Rulemaking - Chapter 173-446 WAC, Climate Commitment Act Program
Dear Mr. Grice,
Thank you for the opportunity to comment on WAC-173-446, Climate Commitment Act (CCA) Program Rule. I appreciate the hard work the Department of Ecology has been doing to implement the CCA.
However, I have concerns related to the follow...↓
Environmental Justice Council
The timeline for implementing the CCA does not allow the Governor's newly formed Equity and Justice Council (EJC) adequate time to understand the CCA program, or its social and environmental context. The draft program rules should define how Ecology will engage with and support the EJC in the development, implementation, and evaluation of the full program.
Ecology needs to define when and how they will provide the EJC details about the CCA program, including:
Air-quality monitoring program data, especially data related to emissions-intensive, trade-exposed (EITE)-adjacent, overburdened communities;
How pollution allowances will be administered to ensure overall declining greenhouse gas (GHG) emissions under the cap, the appropriate amount of revenue generation from auction activity, and the overall health and integrity of the cap and invest program;
Criteria for the selection of offset protocols, including risks and benefits, and how the definition of adverse impacts relates to the rule definition of "environmental harm";
What decisions will be needed to facilitate linkage with other pollution reduction programs, as well as the predicted or possible downstream consequences of those decisions.
Honoring Tribal Sovereignty
The program rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes. In particular, it is critical that offset protocols are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.
Pollution Allowances
Ecology's responsibility to provide oversight and review of the allocation of allowances for Emission Intensive Trade-Exposed polluters should be strengthened and clarified to provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no-cost allowances. Ecology should engage with the Utilities and Transportation Commission on its regulation of investor-owned utilities' use of the value of no cost allowances.
Offsets
Offsets are inherently flawed, allowing polluters to continue polluting. It is important that the program rule establishes a process to evaluate the impact of offsets and the effectiveness of the offsets program over time.
The rule should include language allowing for adaptation and adoption of new protocols moving forward, post-rulemaking, including:
Updating existing offset protocols based on lessons learned in California, such as evolving California's urban forestry offset protocol (which has never been feasible to use).
Adopting new offset protocols to harness other natural climate solutions in Washington state, e.g., blue carbon and agriculture.
Ecology's proposed adoption of California's forestry protocol is premature. CARB - US Forestry should not be adopted as-is.
The CARB - US Forestry protocol doesn't adequately account for leakage (logging occurring elsewhere because of avoided logging prompted by a protocol offset).
A 2019 study found that 82% of the credits issued under CARB - US Forestry likely do not represent true emissions reductions due to the protocol's use of lenient leakage accounting methods.
The CARB - US Forestry protocol also lacks genuine additionality, that is, credits are being issued for forests that were not actually going to be harvested, or that the carbon sequestration benefits of specific offsets were overestimated. A 2021 study showed that ecological and statistical flaws in California's offsets program create incentives to generate credits that do not reflect real climate benefits.
Washington State should not adopt the CARB - US Forestry protocol until these shortcomings are addressed.
Industrial forestry
Logging is the number one source of emissions in OR, and estimated to be third in WA. Emissions have been underestimated by up to 55% in Oregon and 25% in Washington, and as of 2019, these emissions were not reported in state GHG reporting guidelines.
Yet CARB - US Forestry favors industrial logging practices. Such practices produce significant carbon emissions, from soil compaction as well as machinery operations. It takes decades for clear cut forests to return to a natural state that adequately supports diverse habitats. And so called plantation "working forests" do not provide anything close to natural habitat or biodiversity.
To be most effective, any forestry offset protocol used by Washington State should reward the avoidance of industrial forest practices, incentivize longer harvest rotations, and prioritize the protection of old growth and mature forests.
Washington should also avoid decoupling carbon storage from overall forest health. In New Zealand, high carbon prices have incentivized dense plantations of non-native, short-lived trees such as radiata pine that offer poor habitat and can displace native forests.
Wood products
CARB - US Forestry credits the storage of carbon in wood products, even though they store far less carbon than forests. However some estimates have only 15% of a log's carbon ending up in a wood product; the rest becomes carbon emissions. Crediting carbon storage in wood products encourages increased harvests and shorter rotations, both of which are counterproductive to Washington's climate goals.
As 200 forest and climate scientists told Congress in June 2020: "We find no scientific evidence to support increased logging to store more carbon in wood products, such as dimensional lumber or cross-laminated timber (CLT) for tall buildings, as a natural climate solution."
