Rulemaking - Informal Public Comment Period for Chapter 173-424 WAC, Clean Fuels Program Rule

147 Results

Sort:

Comment From: Shell - Hydrogen Mobility (Neil Bhagia)

5/05/22 @ 11:58 AM
Attachments:

Comment From: Tesla (Thad Kurowski)

4/28/22 @ 9:18 PM
Attachments:
Download
Download

Comment From: National Sorghum Producers (John Duff)

4/28/22 @ 7:19 PM
See our comments attached.
Attachments:

Comment From: Growth Energy (Chris Bliley)

4/28/22 @ 7:16 PM
Attachments:

Comment From: Neste (Oscar Garcia)

4/28/22 @ 6:15 PM
Attachments:

Comment From: WSPA (Jim Verburg)

4/28/22 @ 4:57 PM
Attachments:

Comment From: bp America Inc. (Mark Bunch)

4/28/22 @ 4:35 PM
Ecology team, please find bp comments on Lookup table attached. Many thanks
Attachments:

Comment From: MPC (Brian McDonald)

4/28/22 @ 4:10 PM
MPC comments on 173-424 WAC. CI Lookup Table
Attachments:

Comment From: Phillips 66 Company (Marc Ventura)

4/28/22 @ 1:54 PM
This comment is in response to the CI lookup tables emailed on April 26, 2022, by Rachel Assink.

Ecology should correct the following the CI lookup values in tables 4 and 8:
- WSGAS002, Washington gasoline blended with corn ethanol: The CI value should...↓
- WAULSD002, Washington diesel blended with soy biodiesel: The CI value should be established on typical biodiesel blends supplied in the state, rather than the arbitrary proposed 2.5% biodiesel blend. Ecology could established instead a CI value for "B5" (5% biodiesel) for WAULSD002 and create another pathway, for example WAULSD003, with a CI value for "B20" (20% biodiesel).
- WAULSD0116, substitute CI for B5 diesel: The CI value is actually calculated for 2.5% biodiesel blend, not 5% biodiesel blend. Ecology should update the definition of WAULSD0116 and establish the CI value based on the average percentage of biodiesel in diesel fuel sold in Washington State.
No attachments

Comment From: Jay Gordon

4/28/22 @ 12:42 PM
Rachel,
I cannot see that table 4 on page three shows RNG as a motor fuel from any sources...right now we have 1 dairy farm making compressed, scrubbed RNG into pipeline and expect more farms potentially along with existing and future electric generat...↓
I may be missing something here on this, but would rather ask now and be wrong that miss asking the question.

Thanks for all your hard work on this.
Jay Gordon
No attachments

Comment From: BayoTech Hydrogen (Gabriel Olson)

4/28/22 @ 11:18 AM
Supplemental / Updated Comments - please disregard the earlier submission made in error.
Attachments:

Comment From: BayoTech Hydrogen (Gabriel Olson)

4/28/22 @ 7:35 AM
BayoTech.us appreciates the opportunity to comment on the draft carbon intensity lookup table that has been prepared as part of the development of rulemaking for the Washington CFS program. Please see the attached comment letter with our specific co...↓
Attachments:

Comment From: King County (Rachel Brombaugh)

4/27/22 @ 5:56 PM
Attachments:

Comment From: 3Degrees (Maya Kelty)

4/27/22 @ 3:35 PM
Please find attached 3Degrees' comments in response to the Informal Public Comment Period for Chapter 173-424 WAC, Washington Clean Fuels Program. We appreciate Staff's consideration of our comments.
Attachments:

Comment From: Divert Inc. (Ryan Begin)

4/27/22 @ 1:45 PM
The CI scores referenced for food waste RNG facilities seem aggressively high. The food waste RNG facilities that we have designed and are constructing have CI scores between -72 and -79. These numbers come from both the CARB GREET and Canadian GHG m...↓
No attachments

Comment From: e bronstad

4/27/22 @ 11:56 AM
Please expound on the difference in CI scores between the feedstocks labeled "Digester" and "Municipal sludges". It's a safe bet that CNG generated by sludges and food waste will come from a digester, so it's very confusing to have annotations like ...↓
Wastewater sludge, Food Waste, Green Waste, or Other Organic Waste".
No attachments

Comment From: e-Mission Control (Elaine O'Byrne)

4/27/22 @ 11:39 AM
Please find our comments on the rulemaking attached.
Attachments:

Comment From: Western Washington Clean Citie... (Michael Graham)

4/25/22 @ 9:40 PM
Thank you for the opportunity to comment and your work on this program. Please let us know what questions you have.

