clear that the program should benefit overburdened communities and not cause environmental harm. Yet, the program rules do not clearly articulate how this will be achieved. This is a gap that should be filled, starting with the following changes:

– Clarify Ecology's role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs), regardless of when they become a covered entity, on overburdened communities;
– Establish an explicit review process for how the program is impacting overburdened communities and ensure Ecology has information required to conduct that review;
– Clarify Ecology's role in evaluating impact of linkage on overburdened communities and for achieving environmental benefits of program.

Information to build in review and accountability:

– Information to guide evaluation of impacts: Ecology should require all covered entities to provide information about their impacts to overburdened communities and to tribal lands and treaty rights, the chemicals and pollutants they process and/or manage, and if there are any violations under any permits they hold.
– Information to guide program review: Ecology should require gas and electric to provide information on how they spend any revenue from the sale of no cost allowances.
– Best available technology: Ecology should require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by the facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.
– Publicly disclose and document: Ecology should publicly share and document data being used to establish baseline information, subtotal baselines, and allocations.

Role of Environmental Justice Council: Per the statute, the Environmental Justice Council has an oversight role of the full program, including, but not limited to, linkage, protocols for offset projects and credits, designation of EITE industries, and administration of allowances. Yet the draft program rules do not provide adequate information to support this role or clarify Ecology's responsibilities for engaging with the Council. This is a gap that needs to be filled. The Council has the authority to determine its process for engagement with, and recommendations to, Ecology in this regard. This rule should be strengthened to:

– Include explicit language into the rule on how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.
– Track information about the environmental and health impacts of all EITE facilities to inform Council review.

Offsets:

– Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution, 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.
– Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.
– Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.

Tribal Treaty Rights:

– This rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes.

I look forward to Ecology's ongoing work to strengthen and finalize this rule as part of our state's work to meet our climate goals in an equitable and just way.

Thank you,
Alex
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Comment From: Ed Chadd

6/18/22 @ 8:25 AM
Please do all possible to avoid the regulatory pitfalls of California's cap and trade law. Please listen to this in-depth analysis by Professor Danny Cullenward about the strengths and pitfalls of California's rulemaking and implementation to date: h...↓
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Comment From: Jennifer Valentine

6/17/22 @ 11:35 AM
Thank you for the opportunity to comment on this critical rule that will shape how our state's cap & invest program will be implemented. The Climate Commitment Act is the strongest carbon pricing program in the US, and we are excited about the opport...↓

I care about this because a healthy environment is necessary to all living creatures.

The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the rules, and urge Ecology to strengthen the rule in the following ways:

Program design and Overburdened Communities: The statute is clear that the program should benefit overburdened communities and not cause environmental harm. Yet, the program rules do not clearly articulate how this will be achieved. This is a gap that should be filled, starting with the following changes:

– Clarify Ecology's role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs), regardless of when they become a covered entity, on overburdened communities;
– Establish an explicit review process for how the program is impacting overburdened communities and ensure Ecology has information required to conduct that review;
– Clarify Ecology's role in evaluating impact of linkage on overburdened communities and for achieving environmental benefits of program.

Information to build in review and accountability:

– Information to guide evaluation of impacts: Ecology should require all covered entities to provide information about their impacts to overburdened communities and to tribal lands and treaty rights, the chemicals and pollutants they process and/or manage, and if there are any violations under any permits they hold.
– Information to guide program review: Ecology should require gas and electric to provide information on how they spend any revenue from the sale of no cost allowances.
– Best available technology: Ecology should require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by the facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.
– Publicly disclose and document: Ecology should publicly share and document data being used to establish baseline information, subtotal baselines, and allocations.

Role of Environmental Justice Council: Per the statute, the Environmental Justice Council has an oversight role of the full program, including, but not limited to, linkage, protocols for offset projects and credits, designation of EITE industries, and administration of allowances. Yet the draft program rules do not provide adequate information to support this role or clarify Ecology's responsibilities for engaging with the Council. This is a gap that needs to be filled. The Council has the authority to determine its process for engagement with, and recommendations to, Ecology in this regard. This rule should be strengthened to:

– Include explicit language into the rule on how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.
– Track information about the environmental and health impacts of all EITE facilities to inform Council review.

Offsets:

– Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution, 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.
– Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.
– Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.