Aggregation
2.88 million acres of forestland in Washington State were owned by small forest landowners in 2019. Any forestry offset protocol implemented under the Climate Commitment Act should provide mechanisms to enable landowners who would otherwise face barriers to participation in carbon offsets to aggregate their offset offerings�particularly Tribal Nations and small forest landowners�in order to maximize benefits to local communities, tribes, and land owners of all sizes.
California's buffer pools
Forest offset protocols call for "buffer pools" to attempt to account for the fact that some of the carbon presumed stored in the forest will end up being released by wildfire. Recent analysis has indicated that the quantity of trees that California has set aside may be inadequate compared to the risks the state faces from increased mega fires. California's "buffer pool" must be evaluated before Washington State links with California's cap and trade program.
Thank you for considering my concerns. Ahnna Weber
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Dear Mr. Grice,
Thank you for the opportunity to comment on WAC-173-446, Climate Commitment Act (CCA) Program Rule. I appreciate the hard work the Department of Ecology has been doing to implement the CCA.
However, As a resident of the Olympic Peninsul...↓a, I have concerns related to the following areas of the draft program rule.
Environmental Justice Council
The timeline for implementing the CCA does not allow the Governor's newly formed Equity and Justice Council (EJC) adequate time to understand the CCA program, or its social and environmental context. The draft program rules should define how Ecology will engage with and support the EJC in the development, implementation, and evaluation of the full program.
Ecology needs to define when and how they will provide the EJC details about the CCA program, including:
Air-quality monitoring program data, especially data related to emissions-intensive, trade-exposed (EITE)-adjacent, overburdened communities;
How pollution allowances will be administered to ensure overall declining greenhouse gas (GHG) emissions under the cap, the appropriate amount of revenue generation from auction activity, and the overall health and integrity of the cap and invest program;
Criteria for the selection of offset protocols, including risks and benefits, and how the definition of adverse impacts relates to the rule definition of "environmental harm";
What decisions will be needed to facilitate linkage with other pollution reduction programs, as well as the predicted or possible downstream consequences of those decisions.Do we need alternative ways of determining state funding for local education?
Honoring Tribal Sovereignty
The program rule must explicitly incorporate Ecology's existing obligation to proactively engage and consult with federally recognized tribes. In particular, it is critical that offset protocols are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty. We have several active tribes in this area.
Pollution Allowances
Ecology's responsibility to provide oversight and review of the allocation of allowances for Emission Intensive Trade-Exposed polluters should be strengthened and clarified to provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no-cost allowances. Ecology should engage with the Utilities and Transportation Commission on its regulation of investor-owned utilities' use of the value of no cost allowances.
Offsets
Offsets are inherently flawed, allowing polluters to continue polluting. It is important that the program rule establishes a process to evaluate the impact of offsets and the effectiveness of the offsets program over time.
The rule should include language allowing for adaptation and adoption of new protocols moving forward, post-rulemaking, including:
Updating existing offset protocols based on lessons learned in California, such as evolving California's urban forestry offset protocol (which has never been feasible to use).
Adopting new offset protocols to harness other natural climate solutions in Washington state, e.g., blue carbon and agriculture.
Ecology's proposed adoption of California's forestry protocol is premature. CARB - US Forestry should not be adopted as-is.
The CARB - US Forestry protocol doesn't adequately account for leakage (logging occurring elsewhere because of avoided logging prompted by a protocol offset).
A 2019 study found that 82% of the credits issued under CARB - US Forestry likely do not represent true emissions reductions due to the protocol's use of lenient leakage accounting methods.
The CARB - US Forestry protocol also lacks genuine additionality, that is, credits are being issued for forests that were not actually going to be harvested, or that the carbon sequestration benefits of specific offsets were overestimated. A 2021 study showed that ecological and statistical flaws in California's offsets program create incentives to generate credits that do not reflect real climate benefits.
Washington State should not adopt the CARB - US Forestry protocol until these shortcomings are addressed.
Industrial forestry
Logging is the number one source of emissions in OR, and estimated to be third in WA. Emissions have been underestimated by up to 55% in Oregon and 25% in Washington, and as of 2019, these emissions were not reported in state GHG reporting guidelines.
Yet CARB - US Forestry favors industrial logging practices. Such practices produce significant carbon emissions, from soil compaction as well as machinery operations. It takes decades for clear cut forests to return to a natural state that adequately supports diverse habitats. And so called plantation "working forests" do not provide anything close to natural habitat or biodiversity.
To be most effective, any forestry offset protocol used by Washington State should reward the avoidance of industrial forest practices, incentivize longer harvest rotations, and prioritize the protection of old growth and mature forests.
