Rulemaking - Chapter 173-446 WAC, Climate Commitment Act Program
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...↓
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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 believe these changes are not only important but necessary because research is showing that carbon offsets programs are by NO MEANS ensured to make the kind of different necessary in slowing climate change unless they are carefully done and closely monitored with facts checked. 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, Kristi Hunziker 3204 Summitview AveYakima, WA 98902
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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, Vicki Zarrell 1804 Marigold St 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, Kathleen Lee 5533 37th Ave SELacey, WA 98503
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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, Steven Woolpert 185 NE Snohomish AveWhite Salmon, WA 98672
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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, Edith Kusnic 2304 NE 113th StSeattle, 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, Nanci Gabbard 3430 OH-756Felicity, OH 45120
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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 Meyerding 33417 Mann RdSultan, WA 98294
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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 Shaughnessy 7308 N Skyview PlTacoma, WA 98406
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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 Seibel 10 Ponce De Leon Creek SWLakewood, WA 98499
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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, Daniel Rogers 3331 H 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, Noah Ehler 32115 NE 110th CtCarnation, WA 98014
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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 Watson 4145 2nd Ave NWSeattle, 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 linkIf this passes, this will be crippling to our economy and the...↓ trucking and supply community. This industry is already having numerous struggles recovering from the pandemic as well. This will affect a wide swath of individuals and businesses alike.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,Kristina Schneiderskschneider77@gmail.com112 Whitewater Way, Morton, WA 98356, 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 linkAmericans in all states are suffering already due to inflatio...↓n, the poorest always suffer the most from these types of legislation - please do not add to that burden by further increasing the cost of fuel!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,Dezri Deandezdean@yahoo.com3151 SE Lynch Rd, Shelton, WA 98584, 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, Cece P 4310 S Holden StSeattle, WA 98118
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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, Bronwen Evans 219 James StSeattle, WA 98104
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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, Larry Leveen 243 S 55th StTacoma, WA 98408
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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 Meuer 1422 Wheeler Rd Unit EMadison, WI 53704
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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 Fletcher 58900 Apple Canyon RdMountain Center, CA 92561
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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, Shaun Hubbard 685 Spring StFriday Harbor, WA 98250
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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, Robert Lombardi 1465 E 64th StBrooklyn, NY 11234
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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 Gallagher 20679 Miracle MileLeavenworth, WA 98826
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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,Heavenly Father, Ki...↓ng of the Universe, bless our elected government, which You allowed to be over us. Give them wisdom. Please watch over and protect the members of the USSC. Thank you for their wisdom.the snake river dams have ZERO emissions while giving us electrical power and they control the river flow. THEY PROVIDE FLOOD CONTROLHaving a great Sockeye season east of the mountains and we didn't have to use trucks, but then we don't have 1,000s of protected seals.Thank you, Stanley Borries 1490 Desert Springs AveRichland, WA 99352
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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 Esposito 1365 74th StBrooklyn, NY 11228
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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, Pablo Bobe 1 Main StNew York, NY 10044
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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 have lived in Was...↓hington state since 1962. The quality of our environment has deteriorated significantly due to many factors including over population, pollution and climate change. It is crucial that we step up our efforts to protect our environment. The time to act forcefully is past due! 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 am counting on 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 Lichtenberg 501 Colby AveEverett, WA 98201
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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, dean clarke 8232 S River RdWaterville, OH 43566
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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 Shirlock 1409 Rainbow LnCamano, WA 98282
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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, Jennifer Brandon 174 Brody LnLexington, NC 27295
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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 Vogt 269 Bias DrFairbanks, AK 99712
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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, Marie Zwicker 96 Taunton DrSullivan, ME 04664
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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, Bridgett Heinly 4440 Brindisi StSan Diego, CA 92107
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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 Burrows 424 S Chestnut StSpokane, WA 99201
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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, Kelly Keefer 5203 66th Ave Ct WTacoma, WA 98467
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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 linkThank you for the opportunity to comment on rulemaking for Wa...↓shington’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,Jason Goodwingoodwinjason@yahoo.com6804 51st Ave S, Seattle, WA 98118, 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, Kathleen Mendrey 8046 NE Bothell WayKenmore, WA 98028
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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, Russell Terrell 5841 Bow StBow, WA 98232
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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, Jim Haley 35399 Ridge Rte RdCastaic, CA 91384
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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 Fahey 2835 E 7230 SCottonwood Heights, UT 84121
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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, Susanna Smith 2702 E Denny WaySeattle, WA 98122