Tribal Treaty Rights:

– This rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes.

I look forward to Ecology's ongoing work to strengthen and finalize this rule as part of our state's work to meet our climate goals in an equitable and just way.

Thank you.
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Comment From: Donna Shahbazi

6/12/22 @ 10:20 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act. This rule
supports new investments in climate resiliency programs, clean transportation, and addresses health disparities across the state.
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Comment From: Sherry Martin

6/10/22 @ 12:22 PM
We simply cannot afford anymore taxes! Someone has to be the adult in the room and say NO! This does absolutely nothing for the environment and will only continue to take money from Washington families.
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Comment From: Phil Martin

6/10/22 @ 10:07 AM
This truly a bad policy and we cannot afford anymore taxes imposed on us. Your cap and trade scheme should be marked more as a pyramid scheme where the environment sees nothing and government takes all. This punishes rural folks and offers nothing in...↓
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Comment From: Terry Hatton

6/08/22 @ 2:49 PM
The entirety of this "cap and trade" program is 100 percent ridiculous.
This rule only forces Washington State residents to pay the price for emissions released from overseas countries. You get China, India and Russia to conform to these regulations t...↓
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Comment From: Judy Olmstead

6/06/22 @ 2:49 PM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act. With the looming climate crisis, we must step up to the plate NOW. Chapter 173-446 WAC, Climate Commitment Act Program is a good step in this direction.
The best cl...↓
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Comment From: Christine Wells

6/06/22 @ 11:26 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act.

The climate crisis is upon us, and we need immediate action.

I love that the Climate Commitment Act includes provisions to promote environmental justice and equity. ...↓
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Comment From: Melinda Holman

6/06/22 @ 11:24 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act.
We are facing a climate crisis and must start making changes. We MUST do this for our future generations. The Climate Commitment Act includes provisions to promote e...↓
Melinda Holman
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Comment From: Glen Hubbard

6/06/22 @ 11:24 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act. Time is running out for the planet.
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Comment From: Katherine Package

6/06/22 @ 11:23 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act.

We are facing a climate crisis and must start making changes.

Chapter 173-446 WAC, Climate Commitment Act Program provides meaningful emissions allowance budgets.

The ...↓

The best climate policy — environmentally and economically — limits emissions and puts a price on them. Cap and invest is one way to do both.

Cap and invest encourages aggressive climate change goals. We need a path to meet the greenhouse gas emission limits set in state law.

This rule supports new investments in climate resiliency programs, clean transportation, and address health disparities across the state.
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Comment From: Kim Murillo

6/06/22 @ 11:23 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act for my childrens' children and their children
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Comment From: Lisa Ornstein

6/06/22 @ 11:21 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act. This rule supports new investments in climate resiliency programs, clean transportation, and address health disparities across the state.
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Comment From: Garrett Tatsumi

6/06/22 @ 10:19 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act. We need a path to meet the greenhouse gas emission limits set in state law. This rule supports new investments in climate resiliency programs, clean transportation...↓
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Comment From: Robyn Chance

6/06/22 @ 7:01 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act. We are facing a climate crisis and must start making changes in order to combat the rising costs to ourselves, our environment and our economic security. A good pla...↓
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Comment From: Michael Foster

6/04/22 @ 5:27 PM
Solastalgia, the psychological devastation on witnessing the destruction or loss forever of one's place in the world, home.

You have earned my congratulations on a really well-conceived design for a plan to alter business-as-usual, reducing emissions ...↓

My family sued the Dept of Ecology resulting in the Clean Air Rule being hastily proposed. Remember that? Do kids have rights to live here in Washington, and if so, does Washington government have responsibility to end the wholesale foreclosure on their lives before we pollute too much for them? The judge said Yes, three times. Take emergency action now (2015) to reduce emissions by the amount scientists determine is necessary to get Earth back below the red line, 350ppm (the max level under which governable societies and living things evolved in the Holocene), or risk destroying the "essential resources - air land and water - which these children will require to grow to adulthood safely." The draft Clean Air Rule gave Inslee and Ecology a win, no court oversight of a climate champion on the job. Washington residents under 18 have no right to vote, but will now lose everything in their lifetime - civilization, habitable lands, food, trees, governable society - due to the government's willful refusal to restrict destruction in time. Willful ignorance to betray the entire generation of our young and all living things that might come.