Washington should also avoid decoupling carbon storage from overall forest health. In New Zealand, high carbon prices have incentivized dense plantations of non-native, short-lived trees such as radiata pine that offer poor habitat and can displace native forests.
Wood products
CARB - US Forestry credits the storage of carbon in wood products, even though they store far less carbon than forests. However some estimates have only 15% of a log's carbon ending up in a wood product; the rest becomes carbon emissions. Crediting carbon storage in wood products encourages increased harvests and shorter rotations, both of which are counterproductive to Washington's climate goals.
As 200 forest and climate scientists told Congress in June 2020: "We find no scientific evidence to support increased logging to store more carbon in wood products, such as dimensional lumber or cross-laminated timber (CLT) for tall buildings, as a natural climate solution."
Aggregation
2.88 million acres of forestland in Washington State were owned by small forest landowners in 2019. Any forestry offset protocol implemented under the Climate Commitment Act should provide mechanisms to enable landowners who would otherwise face barriers to participation in carbon offsets to aggregate their offset offerings�particularly Tribal Nations and small forest landowners�in order to maximize benefits to local communities, tribes, and land owners of all sizes.
California's buffer pools
Forest offset protocols call for "buffer pools" to attempt to account for the fact that some of the carbon presumed stored in the forest will end up being released by wildfire. Recent analysis has indicated that the quantity of trees that California has set aside may be inadequate compared to the risks the state faces from increased mega fires. California's "buffer pool" must be evaluated before Washington State links with California's cap and trade program.
Thank you for considering my concerns,
Pamela Hastings, Port Angeles, WA
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As a voter, a Grandmother and a Retired Nurse, I ask for the strictest possible regulations to assure that our environment for all future generations will be safe. There is no downside in protecting the public from pollution. People can and must find...↓ clean jobs eventually. Why not now?
Thank-you.
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I am writing in support of strong rules to acheive the Climate Committment Act's goal of significantly reducing carbon emissions from our state. Like most Washingtonians, I have been personally affected by heat waves, severe fire seasons, and other e...↓xtreme weather events over the last few years. I believe implementation of the CCA must include a firm cap on emissions that polluters are not allowed to surpass. I also believe funds raised from the cap-and-trade program should prioritize helping low-income communities make the transition to clean energy. Together, we can make Washington a leader on climate action that sets the standard for other states to follow.
Thank you for your time and consideration.
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July 15, 2022 Joshua Grice Rulemaking Lead Department of Ecology Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600
Dear Mr. Grice, As the registered contract lobbyist of the Snoqualmie Indian Tribe and the Senior Adviser to its Tribal Counci...↓l, please accept this comment letter on the proposed rulemaking process for the Climate Commitment Act. I was a prime policy author of this legislation building off of my experience both in Indian Country and my four years as the Senior Adviser to the Commissioner of Public Lands, and its effective implementation is the highest priority item on the Snoqualmie Indian Tribe’s agenda with Washington State. This letter in no way takes the place of formal consultation with the elected Tribal government, nor should it be construed to limit the Tribe’s access to other sources of engagement or remedy with the State. The Tribe reserves and retains all rights to pursue every available opportunity to support the efficacy and success of this all-important legislation. The Snoqualmie Tribe also wishes to recognize and support DOE's careful consideration of the comment letters provided by NGO allies and policy authorities at the Nature Conservancy and Global Ocean Health. Comments on Proposed WAC 173-446 Given the Snoqualmie Tribe’s sovereign rights and entitlement to separate government-to-government consultation, I will keep our comments in this context general and high-level. We would be happy to engage more fulsomely at a mutually acceptable time.