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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, Jo Clark 26121 Woodland Way SKent, WA 98030
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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 Collins 1935 Nault RdDover, DE 19904
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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, Ramona Wilson 2200 196th St SEBothell, 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, Susan Risser 1822 Wold RdFriday Harbor, WA 98250
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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 submitting a c...↓omment on this important rule that will guide our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country. As a teacher who works with young people and mentors a climate action club, I believe we must take action urgently. I am excited about the possibilities to reduce carbon, grow the economy, and invest in marginalized 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, Kristen Smith 9043 32nd Ave SWSeattle, WA 98126
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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, Floribert Mubalama 19950 International BlvdSeatac, WA 98188
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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, Daniel Henling 1412 NW 61st 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, Scott Bishop 1710 Giles Ave 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, Kevin Davis 22023 SE Wax RdMaple Valley, WA 98038
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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, Celia Cruz 8912 SE Hillcrest DrVancouver, WA 98664
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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 Cruz 8912 SE Hillcrest DrVancouver, WA 98664
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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. I am hopeful 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 describes 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 Allen 5900 37th Ave SSeattle, WA 98118
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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, Hai Nguyen 9024 Silver Star AveVancouver, WA 98664
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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, Scott Gibson 120 Riverview DrSaint Albans, WV 25177
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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, Heather Murawski 17929 W Spring Lake Dr SERenton, WA 98058
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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, Joseph Mayo 418 14th 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, Susan Paine 130 2nd Ave NEdmonds, WA 98020
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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 Zuckerman 15 Richey PlTrenton, NJ 08618
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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 award 1434 31st AveSeattle, WA 98122
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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, Gary Dirks 6473 E Hilldale RdPort Orchard, WA 98366
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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 Sévilla 400 N Michigan AveChicago, IL 60611
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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 Shurgot 6536 31st 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,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 Roberts 4642 N Drake AveChicago, IL 60625
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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, Alaya Bouche 10422 Box Canyon Pl NWAlbuquerque, NM 87114
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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, Noel Barnes 1614 Glennwood Ave SERenton, WA 98058
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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 linkAs a DOT safety consultant working with motor carriers from a...↓ll over our state, I strongly oppose this. The trucking industry has taken hard hits in the past few years and this law will make operational costs increase. It is already a struggle for small trucking businesses lately due to the very real driver shortage. Increasing fuel costs will only make this worse. If the price of fuel increases, the increase will affect consumer prices (and we already have an issue there). This is a terrible time to institute such a law. When Washington truckers give up because they can't afford to run their businesses, we'll all be in trouble.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,Mikki Kingmikki@kingsafetyandcompliance.com15518 Corliss Ave N, Shoreline, WA 98133, 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 linkWashington Legislators,Our small state cannot, will not make ...↓any appreciable difference in the reduction on C02 admissions. Think China, think India, think Shri Lanka, think Germany, heck think every country that doesn’t take drastic measures against its energy policies and against its citizens. Yet you want to burden us with a HUGE tax increase. THE ENTIRE WORLD cannot move away from the reality of the fossil fuel economy until a reasonable replacement is developed. This tax will ONLY CRIPPLE Washingtonians, drive creative, hard working citizens away from our state and the eventuality of fewer tax paying residents with NO MEASURABLE DIFFERENCE IN CLIMATE CHANGE. But, it’s inevitable that people will suffer, will move away and all Washingtonians will suffer. ASK yourselves this; what is READILY available to replace fossil fuels? You have NO answer because no reliable replacement is available YET! Please do not cripple Washingtonians. A senior citizen, Kerri HuntThank 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,Kerri Hunttalksalot56@gmail.com31622 NE 144th St, Duvall, WA 98019, 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, James Nichols 1019 Terry AveSeattle, WA 98104
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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, Fay Forman 355 8th AveNew York, NY 10001
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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 Smith 3018 Coolidge DrBellingham, 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, Jackie Stewart 3406 Kensington CtTuscaloosa, AL 35405
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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, Brenda Sullivan 1654 SW 168th StNormandy Park, WA 98166
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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, Annie McMahon 421 Geary Heights RdClarkdale, AZ 86324
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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 Sparer 6224 20th 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,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 Samaras 10342 Ravenna 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, John Miller 5187 Ranchos RdBellingham, WA 98226
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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, Keith D'Alessandro 42486 Saratoga RdCanton, MI 48187
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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, Carole H 4807 Willamette StPort Townsend, WA 98368