Back then, to act in time would have required 6 - 10% emission cuts (or caps) each year going forward statewide. Impossible? Or the minimum necessary to govern a living Washington state into 2100?

7 years later...

Your cap needs to drop each year 25% or faster, or else we all go bust. But we can't you say, too expensive! Costs, inflation! Green economics on a dead planet. You won't listen to me, or to the science. There will be no living planet. All the research is plain: no new anything, drop what you're doing, or else we fly past the point of no return for all time. Centuries of chaos, war, murder, starvation, and finally death, so that we can visit Yellowstone, fly to Hawaii or cruise to Alaska with grandma and the kids, one more time. Then the gas-fueled wheels come off for real, whether we act now or not. Very soon yes, but not soon enough to keep life going. Today only you can do that. Today.

Life in the last half of this century will appear unrecognizable to people today.

By 2100, what's left of Life will get better only if you deliver unprecedented mandates -- mandates like lockdowns in March 2020 -- to stop everything "non-essential" immediately. Then we convince others to follow suit or bust. That's scientific reality meets political impossibility. We living things suffer forever if you delay longer using proposed pollution permits.

Climate wonks say Washington state can't save the world, our emissions are too small to matter. Look at Denmark. If we want to live, we do what we know massive polluters refuse to do. We cut off everything today if we mean to influence regulatory action in time. What else can we do in 2022, when there is zero carbon budget left? We already burned up the bridge to life below 1.5C didn't we? And 350ppm in a century. But that's the red line. Below 350ppm most life might live.

You pretend you make a difference. Doing only half what is required, years too late, and being a "leader" sets an "example" for others to emulate and greenwash our date with oblivion. Knowing what needs to be done to survive, and refusing to tell people, is worse, billions of times worse, than being an active shooter in an elementary school. Ecology is pulling the trigger against all life in Washington state today.

I know you will not do it. I know.

2 of every 3 living creatures on the planet are now gone, since I started grade school in 1970, the dawn of environmental action.

You will not cap it in time. Voters, consumers, job-creators, the people, won't accept it.

Globally, 95% of endemic species now face extinction this century. You ignore the alarm.

Doug fir babies will not be able to grow to maturity in 50 years. You cut trees much faster than CO2.
1 in 6 deaths worldwide is from air pollution. You give out polluter permits.

1 billion refugees forced from their homelands, flooding northward into places like Washington, in the next 50 years. You refuse to plug the gap in time.

The Dept. of Ecology offices will sink under the ocean long before anyone there takes responsibility for any of this.

It's not your job, am I right?

But if not yours, whose job is telling us the true emergency so we can protect ourselves, as during COVID-19? To point the way to life from death? To say how quickly people must drop everything and go, to stay alive? Look at wildfires approaching people's homes. People won't go until they know it's do or die time.

Your cap-and-invest plan creates a plausible diversion so that people can keep going to work at Boeing, sleeping easy at night, growing the business, flying around the world for selfies, wondering if the government is going to do anything in time or not.

I'm sorry our lawsuit didn't inspire leaders to act in earnest, in collaboration with courts, to do what is both scientifically required and politically lethal: cap emissions fast enough for residents to survive in Washington. Stop us.

The attached chart shows more graphically there is no other time, no chance to get it right, later, in another year or two. Only suffering, the loss of home. For all.

Do the impossible. Make the courts shoot you down. Give other governments the chance to follow your example. You have no choice. Shrug and all the rest is darkness.
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Comment From: Association Washington Busines...

6/03/22 @ 2:00 PM
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Comment From: Anonymous Anonymous

6/02/22 @ 8:59 PM
This program will make all electricity bills go up because the people that pay their bills are putting money into crap funds such as listed - "including dedicating a minimum of 35% of funds toward overburdened communities and a minimum of 10% toward ...↓
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Comment From: Byron Adams

6/02/22 @ 5:46 AM
I want to see investment into nuclear energy production or carbon capture. Why are we investing so significantly into climate change when the likes of China far out weigh our own. China will surpass the US in a few years with no signs of stopping.

I c...↓

I personally don't like this program as I believe it will make us less competitive in the global economy.
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Comment From: christy bear

6/01/22 @ 11:15 AM
I support the new cap-and-invest rule needed to implement the Climate Commitment Act.