1) Tribal Consultation and Cultural Resource Sites : The Climate Commitment Act was passed utilizing the power of a coalition of nineteen Tribal Nations across Washington State whom the prime legislative sponsors publicly acknowledged as the decisive influence on the bill’s passage. This coalition negotiated explicit consultation language that protected Tribal cultural resource sites, sacred sites, and archeological sites with language that required consent of the impacted Tribal Nation instead of consultation. This was not a request but a nonnegotiable demand that determined Snoqualmie’s support for the legislation. Governor Inslee’s targeted veto of this provision has created immense distrust within the leadership of the Snoqualmie Indian Tribe for DOE’s impartial implementation of this bill. In the aftermath of his veto, Governor Inslee specifically insulted Tribal opponents by saying they were not led by “real Tribal leaders.” This discriminatory, prejudiced, and offensive language has called into question whether DOE will implement this legislation impartially and without favoritism to Inslee’s preferred “real Tribal leaders.” For this reason, the Snoqualmie Indian Tribe demands far clearer rulemaking expectations laying out how DOE will actually consult with Tribes on this legislation, as well as what provisions it will take to ensure the full fairness, impartiality, and transparency of the implementation of this bill. The Tribe will be fully prepared to take any necessary step to ensure this fundamental fairness expectation is fulfilled. Likewise, the Snoqualmie Indian Tribe has been the subject of targeted discrimination by governments who confuse the universal requirement to consult with sovereign Tribal Nations with the very specific and narrow adjudicated treaty rights around fishing that are held by some Tribes. Treaties did not create a consultation caste system, and the Tribe expects DOE will not take any step that perpetuates this discriminatory narrative. Unless the question pertains to treaty fishing rights, there is absolutely no other legal or policy reason that “treaty rights” should be invoked in the implementation of this legislation. If “treaty rights” language is included inappropriately, it is a calculated insult to all Tribes – who it is inferred receive their right to consultation from any piece of paper issued by the United States federal government. That right is a fundamental aspect of sovereignty, which Tribes have always had and will always have. As with above, the Tribe will be fully prepared to take any necessary step to ensure this fundamental fairness expectation is fulfilled. Lastly, the Tribe will eagerly await language around sacred sites, archeological sites, and cultural resource sites that will address the considerable concern around these irreplaceable heritage areas.
2) Waiver of Sovereign Immunity : The California system that DOE is apparently appropriating for a large segment of the rulemaking of the CCA has a fatal flaw: the requirement for waivers of sovereign immunity for Tribes to receive resources. This expectation would immediately doom the implementation of the CCA in Washington State – the Snoqualmie Tribe, and the vast majority of WA Tribes, will not accept any requirement to sign a waiver of sovereign immunity in order to receive resources they are entitled to by law. The Snoqualmie Tribe requests explicit acknowledgment that no waiver of sovereign immunity will be included in any and all rules pertaining to the CCA.
3) Environmental Justice Council: RCW 70A.65.040 lays out explicit and specific expectations that Ecology and the Legislature will receive recommendations from the Environmental Justice Council (EJC). It is our understanding that the EJC has not been fully integrated and consulted in this process, and we believe this is inconsistent with the intent of the Legislation and the Tribe’s understanding of the language it negotiated and co-authored. At every step of this process the EJC should be an instrumental and indispensable participant, including in formal rulemaking. There are no grounds within the legislation to limit its scope outside of rulemaking, and plenty of evidence that a broad and robust engagement with the EJC was expected by the Legislature.
4) Support for Working Washingtonians Improving Their Vehicle Efficiency: The average working forester, fisher, farmer, trucker, and other long-traveling professions contribute a vanishingly insignificant amount of pollution to the atmosphere compared to large industries, the U.S. military, and the aerospace sector. These average Washingtonians should not bear the brunt of the cost of the CCA during a time of high inflation and gas prices but instead should be made collaborative parts of the solution. The language pertaining to these communities was specifically co-authored and negotiated by myself on behalf of the Snoqualmie Indian Tribe and with House Natural Resources Chairman Mike Chapman. It was undeniably the intent of this language to lead to proactive, substantive, and meaningful actions to support them. The CCA at Sec 29, Subsecton1(j)(i) explicitly authorizes investments that could greatly mitigate unintended price impacts on these vulnerable and protected communities, specifically by allowing investments for “Programs, activities, or projects that directly improve energy affordability and reduce the energy burden of people with lower incomes, as well as the higher transportation fuel burden of rural residents, such as bill assistance, energy efficiency, or weatherization assistance.” The Snoqualmie Indian Tribe strongly supports fuel-efficiency investments for working vehicles as a critical requirement to mitigate potential price impacts on the communities and people identified by the statute.
5) Definition of Tribal Lands : In engagement with DOE, it appears that there has not been an adopted definition of what “Tribal Lands” means in the context of this legislation and grant funding from within it. Given that Tribal lands are inherently something defined by the Tribe itself as a fundamental aspect of sovereignty, it is our position that the definition of “Tribal Lands” should be as defined by each independent sovereign Tribe itself. If one Tribe would like to do projects off-reservation and another wishes to limit its projects to specifically Tribal-owned lands, then that should be a recognized expression of their sovereign right to self-governance. No outside party or state agency should be able to assert where or where not Tribal lands are located. It would be legally and morally inappropriate for an outside state agency to define the “lands” of a sovereign nation. In Closing The Snoqualmie Tribe and its elected leadership are incomparably proud of the Tribe’s role in authoring and passing this historic legislation. All of us are facing the greatest existential environmental threat in human history together, and DOE has a duty to comply with both the intent of this ambitious legislation and the obvious scientific mandate to take radical steps to mitigate Washington State’s contribution to this crisis. That is literally why the word “Commitment” is in the name of the legislation. The Snoqualmie Indian Tribe intends to continue to collaborate with DOE and Washington State on ensuring that the Commitment is kept.