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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, Pamela Evans 101 W 9th StKemp, TX 75143
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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, Jeannie Keyes 485 Renton Center Way SWRenton, WA 98057
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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, George Bourlotos 49 Flanders-Bartley RdMount Olive, NJ 07836
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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, Dean Borgeson 36030 Bonnie Lakes RdCrosslake, MN 56442
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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 Helget 5121 NW Franklin 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,I appreciate the op...↓portunity 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. We must consider the legacy of our generation.Thank you, Dale Benjamin 408 NE 4th StBattle Ground, WA 98604
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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, Mona McNeil 15704 NE 28th CtVancouver, WA 98686
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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 linkThis is beyond ridiculous! WA is already one of the most expe...↓nsive states to live in. Now you want to add heavily to that cost. Perhaps you can afford it on your public service salary, increased every year by you, and supported by wealthy elite and lobbyists… but the working folk can’t. Get your heads out in the public, not just the wealthy support group that funds your campaigns. Listen to real people, not just the media and your inner circles. Try for once to actually approach the isle and make real compromises that benefit all people in WA - not just the democrats.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,Rich WendtRichwendt@yahoo.com25905 Highland Rd NE, Kingston, WA 98346, 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 linkThank you for the opportunity to comment on rulemaking for Wa...↓shington’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. Where will all the energy for additional electricity come from, if not coal, gas, and hydro?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,Lyle Russelltrulygin@cs.com7913 37th St Ct W, University Place, WA 98466, 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 linkThank you for doing all you can to keep us able to eat AND dr...↓ive to work in WashingtonThank 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,Ryan MasingaleRmasingale123@gmail.com20 Kidwell Rd, Republic, WA 99166, 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 linkThank you for the opportunity to comment on rulemaking for Wa...↓shington’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,Megan AndersonMeganeanderson@protonmail.com22433 NE Marketplace Dr, Redmond, WA 98053, 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 linkHow many people can’t afford a new electric car? How is the e...↓lectricity generated for them anyway. This is totally unrealisticThank 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,Glen Godfreyglengodfrey01@gmail.com28381 Gamble Bay Rd NE, Kingston, WA 98346, 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 linkThese kind of ideas are why people don’t like you, the absolu...↓te lack of insight into what the average person you “represent” cares about. Nobody wants this right now, we want lower prices for fuel. Lower fuel prices drive down the cost of countless other items, high fuel prices drive them up. This is not difficult to understand. Just because it doesn’t directly impact your life and your financial well being doesn’t mean it isn’t important to the vast majority of people in this state. Pull your heads out of your ass and try doing something worth a fuck, ever.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,DJ StraitDjstrait21@gmail.com124 Skyline Dr, Port Angeles, WA 98362, 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 linkPlease. Not another fuel tax.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,Andy BenedettiAndyb929@gmail.com24215 SE Green Valley Rd, Auburn, WA 98092, 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 linkThank you for the opportunity to comment on rulemaking for Wa...↓shington’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,Charles Funkcnfunk@comcast.net5815 134th Pl SE, Bellevue, WA 98006, 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 linkThis mandate of 2035 for 35% EV's is wild. Who is going to bu...↓ild all the charging stations needed at least one million new EV's? Where are they going to locate them? Where is increased electrical demand going to be produced? Thankfully I am 80 and hopefully will not be on. this earth by 2035.The woke and greenies need to pay for it all and accept all the blame for the mess that will happen.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,Emory Longstrethstretch001@comcast.net15102 NE 29th Ave, Vancouver, WA 98686, 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 linkWith a recession well on the way, Washington State residents ...↓are already paying over $5.00/gal for gasoline. and diesel. The cap-and-trade program will only increase fuel prices for hard working resident's transportation to and from their workplace, and shopping for their family needs. We are still "not out of the woods" in as far as Covid 19 and variants, with an economy that is lagging. Please vote against any measures that impair Washington resident's ability to provide for their families, and would increase transportation costs across the board, including public transportation during transition from petroleum to alternate sources of vehicle propulsion. Reasonable responses are paramount in these uncertain times. Thank you for your consideration of this vitally important issue and the current needs of Constituents.Sincerely,Timothy J. WellerThank 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,Timothy Wellertweller1947@outlook.com799 Lewis Rd, Port Angeles, WA 98362, 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 linkI am retired. It is looking like I am going to have to move o...↓ut of state. With all the taxing on cars and gas no way can I live in this state any longer. Property taxes keep going up . I am taxed out!!!!!!!!!!!!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,cheri boegerptacheri@yahoo.com1917 37th Way SE, Auburn, WA 98002, 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 linkWe need a break. The rapid rise in the cost of living has bee...↓n burdensome, for many in WA state. It's impacting so many, and forcing families to make tough decisions - fuel or food. We already pay the highest in the nation. What a disgrace. Please reconsider and adjust this policy to make it work for people who really want to live here. We don't want to lose more families in this beautiful state. Thanks.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,Lydia Zibinlydiazib@gmail.com254 145th Pl SE, Bellevue, WA 98007, 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 linkThank you for the opportunity to comment on rulemaking for Wa...↓shington’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,Donald Postdpost1945@embarqmail.com361 McMillan Rd, Chimacum, WA 98325, 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 linkFuel prices are already higher than ever before. More increas...↓es on fuel prices does not just stop at the gas pumps, this increase will affect everything we purchase such food, clothing, homes, travel, etc. Please stop this nonsense tax hikes on fuel.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,John Herberjohnaherber@hotmail.com12119 Rock Creek Dr, Pasco, WA 99301, USA
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