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 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, Jean Pauley 414 Malden 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, Jeanie Bein 4911 Coronado LnBellingham, WA 98229
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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, Amanda Dickinson 1322 S 18th 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, Tika Bordelon 1400 Hubbell PlSeattle, WA 98101
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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, Bob Leppo 310 Cuyama AvePismo Beach, CA 93449
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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, Maryellen Redish 671 S Riverside DrPalm Springs, CA 92264
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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, Stephen Sachs 1916 San Pedro Dr NEAlbuquerque, NM 87110
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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, Neilia Pierson 805 Caves HwyCave Junction, OR 97523
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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, Lanie Cox 13625 S Sherman RdSpokane, WA 99224
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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, Joyce Grajczyk 12026 SE 216th StKent, WA 98031
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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, Harold Watson 2223 N U DrSpringfield, MO 65803
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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, Sarah Bauman 695 Chuckanut Dr NBellingham, WA 98229
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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 n 14005 SE 38th StVancouver, WA 98683
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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, William McGunagle 1727 E Olympic AveSpokane, WA 99207
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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, CECIL PHILIP 2541 Windsor Castle WayLewisville, TX 75056
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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, Brandie Deal 301 225th St SWBothell, WA 98021
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Mark Koritz 12104 Ashford Gables DrDunwoody, GA 30338
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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 Schenck 115 Sycamore CtSpartanburg, SC 29302
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, David Arntson 1615 208th 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, Michael Seager 8253 Westmoor RdMentor, OH 44060
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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, Hannah Liu 3008 NE 141st StVancouver, 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 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, Ben Moore 4823 243rd St SWMountlake Terrace, WA 98043
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Andrew Jackson 14131 Bishop Bend LnHouston, TX 77047
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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, Sophie Johnson 3711 Walnut Ave SWSeattle, WA 98116
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Dan Snyder 5904 53rd St Ct WUniversity Place, 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 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, Carrie Heron 3955 S Eddy 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, Karen Stickney 27 Baril StLewiston, ME 04240
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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, Derek Benedict 709 212th Pl SWLynnwood, WA 98036
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Caroline Bowdish 1531 N 16th AvePasco, WA 99301
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,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, Andrea Speed 1618 154th St ETacoma, WA 98445
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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, Faye Bartlett 3382 Southbend PlBellingham, 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, j g 3011 State Hwy 30Minnesota Lake, MN 56068
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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, thor t 1211 Aqua Vista Dr NWGig Harbor, WA 98335
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Brandon Bee 12512 E Houk RdSpokane Valley, WA 99216
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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 which 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 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, Patti Nordby 133 Twin Lakes DrWinthrop, WA 98862
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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, Urmila Padmanabhan 3624 Chelsea CtPleasanton, CA 94588
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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 Skal 630 Churchill AveColumbus, OH 43214
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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 Brown 1443 Edwards AveFircrest, WA 98466
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Carol Price 1599 NW Lassie WayPoulsbo, WA 98370
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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, Margaret Weant-Leavitt 10655 E Quail Run RdCornville, AZ 86325
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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, Gloria Skouge 326 NW 182nd StShoreline, WA 98177
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, John Guros 308 10th St SMontesano, WA 98563
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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, Javier Rivera 55 S 3rd StBrooklyn, NY 11249
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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, Margie Heller 731 S Garfield StSpokane, WA 99202
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Mark Blandford 2800 Randy StAmarillo, TX 79124
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Sarah Campbell 4120 50th Ave NESeattle, WA 98105
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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, Kristi Weir 4639 133rd Ave SEBellevue, WA 98006
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Erik Larue 17598 Maiben RdBurlington, WA 98233
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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, Cheryl Biale 7711 Greenridge St SWOlympia, WA 98512
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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, Sophia Keller 851 SW 127th StSeattle, WA 98146
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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, Javier Rivera 55 S 3rd StBrooklyn, NY 11249