Sincerely, Matthew Randazzo V Senior Adviser to the Snoqualmie Indian Tribe State Lobbyist for the Snoqualmie Indian Tribe
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Dear Mr. Grice, In 1970, as a NASA geologist, I studied samples from the Moon and celebrated the very first Earth Day. What a contrast between planetary environments! Substitutes for Earth – none. Substitutes for fossil fuels – many. In 1973, I read ...↓“The Limits to Growth.” I watched the Business As Usual (BAU) scenario unfold. In 1986, I was working as an environmental geologist at the Hanford when American and Soviet leaders decided to end the Cold War. Hanford changed on a dime - from producing plutonium to restoration and remediation of the radioactive wasteland we ironically created in our own country, not the enemy’s. In 2021, the Northwest experienced the deaths of hundreds of people and an estimated billion of marine fauna due to a heat dome (that’s a thing?). These emerging catastrophes are not one-offs. Planetary conditions are rapidly deteriorating. I agree with the critique of the WAC-173-446 Climate Commitment Act (CCA) Program rule draft provided the Community Energy reSource organization, and documented in their report entitled "Exposing False Solutions: How Washington's Cap and Trade Program Gives Industrial Polluters a Free Pass." The WAC Program Rule draft is astonishingly weak on lowering carbon emissions. Exempting the majority of EITEs from incentivizing rules (3% is trivial, insulting even). The draft smacks of being much more influenced by industry and polluters rather than citizens, human health concerns, environmental degradation, and climate scientists. The former have created the problems, have they not discredited themselves many times over? I also agree with the "spot on" comments provided by Seattle's 350.org (such as more time to understand the rules and their consequences, flawed offsets allowing pollution to continue, inflated emissions reduction estimates, inadequate oversight of Utilities, unsupported claims such as “working forests” that do not provide the trillions of dollars in ecological services that natural forests do). To be most effective, any forestry offset protocol used by Washington State should reward the avoidance of industrial forest practices, • Incentivize longer harvest rotations. • Prioritize the protection of old growth and mature forests. • Evaluate carbon storage and overall forest health together. I hope that you can see the writing on the wall and change the rules accordingly. Thank you for reading.
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Nancy Miller 11045 8th Ave NESeattle, WA 98125
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Elizabeth Kelly 900 W Tyler StDalton, GA 30720
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Henry Roller 280 Boyer AveWalla Walla, WA 99362
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Tracy Cole 10227 N 66th DrGlendale, AZ 85302
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Carl Woestwin 9608 25th Ave NESeattle, WA 98115
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,As a long-time resi...↓dent of Olympia, retired biologist from the USFWS, and part-time volunteer environmental educator, I thank you for the opportunity to comment on this rule on the state’s Cap-&-Invest Program. This part of the Climate Commitment Act is the strongest carbon pricing program in the country, and I am proud about its potential to reduce carbon and invest in low-income neighborhoods. In passing this legislation, the state has integrated environmental justice, tribal sovereignty, and the right approach to environmental effects into the structure of the law. I hope Ecology will continue to faithfully implement its directives.The program should give Ecology clear authority to act and clarify the responsibilities of other covered entities. Therefore, I urge Ecology to strengthen it in the following ways:A. Offsets:Be very careful to make these meaningful in the real world, and not empty "window-dressing." Other writers may have more detailed information that should be reviewed.B. Overburdened communities 1. Articulate Ecology’s responsibility that the cap-and-invest program avoid negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.2. Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities on overburdened communities, regardless of when each facility becomes a covered entity.3. Require an explicit process to review impacts to overburdened communities, to inform Ecology’s reporting to the legislature as required by RCW 70A.65.060(5). The rule must be meaningful and thorough. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, by addressing the full range of overburdened communities as defined by the law.C. Tribal Sovereignty:1. Mention Ecology’s existing obligation to proactively consult with federally recognized tribes.D. Information for review and accountability:1. Require all covered entities to provide information about: a) impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.2. Establish reporting requirements for consumer-owned utilities on "no-cost allowances" and engage with the UTC on its regulation of them. 3. Best available technology: Require EITEs applying for an upward adjustment of no-cost allowances to submit any unexpected environmental impacts of the fuels, processes, and equipment used. If the facility is creating excessive environmental impacts, upward adjustments must be denied.4. Require Ecology to publicly share data being used to establish baseline information, subtotal baselines, and allocations. E. Environmental Justice Council:1. Include explicit language on how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.2. Track information about the environmental and health impacts of all covered entities to inform Council review. I look forward to Ecology’s ongoing work to strengthen this rule as part of our work to meet climate goals in an equitable way.Thank you, Joseph Hiss 225 17th Ave SEOlympia, WA 98501
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Melissa Roberts 1215 S Ridgewood AveTacoma, WA 98405
