Chapter 173-446 WAC: Cap-and-Invest US Forest Offsets Protocol Formal Comment Period

Thank you. Yes. Um, I'm, uh, concerned that, um, whatever,

however your process, um, is that it that it actually measures the reduced carbon in a way that is, um, real, so that so that you're, you're not. The

process has to be, um, aligned with what's ...↓actually happening on the ground. And my concern comes from experiences at state agencies like DNR and um, watching their processes DNR and uh, um, Department of Commerce, others uh, where there's uh, assumption there are assumptions that, uh, for instance, uh, removing biomass from a forest reduces fire load, that kind of thing, or that, uh. Wood products are, um, more are sequestering more carbon than they are. Um, so, um, as you know, the, uh, we're actually lagging behind in, uh, cutting our carbon emissions in the state of Washington. Our in law, we're our carbon limit for twenty thirty is, or I should say, our greenhouse gas emissions limit for twenty thirty is a forty five percent reduction from nineteen ninety levels. We're not getting there, and I'm concerned that part of the reason is because we're not really understanding the physical carbon reduction effects of our actions. So I think there should be some way of evaluating whether this Cap and

invest program is actually succeeding in reducing carbon emissions, greenhouse gas emissions in the real world. And I am also concerned that, for instance, in the state legislature there's no difference. And at DNR there is no difference between um timber Plantations and naturally regenerated forests. That's, uh, that's kind of a big blind side. Uh, big blind spot. And so I guess I'm, I'm concerned that whatever you do is actually reducing greenhouse gas emissions in the real world, and we're not stuck with old definitions or outdated concepts. Thank you. Yeah. I don't know if I said my name. Donna Albert. D-o-n-n-a A-l-b-e-r-t. Montesano, Washington. Thank you.

Hello. Um, my name's Grayson Badgley. That's G-r-a-y s-o-n

and Badgley is B-a-d-g-l-e-y. Lower my hand. All right. And I'll start my

comment. Uh, I want to first start by thanking ecology for the opportunity to

comment today. And I also want to take a m...↓oment to thank Jordan in particular.

Um, Jordan, I know you've worked on this, um, very hard for a number of years,

and. Yeah, uh, I just it's worth recognizing all the hard work that I know has

gone into this. Um, I've been engaged with ecology for about two years in

developing the revisions to this forest protocol that are proposed in this rulemaking,

uh, that started with my participation on, uh, ecology's US Forest Offset

Protocol technical working group. Uh, and it's continued. Uh, the last two

rounds of informal comment of the draft versions of this proposed protocol.

I've submitted comments. I've spoken with Jordan on various occasions

throughout that process. I've relied on my training, my academic training as a

forest ecologist. I have a PhD in forest ecology and plant physiology and on my

expertise in the carbon markets, which I've been studying and researching for

the past several years. It's with that background that I can confidently say

that Ecology's proposed protocol fails to satisfy its statutory requirement

that its offsets are real and permanent. I think ecology has done some good

things. I think they really have made some steps to lower the likelihood of

issuing nonadditional credits, and I think it's great that there's going to be

spatially explicit risks. But when it comes to how the proposed protocol

specifies buffer pool contributions for wildfire and insect risk, uh, there's,

uh, some real scientific problems, in particular critical assumptions about the

maximum risk of wildfire loss at twelve percent and insect risk being capped at

eight percent over the next one hundred years. It has no basis in science. It

has no basis in the scientific literature. These assumptions were not discussed

in the various technical work, group meetings, and on multiple occasions I've

asked ecology where these numbers came from, and I really haven't had one yet.

Uh, there's equally arbitrary decisions that have been made around, um,

reductions in these risks from vegetation management plans. It's a fifty

percent reduction for vegetation management plans. That is written in the

protocol don't have. They're very ill defined. It doesn't even say the

vegetation management plan has to address specific insect risks. Uh, it's

started as an eighty percent reduction and now it's just a fifty percent

reduction. But where did those numbers come from? I don't know, but what I can

tell you is they do not come from the scientific literature. Combined together,

these two arbitrary decisions of capping risk and arbitrarily allowing for

reduction of those arbitrary risks means that we have no assurances that

offsets issued under this rule will be real or permanent, which is required by

statute. Thank you.