We are facing an extreme climate crisis and must start making changes before it's too late. The best climate policy — environmentally and economically — limits emiss...↓
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Comment From: Anonymous Anonymous

5/31/22 @ 11:26 AM
Finally, WA is trying to catch up with the rest of the world. Happy to see this.
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Comment From: Maureen Canny

5/31/22 @ 9:25 AM
Dear Dept. of Ecology,
As we face the climate crisis and we must make changes, I support the new cap-and-invest rule needed to implement the Climate Commitment Act. This rule supports encourages investment in our collective future.
Thank you.
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Comment From: Jeanne Poirier

5/30/22 @ 11:46 AM
Honestly, I don't hold much faith in the CCA - especially with rule making. Good luck figuring out compliance and really bringing down carbon quickly.
Listen to the Environmental Justice Committee and uplift their voice in all decisions with CCA.
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Comment From: Ira Astrachan

5/27/22 @ 10:02 AM
The entirety of this "cap and trade" program is 100 percent ridiculous. You plan to make "greenhouse gas" producers pay a fee for "emission allowances", essentially charging a business a fee to operate. Ridiculous how? Firstly, "Climate Change" is...↓
Have you decided what a "greenhouse gas" is? Have you proven it? Have you defined it?

You then pledge to take these fees and use them to "reduce emissions". How does money reduce emissions? Please be specific. The problem with government fees that are allocated to feel-good projects is the vagueness in the verbiage. It's just a money grab for Washington government to add to their surplus pile of money. You also pledge to use these fees to "support disproportionally affected communities". How do you define that? Affected by what? Are you saying smog only affects people who live in these "communities" because smog is smart enough to rain down on them and then alone? THIS is ridiculous. Emissions affect ALL communities, don't fool yourself or the public. You also claim the fees will be used to "build climate resiliency" without defining that. What exactly is "climate resiliency"? For me, it's an umbrella and a warm coat.

The lack of specifics in this bill are the icing on the Ridiculous Cake that it is.
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Comment From: Lane Seeley

5/25/22 @ 2:01 PM
The Climate Commitment Act is projected to result in price increases for lower income families in Washington State. In some cases, such as natural gas customers, there may be refunds paid to these families that will offset some price increases. I hav...↓
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Comment From: Daniel Schneider

5/24/22 @ 1:01 PM
I'd like to see all the revenue from the cap and trade program go directly to lowering/offsetting cost for clean energy to lower and middle class citizens as well as subsidizing clean energy projects in Washington rather than into the general fund.
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Comment From: Talis Abolins

5/24/22 @ 7:24 AM
I support the roll out of this carbon tax program. It did not come soon enough. With proper implementation, this may be one of the most successful ways to address climate change, and the Vancouver British Columbia experience is evidence of this. Don'...↓
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Comment From: WEST STAR CONSTRUCTION OF SPOK... (JACQUELINE ETTER)

5/22/22 @ 3:26 PM
It appears that the emissions allowances and carbon costs are directed at energy producers and high emitting industries which will then pass the costs on to their customers.

How can lower tier companies who are proactive about reducing their pollution...↓

In essence, how can regular companies who modify their practices to significantly produce less carbon be incentivized to do so instead of being penalized by higher costs from the energy suppliers.

This is very important.
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Comment From: Rodney Fosback

5/22/22 @ 3:09 PM
This rule only forces Washington State residents to pay the price for emissions released from overseas countries. You get China, India and Russia to conform to these regulations then we'll talk, but then these regulations won't be needed. Meanwhile...↓
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Comment From: Fiona Sheehan

5/21/22 @ 6:35 PM
This comment is being submitted for a class.

WAC 173-446-335, otherwise known as the Climate Commitment Act, is being implemented next year to help Washington achieve its 2050 emissions reduction goals. The basic framework of this carbon trading progr...↓
Lawmakers should seriously consider the ethical implications in greater detail before passing such a bill. Several local environmental justice groups, including GotGreen and Puget Sound Sage, have made it known that they take issue with the potential harm this legislation could wreck in their communities. While the allowances part of the law enables corporations to buy the rights to continue to pollute (which may not be enough of a motivator to change for some), having offsets as part of the pollution trading market, even if it is less than 5% in some cases, perpetuates environmental injustices in communities where extractive offset projects are located. Additionally, tying community investments to the market mechanisms doesn't uplift economic self-determination for communities. Vulnerable communities need a voice. Community self-determination and wealth redistribution should be the cornerstone of any policy that purports to support environmental justice. It's easy to remember: by and for the community.