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,We need all the cli...↓mate laws we can get. I feel we need this one more than ever after the action of the Senate and Joe Manchin. Thank you for the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Thomas Gordon 642 I StWashougal, WA 98671
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Phebe Schwartz 523 N Garden StBellingham, WA 98225
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Millie Magner 4228 28th Pl WSeattle, WA 98199
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Mary Orrange 1327 Batey RdSedro-woolley, WA 98284
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Hilarie Ericson 14515 N Creek DrMill Creek, WA 98012
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Rita Calcagno 1915 234th Ct NESammamish, WA 98074
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Chris Hazynski 17 Gate CtBurlington, NJ 08016
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, lynn hoang 2307 Leggett LnFullerton, CA 92833
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Helen Moissant 2965 Ross LnCentral Point, OR 97502
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Aisha Franco 1755 N Western AveLos Angeles, CA 90027
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Andrew R. 7 Washington StCumberland, MD 21502
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Joann Koch 134 Olenick RdLebanon, CT 06249
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Leslie Kreher 427 S Lewis StMonroe, WA 98272
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Loewyn Young 337 E Beck StMccleary, WA 98557
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Kevin Walsh 155 Bishop LnMadison, CT 06443
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Julia York 1716 NE 146th StShoreline, WA 98155
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Eric Zimdars 14902 12th Dr SEMill Creek, WA 98012
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation I understand the awkward position the Department of Ecology (DoE) is in regarding incorporation of guidance from the Environmental Justice Council. That said, unless advice from the EJC is given extra weight and power (beyond that of other public comments) in affecting DoE’s implementation of the Climate Commitment Act, the reason for creating the EJC is undermined.The statute clearly states that the program should benefit overburdened communities and not cause environmental harm. The rule should be revised to: Articulate DoE’s responsibilities for engaging with the EJCClarify the authority of EJC to request rule language and under what circumstances DoE needs to agree to that requestClarify DoEs responsibility for evaluating and reducing impacts on overburdened communities; andEstablish an explicit review process for how the program is impacting overburdened communities and ensure Ecology has information required to conduct such reviews and the authority to fix problems identified by those reviews.Thank you, Lawrence Luton 1321 S Crestline StSpokane, WA 99202
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Guy Chan 1959 NE Pacific StSeattle, WA 98195
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Grace Padelford 11807 100th Ave NEKirkland, WA 98034
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Lenore Reeves 19934 Hickory Stick LnMokena, IL 60448
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Becca Kempton 121 E 28th StVancouver, WA 98663
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Mark Blandford 2800 Randy StAmarillo, TX 79124
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Celeste Maris 2418 Woodfield Loop SEOlympia, WA 98501
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Janice Wilfing 167 Sunset PlSequim, WA 98382
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, carol uschyk 1709 Reynard LnCalistoga, CA 94515
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, jesse gillman 15811 SE 43rd PlBellevue, WA 98006
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Julie ODonnell 10046 13th Ave NWSeattle, WA 98177
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Emily Thompson 303 NW 164th StRidgefield, WA 98642
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Kathleen Mahan 2330 43rd Ave ESeattle, WA 98112
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Tess Reeber 1211 Jersey StBellingham, WA 98225
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Caroline Bowdish 1531 N 16th AvePasco, WA 99301
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,I am writing from V...↓ancouver and as we work to adopt and implement a strong local Climate Action Plan, the Climate Commitment Act is essential in our local work being as strong as it can be.Our city and county have among the highest numbers on the WA Health Disparities Map, and climate pollution is a heavy burden on much of our community. So the Climate Commitment Act must be as strong as it can be to overcome the burdens here and benefit those most affected.Thank you for the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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. And I am mindful that as the state meets it's climate goals in an equitable and just way, it will also allow cities across the state to do so as well.Thank you, Cathryn Chudy 1506 E 29th StVancouver, WA 98663
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Kimberly Teraberry 532 18th Ave ESeattle, WA 98112
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Martha Gorak 22502 Downdale CirKaty, TX 77450
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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.Climate change, like numerous other issues (gun safety, immigration reform, prison reform, education reform, short-term lending regulation, healthcare reform, banking regulation, opioid regulation) remains a vexing problem primarily due to corporations' ability to curry favor with elected officials. The corrupting influence of money in our political system is undermining our democratic traditions and discouraging Americans from voting and/or running for office. This ominous development may well end our experiment in representative democracy unless we alter this decades-long trend. For the sake of the republic, we must amend the US Constitution to state that corporations are not people (and do not have constitutional rights) and money is not speech (and thus can be regulated by state and/or federal campaign finance laws). Short of accomplishing this, no other reform of significance will be achieved. The moneyed interests will turn any reform to their benefit, often at the expense of the nation as a whole.Thank you, James Klein 3501 Monterrey StCorpus Christi, TX 78411
