Rulemaking - Clean Fuel Standard Informal Comment Period #2

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Comment From: Hammerschlag LLC (Roel Hammerschlag)

6/07/24 @ 11:10 PM

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Comment From: Voltera (Paul Hernandez)

6/07/24 @ 9:31 PM

Please see the attached, "Comments of Voltera in Response to the Clean Fuel Standard Program (Chapter 173-424 WAC) Rulemaking, Informal Comment Period #2" in PDF format.

Please reach out with any questions or for clarification regarding these comme...↓

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Comment From: 3Degrees (Helen Kemp)

6/07/24 @ 5:10 PM

Please see our comments in the attached file. Thank you for your work on this important rulemaking.

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Comment From: Pacific Environment (Jayne Stevenson)

6/07/24 @ 3:47 PM

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Comment From: Twelve Benefit Corporation (Ira Dassa)

6/07/24 @ 3:38 PM

Please see the attached for Twelve's informal comments.

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Comment From: NW Natural (Kellye Dundon)

6/07/24 @ 3:31 PM

Please see attached comment letter.

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Comment From: CALSTART (Nicole Hutchinson)

6/07/24 @ 3:21 PM

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Comment From: Union of Concerned Scientists (Jeremy Martin)

6/07/24 @ 3:12 PM

I wanted to share a few thoughts responsive to the current interpretive statement. It is important that whatever approach you decide is enforced uniformly, to avoid cherry picking and pollution shuffling. Petitioners should not able to choose the ap...↓proach that is most favorable for their specific application. This principle should apply to electricity, upstream methane leakage, or any other element of a pathway.

I appreciate the legislature has encouraged WDE to give more generous accounting treatment for power used to produce SAF, as a means of encouraging the development of what is current perceived to be a hard to decarbonize fuel pathway. However, I am concerned that establishing inconsistent accounting practices among very similar fuel pathways (SAF versus renewable diesel for example) could lead to unintended consequences that could be difficult to address later without establishing the appropriate mechanisms now.

It was only a few years ago that renewable diesel (RD) was an expensive source of compliance with the California LCFS. But changes in policies outside California led RD became a very inexpensive and abundant source of LCFS compliance, creating a major crisis for the California LCFS and undermining the support CARB expected the LCFS to provide for electrification (see my January blog for more details https://blog.ucsusa.org/jeremy-martin/a-cap-on-vegetable-oil-based-fuels-will-stabilize-and-strengthen-californias-low-carbon-fuel-standard/). Changes in federal support for SAF could plausibly create a similar dynamic down the road, which could then render the preferential treatment of SAF inappropriate and counterproductive.

For this reason I would encourage you to ensure that any special treatment afforded to SAF is limited and can be phased out when circumstances no longer support the special treatment. For example, the special accounting treatment for each new pathway could be contingent on a determination that the scale of SAF production is still below a target level that demonstrates that special treatment is appropriate. This would be consistent with the caps put in place on other special treatment, for example capacity based credits for ZEV infrastructure.

I would also encourage you to set stringent limits on the use of book and claim accounting for biomethane. Without these limits book and claim accounting can undermine the support for investment in Washington's fuel system and function instead as a offset (for more details, see my February blog at https://blog.ucsusa.org/jeremy-martin/something-stinks-california-must-end-manure-biomethane-accounting-gimmicks-in-its-low-carbon-fuel-standard/).

Thank you for the opportunity to comment on this.

Regards,

Jeremy

Jeremy I. Martin, Ph.D.
Director of Fuels Policy, Senior Scientist
Pronouns: he / him / his
Clean Transportation Program, Union of Concerned Scientists

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Comment From: SkyNRG (Alli McIntosh)

6/07/24 @ 2:50 PM

Please see the attached document for comments from SkyNRG regarding the Washington Clean Fuel Standard (CFS) rulemaking.

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Comment From: Climate Solutions (Leah Missik)

6/07/24 @ 2:30 PM

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Comment From: EV Realty (Jamie Hall)

6/07/24 @ 2:18 PM

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Comment From: Cascade Natural Gas Corporatio... (Abbie Krebsbach)

6/07/24 @ 2:03 PM

Please see attached comment letter pdf from Cascade Natural Gas Corporation

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Comment From: Coalition for Renewable Natura... (Dana Adams)

6/07/24 @ 1:55 PM

Please see attachment for comments.

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Comment From: NovoHydrogen (Jackson Becce)

6/07/24 @ 1:42 PM

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Comment From: MN8 Energy (Jake Spolan)

6/07/24 @ 1:39 PM

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Comment From: Forum Mobility (Adam Browning)

6/07/24 @ 1:21 PM

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Comment From: Global Clean Energy (Amanda Parsons DeRosier)

6/07/24 @ 12:59 PM

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Comment From: Powering America's Commercial ... (David Bonelli)

6/07/24 @ 12:07 PM

Please see attached comments from Powering America's Commercial Transportation (PACT) on the Clean Fuel Standard Informal Comment Period.

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

6/07/24 @ 11:56 AM

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Comment From: RPMG

6/07/24 @ 11:46 AM

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Comment From: Electric Vehicle Charging Asso... (Brian Bonlender)

6/07/24 @ 11:44 AM

Please see attached letter for EVCA comments.

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Comment From: POET (Joshua Wilson)

6/07/24 @ 10:52 AM

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Comment From: FirstElement Fuel (Matt Miyasato)

6/07/24 @ 10:38 AM

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Comment From: EVgo (Noah Garcia)

6/07/24 @ 10:23 AM

Comments attached - thank you.

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Comment From: Puget Sound Energy (Jessica Zahnow)

6/07/24 @ 9:45 AM

June 7, 2024

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

RE: PSE informal comments on Ecology's Clean Fuel Standard Rulemaking revising Chapter 173-424 of the ...↓

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Comment From: Growth Energy (Dallas Gerber)

6/07/24 @ 8:24 AM

Please see the attached comments from Chris Bliley, Growth Energy's Senior Vice President of Regulatory Affairs.

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Comment From: PineSpire Anonymous

6/06/24 @ 10:56 AM

Thank you for considering PineSpire's comments on the current rulemaking

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Comment From: Christianson PLLP (Kari Buttenhoff)

6/06/24 @ 5:19 AM

Our comments are attached. Thank you.

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Comment From: ChargePoint (Nate Schuster)

6/05/24 @ 7:39 AM

Please see attachment

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Comment From: Bridge To Renewables, Inc. (Jack Barrow)

5/31/24 @ 2:40 PM

Bridge To Renewables, Inc. (BTR) is pleased to provide comments on potential changes to Washington's Carbon Fuel Standard ("CFS") program in response to the CFS Rulemaking Workshop on May 8th, 2024. We appreciate the opportunity to engage with Depart...↓

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Comment From: SRECTrade (Evan Rosenberg)

5/30/24 @ 5:53 PM

Please find comments in the attached.

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Comment From: Beta Analytic Inc. (Benjamin Kling)

5/30/24 @ 12:08 PM

Please see Beta's comments in the attached document. We appreciate the opportunity to share our feedback very much, thank you!

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

5/15/24 @ 8:37 AM

Please find attached SCT comments on the 3rd-Party Verification rulemaking.

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Comment From: Puget Sound Energy (Chris Leyerle)

5/08/24 @ 11:26 AM

Thank you for the workshop/meeting today. Following up on the intersection of 3PV and book-and-claim. Abbey stated that this was still being worked on, and also that the Producer rather than the Reporter would be the obligated party for 3PV. As a pra...↓

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