Warmest Regards,

Michael
Attachments:

Comment From: Researchers at UC Davis Policy... (Julie Witcover)

4/25/22 @ 9:20 PM
Please see the attached file, with comments from myself, Colin Murphy, and Jin Wook Ro at the UC Davis Policy Institute for Energy, Environment, and the Economy.
Attachments:

Comment From: Washington Environmental Counc... (Caitlin Krenn)

4/25/22 @ 8:42 PM
Attachments:

Comment From: WSPA (Jim Verburg)

4/25/22 @ 8:38 PM
Attachments:

Comment From: Ben Farrow

4/25/22 @ 8:37 PM
Attachments:

Comment From: POET, LLC (Janie Kilgore)

4/25/22 @ 7:55 PM
Attachments:

Comment From: BTR Energy (Ashley Patterson Beaty)

4/25/22 @ 6:41 PM
Please see enclosed comments for BTR Energy, thank you.
Attachments:

Comment From: Clean Energy (Todd Campbell)

4/25/22 @ 5:44 PM
Attachments:

Comment From: SRECTrade, Inc (Evan Rosenberg)

4/25/22 @ 5:24 PM
Attachments:

Comment From: CleanFuture, Inc. (John Thornton)

4/25/22 @ 5:00 PM
Please find comments attached.
No attachments

Comment From: Renewable Hydrogen Alliance (Dave Warren)

4/25/22 @ 4:59 PM
Attachments:

Comment From: Audi of America, Inc. (Spencer Reeder)

4/25/22 @ 4:56 PM
Attachments:

Comment From: Tacoma Power (Kyle Frankiewich)

4/25/22 @ 4:52 PM
Attachments:

Comment From: Electrify America, LLC (Andrew Dick)

4/25/22 @ 4:52 PM
Please find attached comment from Electrify America, LLC, on the draft Clean Fuels Program rule.
Attachments:

Comment From: EVgo (Adam Mohabbat)

4/25/22 @ 4:51 PM
Attachments:

Comment From: Northwest Seaport Alliance (Jason Jordan)

4/25/22 @ 4:39 PM
Attachments:

Comment From: Forth (Jeanette Shaw)

4/25/22 @ 4:37 PM
Please see attached PDF for comments from Forth on the draft Clean Fuels rulemaking.
Attachments:

Comment From: Puget Sound Energy (Cassie Bordelon)

4/25/22 @ 4:36 PM
Attachments:

Comment From: Earth Ministry/Washington Inte... (Jessica Zimmerle)

4/25/22 @ 4:36 PM
Attachments:

Comment From: Scott Kennedy

4/25/22 @ 4:35 PM
Attachments:

Comment From: Rivian Automotive, LLC (Tom Van Heeke)

4/25/22 @ 4:32 PM
Attachments:

Comment From: Clean Fuel Washington (Tim Zenk)

4/25/22 @ 4:27 PM
Attachments:

Comment From: AMPLY Power (Heidi Sickler)

4/25/22 @ 4:08 PM
Attachments:

Comment From: Marathon Petroleum Corporation... (Brian McDonald)

4/25/22 @ 3:43 PM
MPC comments to 173-424 WAC, Clean Fuels Program
Attachments:

Comment From: Twelve Benefit Corp (Andrew Stevenson)

4/25/22 @ 3:42 PM
Attachments:

Comment From: Remora (Christina Reynolds)

4/25/22 @ 3:36 PM
Attachments:

Comment From: EV Charging Coalition (Cory Bullis)

4/25/22 @ 3:33 PM
Please see attached comment letter from a coalition of EV charging companies.
Attachments:

Comment From: SkyNRG Americas, Inc. (Amy Malaki)

4/25/22 @ 3:19 PM
Attachments:

Comment From: Puget Sound Clean Air Agency (Kathy Strange)

4/25/22 @ 3:10 PM
Attachments:

Comment From: Diamond Alternative Energy (Lori Taylor)

4/25/22 @ 3:02 PM
Attachments:

Comment From: Delta Air Lines (Margaret Campbell)

4/25/22 @ 2:35 PM
Attachments:

Comment From: Clean Fuels Alliance America a... (Floyd Vergara)

4/25/22 @ 2:27 PM
For your consideration, please see the enclosed joint comments from Renewable Energy Group, Darling Ingredients, World Energy, SeQuential Biodiesel, Crimson Renewable Energy, and Clean Fuels Alliance America.
Attachments:

Comment From: Washington State Department of... (Jonathan Olds)

4/25/22 @ 2:17 PM
Please see attached WSDOT Comments ECY CR 101 WAC 173_424 document.
Attachments:

Comment From: Smart Charging Technologies LL... (MAN ALTAHER)

4/25/22 @ 1:51 PM
Please see our comments in the attached file.
Attachments:

Comment From: Rod Whittaker

4/25/22 @ 1:49 PM
Comments of the Washington Refuse and Recycling Association.
Attachments:

Comment From: Smart Charging Technologies LL... (MAN ALTAHER)

4/25/22 @ 1:43 PM
This is to correct the contact email address for the Smart Charging Technologies comment submitted earlier.
No attachments

Comment From: Smart Charging Technologies LL... (MAN ALTAHER)

4/25/22 @ 1:39 PM
Please find our comments attached.