Sources:
https://ecology.wa.gov/Air-Climate/Climate-change/Reducing-greenhouse-gases/Climate-Commitment-Act
https://www.pugetsoundsage.org/opposing-cap-and-trade/
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Comment From: Charles Bagley

5/18/22 @ 4:06 PM
This excellent law has been well developed out by Ecology and its consultants.

I strongly support the proposed rules.
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Comment From: Steffen Coenen

5/18/22 @ 11:40 AM
In order to develop a realistic pathway towards achieving the carbon (and, more broadly, GHG) emission reduction targets set out by WA, the auction floor and ceiling prices for carbon emission allowances laid out in WAC 173-446-335 of the proposed pr...↓

There has been plenty of research and practical evidence assessing the true environmental and social costs of carbon emissions, resulting in values starting at around $50 (see, for example, https://www.edf.org/true-cost-carbon-pollution). Most experts agree that the true costs of carbon pollution are substantially higher. The document attached to this comment prepared by the EPA back in 2016 lists carbon prices ranging from $14 (lower limit) through $138 (for high impact) for 2025 in 2007 dollars (meaning that these values need to be adjusted for inflation, resulting in values ranging from $19.52 to $192.42 for 2025, according to https://www.usinflationcalculator.com/). The United States and WA state commit to the Paris Agreement and, explicitly, the 1.5 °C target (see https://www.whitehouse.gov/briefing-room/statements-releases/2021/11/13/fact-sheet-renewed-u-s-leadership-in-glasgow-raises-ambition-to-tackle-climate-crisis/ and https://www.seattletimes.com/seattle-news/washington-politicians-promote-state-climate-laws-at-glasgow-un-summit/, respectively). To have any chance of reaching these goals, the lower limit estimates on carbon prices will not suffice: In Chapter 2 of its 2018 Special Report on Global Warming of 1.5 °C (https://www.ipcc.ch/sr15/chapter/chapter-2/), the IPCC outlines carbon pricing figures necessary to achieve the 1.5 °C limit, with specific estimates of no less than $50, the majority of the estimates beginning at arond $120, and the median of all estimates at more than $400 (see e.g. Figure 2.26 of the report). Below such figures, the goal of staying within the total carbon emission budget available for the 1.5 degree limit is unattainable.

This enourmous discrepancy between the proposed floor and ceiling price for carbon auctions laid out in WAC 173-446-335 and the carbon prices found by an astounding amount of research and evidence signifies the strong and urgent need to readjust both the auction floor and ceiling prices in the proposed program rules. A doubling of both the lower and upper limit would be the minimum increase necessary for the carbon emission allowancs in WA to develop a steering effect away from carbon-emitting industries and processes. Higher increases would be required to keep WA on a pathway in line with the carbon emission budget associated with the 1.5 degree limit.


Note: As per common practice and in line with the units in the proposed program rules, all carbon prices refered to in this comment are in units of $/metric ton of CO2-eq. emission.
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Comment From: Duane Goehner

5/18/22 @ 9:20 AM
Unfortunately I cannot support this proposal. The DoE has instituted so much regulation in the past years, but not been consistent on enforcement. Case in point, we have had significant stormwater failure in Leavenworth, and have repeatedly attempt...↓
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Comment From: Marcy Anholt

5/18/22 @ 5:37 AM
I think the Chapter 173-443 WAC climate commitment Act is an excellent opportunity to change the trajectory of our continuing warming and reinvest in our state's ability to mitigate the devastating effects of the negative impacts of climate change.
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Comment From: Kim Jordan

5/18/22 @ 3:53 AM
This will basically create a tax on businesses that you determine are polluting the environment.
1. This will create price hikes for consumers in an inflated economy.
2. If your plan works your funding will be nothing and then where will your funding c...↓
3. This is a political attempt to garner more votes by making people 'feel' better.
4. Let's get money from China and other countries that have far worse pollution than we do.
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