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Deborah Hagen-Lukens 4200 SW Atlantic StSeattle, WA 98116
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Carmela Micheli 10429 Sunrise Beach Dr NWGig Harbor, WA 98332
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Karen Berger 4412 Ocean View BlvdLa Crescenta-montrose, CA 91020
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Charles Favorite 16971 330th PlIsle, MN 56342
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes including impacts relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and include disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts, including impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Peggy Willis 2637 W Viewmont Wy WSeattle, WA 98199
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Susan Thiel 1810 172nd St ESpanaway, WA 98387
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, David Turnoy 1131 Discovery WayEastsound, WA 98245
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Marco Pardi 2195 Sandown CtLawrenceville, GA 30043
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Amy Scott 2426 NW 62nd StSeattle, WA 98107
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Kenneth Zontek 4701 Modesto WayYakima, WA 98908
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Michael Brandes 2024 Cameron AveMerrick, NY 11566
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, TJ Williamson 2222 NE 92nd StSeattle, WA 98115
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Michelle Macy 12550 Piping Rock DrHouston, TX 77077
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Joan Furtado 115 Goldsmith AveEast Providence, RI 02914
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, David Hand 7169 NE Hidden Cove RdBainbridge Island, WA 98110
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Steve Hansen 2644 Donovan AveBellingham, WA 98225
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Jay Besig 17 Sessions St NWMarietta, GA 30060
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, J K 15120 Starr Rd SEOlalla, WA 98359
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Diane Basile 7 Evert StHuntington Station, NY 11746
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkWe are on fixed income, doubling the cost of fossil fuels hur...↓ts the lower income while the elite can afford the extra cost to inflate their self-image.Thank you for the opportunity to comment on rulemaking for Washington’s new cap-and-trade program.I urge you to adjust this costly new policy to help minimize the impacts on Washington families, small businesses and working people across our state.Studies estimate that this program could increase the cost to manufacture gasoline and diesel fuels by as much as 47 cents per gallon in 2023. (Cap and Trade Program Analysis, Washington Research Council, Memo on E2SSB 5126, June 6, 2022.)This is on top of record high fuel prices that consumers are already paying at the pump!Washingtonians are burdened enough right now with skyrocketing inflation and an economy that is still suffering the consequences of the COVID-19 pandemic. Gas prices in Washington state are already some of the highest in the nation.Please consider delaying the inclusion of gasoline and diesel fuel for at least the first few years – as California’s program did in order to delay the impacts on consumer fuels.Many experts believe the goals set by this program are too unrealistic. In order to meet its goals the program relies on a total ban of new gas, diesel and hybrid vehicles by 2035 – starting in 2026 with a requirement that 35% of new vehicles sold in Washington must be electric vehicles.Surveys show that a majority of Washington voters believe the state legislature needs to go back to the drawing board and revise the Cap-and-Trade program to make sure it will work as intended without placing such enormous cost burdens on Washington families and businesses. When it was first introduced, the state originally estimated that the Cap-and-Trade program would cost up to $500 million per year – which the state would spend on a variety of climate-related programs. Recent estimates indicate that the program could now cost up to 4 times more – close to $2 billion a year. (OFM Fiscal Note 2021, Ecology Preliminary Analysis, May 2022)Please do everything you can to reduce the costs of this new program to minimize burdens on Washington families and working people across our state.Thank you.Sincerely,Kathryn Palmerkitty_palmer@hotmail.com3958 SE Nelson Rd, Olalla, WA 98359, USA
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Russ Ziegler 22 61st StDowners Grove, IL 60516
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Melanie Palmer 7322 25th St WUniversity Place, WA 98466
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Mary Wilkins 315 W 50th AveKennewick, WA 99337
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Christi Sutphin 807 N B StEllensburg, WA 98926
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, David Elmendorf 1058 Modoc StWalla Walla, WA 99362
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Sharon Sollenberger 6306 NE 87th AveVancouver, WA 98662
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Hank Ramírez 4823 Mansfield StSan Diego, CA 92116
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,We need to move for...↓ward to prevent more climate change. If we don't invest now we will pay more in the future.Thank you for the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Dixie Edwards 2039 44th AveLongview, WA 98632
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Vivian Korneliussen 917 N 178th StShoreline, WA 98133