Best Regards,

Ma'n
Attachments:

Comment From: Twelve Benefit Corp. (Andrew Stevenson)

4/25/22 @ 1:28 PM
Attachments:

Comment From: Cargill, Inc. (Gary Kay)

4/25/22 @ 1:08 PM
Attachments:

Comment From: Carbon Removal Buyers, Develop... (Annie Gilleo)

4/25/22 @ 1:07 PM
Please see the attached comments jointly submitted by Stripe, The Future Forest Company, Charm Industrial, CarbonBuilt, SeaChange Inc., Remora, Eion, Ebb Carbon, CarbonCure, 44.01, Heirloom, Running Tide, and the Foundation for Climate Restoration
Attachments:

Comment From: Union of Concerned Scientists (Jeremy Martin)

4/25/22 @ 12:56 PM
See attached comment letter.
Attachments:

Comment From: Renewable Fuels Association (Tom Koehler)

4/25/22 @ 12:54 PM
Attachments:

Comment From: Low Carbon Fuels Coalition (Robin Vercruse)

4/25/22 @ 12:49 PM
The attached comments are from the Low Carbon Fuels Coalition Executive Director Graham Noyes on behalf of the Coalition.
Attachments:

Comment From: Airlines for America (A4A) (Ira Dassa)

4/25/22 @ 12:33 PM
Attachments:

Comment From: Coalition for Renewable Natura... (Sam Lehr)

4/25/22 @ 12:33 PM
Attachments:

Comment From: NW Energy Coalition (Annabel Drayton)

4/25/22 @ 12:17 PM
Attachments:

Comment From: Port of Seattle (Sandra Kilroy)

4/25/22 @ 11:44 AM
Attachments:

Comment From: Natural Gas Vehicles for Ameri... (Sherrie Merrow)

4/25/22 @ 11:25 AM
Dear Director Watson and Ms. Assink:

Natural Gas Vehicles for America (NGVAmerica), the national trade association for the natural gas vehicle industry, respectfully submits the attached comments on the State of Washington Clean Fuels Program Draft Ru...↓

Please let me know if you have any questions.

Sincerely,

Sherrie Merrow
Director, State Government Affairs
NGVAmerica
smerrow@ngvamerica.org
303.883.5121
Attachments:

Comment From: Pacific Propane Gas Associatio... (Matt Solak)

4/25/22 @ 11:24 AM
Attachments:

Comment From: Nuvve Holding Corp (Jacqueline Piero)

4/25/22 @ 10:58 AM
Attachments:

Comment From: Ryan Mello

4/25/22 @ 10:30 AM
Dear Rachel Assink,

Thank you for the opportunity to submit joint comments on rules pertaining to the Clean Fuel Standard. I am very supportive of a Clean Fuel Standard in Washington State, and believe the rule should be as strong as possible. For tha...↓

The Legislature granted the Department of Ecology the authority to set this trajectory, which most closely aligns with achieving the statutory reduction in greenhouse gas emissions that Washington is committed to. A 20% reduction in 2034 is also closer to those in other states with Clean Fuel Standards. Both California's and British Columbia's current programs require a 20% reduction by 2030. Oregon is currently in the process of expanding their Clean Fuels Program, and as a result of public feedback, they are considering a standard of 20% below 2015 levels by 2030 and 37% below 2015 levels by 2035.

A 20% reduction in carbon intensity by 2034 is more aligned with Washington State policy, other state's programs, and will lead to faster pollution reductions and the commensurate benefits to our health and well-being. It will lead to a strong signal for greater clean fuels investments in the near term, to the benefit of Washingtonians.