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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 Cowan 3709 SW Trenton StSeattle, 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.We need to take better care of what is left of our environment, for wildlife, marine life, plant life, and people.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the 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, Priscilla Martinez 35411 SE English StSnoqualmie, WA 98065
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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 Kawamura 16415 Basswood LnFontana, CA 92336
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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,There is no Planet ...↓B. Thank you for the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Marie Marrs 111 Heron Cove RdPort Angeles, WA 98363
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jo Hebberger 2111 W Dayton AveSaint Paul, MN 55104
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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 Shouse 2919 Leonard DrEverett, 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, Jim Loveland 2500 54th Ave NSt. Petersburg, FL 33714
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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, Natalie Niblack 21357 Mann RdMount Vernon, WA 98273
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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, Jody Gibson 317 E Wall AveDes Moines, IA 50315
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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, Barbara DuBois 5020 N 18th StTacoma, 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, Tracey Bonner 1707 Castle RdArlington, TX 76014
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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, Donald Shaw 1906 Hawaii Ave NESt. Petersburg, FL 33703
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, David Hand 7169 NE Hidden Cove RdBainbridge Island, WA 98110
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jackie Stolfi 267 Harbor Ln NMassapequa Park, NY 11762
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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, Thomas Cox 11682 Holmes Point Dr NEKirkland, WA 98034
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Barbara Fristoe 3418 16th Ave SSeattle, WA 98144
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Steve Shapiro 2511 30th Ave SSeattle, WA 98144
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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, Catherine McHugh 526 17th 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, Jason Crawford 3224 Randy RdLancaster, PA 17601
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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, Dave Baine 32116 42nd Pl SWFederal Way, WA 98023
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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 Ellenberger 23633 112th Ave SEKent, WA 98031
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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, Jean Schwinberg 6341 5th 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, Judy Palmer 15 5th StTonasket, WA 98855
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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, Marilyn Shepherd 357 Main StTrinidad, CA 95570
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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, and IT IS WRITTEN IN PRECISE and UNAMBIGUOUS LANGUAGE THAT CANNOT BE FRAUDULENTLY DISTORTED BY BLATANT and PATENTLY IMMORAL AND UNETHICAL CHRISTIAN and CORPORATE CORRUPT REPUBLICAN PARTY ZELOTS WHO REFUSE TO ACKNOWLEDGE ANY REALITY AND VALUES THAT DIFFER FROM THEIR PERSONAL MEGALOMANIACAL REPUBLICAN PARTY CULT POLITICAL LUST AND ABUSE. With that in mind, I already 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, Patrick Conn 22018 126th Ct SEKent, WA 98031
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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, Esther Garvett 1861 NW S River DrMiami, FL 33125
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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, Cornelia Teed 1201 13th St Unit 201Bellingham, 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, Charles Bagley 1235 8th Ave WSeattle, WA 98119
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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, Richard Hernandez 14304 110th Ave NEKirkland, WA 98034
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Robert Jehn 180 S Atlantic AveCochranton, PA 16314
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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, Tara Kerr 1027 4 Wood DrFayetteville, NC 28312
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Please strengthen t...↓he Climate Commitment Act following the proposals listed below.Thank you for the opportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Andrea Faste 7713 11th Ave NWSeattle, WA 98117
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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, Marquam Krantz 5698 NE Wild Cherry LnBainbridge Island, WA 98110
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Joanna Stiehl 512 Puget St NEOlympia, WA 98506
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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, Lori Stefano 22440 Vale Ct SEYelm, WA 98597
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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, Felicity Hohenshelt 4321 Sunbeam Lake DrJacksonville, FL 32257
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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 Finley 7207 78th Dr NEMarysville, WA 98270
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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 Barlow 1533 Orillia CtSunnyvale, CA 94087
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Steve Graff 1948 Malcolm AveLos Angeles, CA 90025
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Emily Van Alyne 6749 Whitestone StWest Richland, WA 99353
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Peter Giono 18118 Clarence AveStanwood, WA 98292
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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, fayette krause 2315 Madrona 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, Julia Paulsen 8237 Ravenna 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, Susan Loomis 15159 140th 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 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, Richard Johnson 6 Overlake CtBellingham, WA 98229
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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, Victoria Urias 14001 35th 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, Jim Byrne 28501 NW 7th AveRidgefield, WA 98642
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, leslie spoon 1298 Ramona AveBaywood-los Osos, CA 93402
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