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Please address thes...↓e issues: Thank you for the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, nancy corr 816 S 216th StDes Moines, WA 98198
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkSupporting this Rule is not in favor of the blue-collar and u...↓nskilled laborers who can little afford more government taxation, no matter how it is disguised.Thank you for the opportunity to comment on rulemaking for Washington’s new cap-and-trade program.I urge you to adjust this costly new policy to help minimize the impacts on Washington families, small businesses and working people across our state.Studies estimate that this program could increase the cost to manufacture gasoline and diesel fuels by as much as 47 cents per gallon in 2023. (Cap and Trade Program Analysis, Washington Research Council, Memo on E2SSB 5126, June 6, 2022.)This is on top of record high fuel prices that consumers are already paying at the pump!Washingtonians are burdened enough right now with skyrocketing inflation and an economy that is still suffering the consequences of the COVID-19 pandemic. Gas prices in Washington state are already some of the highest in the nation.Please consider delaying the inclusion of gasoline and diesel fuel for at least the first few years – as California’s program did in order to delay the impacts on consumer fuels.Many experts believe the goals set by this program are too unrealistic. In order to meet its goals the program relies on a total ban of new gas, diesel and hybrid vehicles by 2035 – starting in 2026 with a requirement that 35% of new vehicles sold in Washington must be electric vehicles.Surveys show that a majority of Washington voters believe the state legislature needs to go back to the drawing board and revise the Cap-and-Trade program to make sure it will work as intended without placing such enormous cost burdens on Washington families and businesses. When it was first introduced, the state originally estimated that the Cap-and-Trade program would cost up to $500 million per year – which the state would spend on a variety of climate-related programs. Recent estimates indicate that the program could now cost up to 4 times more – close to $2 billion a year. (OFM Fiscal Note 2021, Ecology Preliminary Analysis, May 2022)Please do everything you can to reduce the costs of this new program to minimize burdens on Washington families and working people across our state.Thank you.Sincerely,Lloyd Palmerkitlloyd53@gmail.com3958 SE Nelson Rd, Olalla, WA 98359, USA
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I'm excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Margaret Donaldson 9431 Capstan Dr NEBainbridge Island, WA 98110
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Allen Smith 7848 Stroud Ave NSeattle, WA 98103
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I ??appreciate?? the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.Really!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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Irene Bensinger 43708 161st Ave EEatonville, WA 98328
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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.No amount of money nor political power will be able to make one escape the climate catastophe that is coming. This issue is the primary moral/existential issue of our time, and to know that political prostitutes to the fossil fuel industry are in power in our government. They are stopping actions to slow and reverse climate change is simply showing them as against all life and too ignorant to acknowledge that it took the natural processes of our planet 4 billion years to get us to this point. What kind of sentient human would do this? No one - only those too ignorant and greedy to act beyond their own self interest - even though they themselves won't escape the increasingly looming destruction from climate change.Thank you, TJ Thomspon 3118 Judson StGig Harbor, WA 98335
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, John Messer 6242 Johnson RdBrutus, MI 49716
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Judith Cohen 1608 E Republican StSeattle, WA 98112
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Mike LeHew 2114 SW Gailwood StPort St. Lucie, FL 34987
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Lynne Bannerman 1513 Woodard Ct NWOlympia, WA 98502
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Kathy Bradley 1220 Fredericksburg Dr SLugoff, SC 29078
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Chris O'Niell 15613 Olson Dr NWVaughn, WA 98394
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,With proposed globl...↓e warming legislation frozen in the U. S. Senate. and a possible loss of a Democratic majority in the U. S. House of Representatives, it is crxitical that State and local governments act to decrease green house gas emissions. I appreciate the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, MIKE DOHERTY 617 S B StPort Angeles, WA 98363
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Phyllis Friedman 1122 10th Ave ESeattle, WA 98102
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Mary Garttmeier 9200 Redmond - Woodinville Rd NERedmond, WA 98052
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, R. Morris 21031 5th Ave SDes Moines, WA 98198
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Peter Mastenbroek 12323 NE 97th StKirkland, WA 98033
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.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 proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: 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 each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing 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 covered entities 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; and 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.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.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, Rebecca Rose 20119 113th St SESnohomish, WA 98290
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