Sincerely,

Ryan Mello
Pierce County Councilmember - District 4
No attachments

Comment From: Chelan County PUD (Andrew Grassell)

4/25/22 @ 8:52 AM
Attachments:

Comment From: Neste (Oscar Garcia)

4/25/22 @ 6:52 AM
Attachments:

Comment From: Nuseed (Glenn Johnston)

4/23/22 @ 11:18 AM
Attachments:

Comment From: Climate Solutions (Leah Missik)

4/22/22 @ 8:01 PM
Attachments:

Comment From: bp America Inc. (Mark Bunch)

4/22/22 @ 6:14 PM
Ecology team, please find bp comments relating to rulemaking workshop #5. Best wishes, Mark Bunch
Attachments:

Comment From: Multiple Utility Organizations... (Marian Dacca)

4/22/22 @ 4:58 PM
Attachments:

Comment From: City of Seattle (Mendy Droke)

4/22/22 @ 1:29 PM
Attachments:

Comment From: 350 Seattle (David Perk)

4/21/22 @ 11:51 AM
Attachments:

Comment From: Sound Transit (Kimberly Farley)

4/21/22 @ 11:35 AM
Attachments:

Comment From: Center for Resource Solutions (Lucas Grimes)

4/21/22 @ 10:33 AM
Attachments:

Comment From: Oberon Fuels, Inc. (David Mann)

4/21/22 @ 4:31 AM
Attachments:

Comment From: Audubon Washington (Adam Maxwell)

4/20/22 @ 5:27 PM
Thank you for the opportunity to submit comments on rules pertaining to the Clean Fuel Standard. Audubon Washington recognizes that climate change and associate air pollution from fossil fuel represents a grave threat to birds and people. As such we ...↓

The Legislature granted the Department of Ecology the authority to set this trajectory, which most closely aligns with achieving the statutory reduction in greenhouse gas emissions that Washington is committed to. A 20% reduction in 2034 is also closer to those in other states with Clean Fuel Standards. Both California's and British Columbia's current programs require a 20% reduction by 2030. Oregon is currently in the process of expanding their Clean Fuels Program, and as a result of public feedback, they are considering a standard of 20% below 2015 levels by 2030 and 37% below 2015 levels by 2035.

A 20% reduction in carbon intensity by 2034 is more aligned with Washington State policy, other state's programs, and will lead to faster pollution reductions and the commensurate benefits to our health and well-being. It will lead to a strong signal for greater clean fuels investments in the near term, to the benefit of Washingtonians.

Sincerely,
Adam Maxwell, Audubon Washington
No attachments

Comment From: Lineage Logistics LLC (CHRIS THURSTON)

4/20/22 @ 9:10 AM
LINEAGE LOGISTICS OPERATES 26 COLD STORAGE FACILITIES, OVER 7M SQUARE FEET OF SPACE WITH A SIZEABLE ELECTRICITY LOAD AND PART OF THE COLD SUPPLY CHAIN WHICH HAS A LARGE CARBON FOOTPRINT GIVEN THE DEMANDS AROUND ELECTRIC GENERATION AND TRUCKS COMING I...↓

HERE AT LINEAGE, WE ARE COMMITTED TO SUSTAINABILITY AND HAVE INVESTED HEAVILY INTO ON-SITE GENERATION VIA SOLAR WITH OVER 160MW DOMESTICALLY. TAKING IT ONE STEP FURTHER, OUR GOAL IS TO GENERATE AS MUCH CLEAN POWER ON-SITE AND FIND WAYS TO DISTRIBUTE IT LOCALLY TOWARDS CARBON EMITTING PROCESSES SUCH AS DIESEL TRANSPORTATION AND DIESEL REEFER UNITS OR MORE COMMONLY KNOW AS TRUS. THIS PROCESS WHAT WE CALL "ELECTRIFICATION OF OUR YARDS" REQUIRES A SUBSTANTIAL CAPITAL OUTLAY. WHILE THERE IS SOME OPPORTUNITY FOR US TO CHARGE THIS COST BACK TO TRANSPORTATION PROVIDERS, THE LCFS INCENTIVES IN CA AND OR WERE WRITTEN IN SUCH A WAY TO MAKE IT DIFFICULT FOR 3PL PROVIDERS SUCH AS US TO MONETIZE THESE CREDITS EVEN THOUGH WE ARE IN A PERFECT POSITION TO CREATE THAT INFASTRUCTURE.

OUR HOPE IS THAT WA STATE LEARN FROM THIS IN THEIR RULE MAKING IN AN EFFORT TO MEET ALL OF OUR GOALS WHICH IS TO HELP REDUCE THE NEGATIVE IMPACTS OF CARBON ON OUR ENVIRONMENT.

THANK YOU
No attachments

Comment From: Suburban Propane (Paul Rozenberg)

4/19/22 @ 7:33 AM
Attachments:

Comment From: Advanced Biofuels Canada (Ian Thomson)

4/18/22 @ 9:13 PM
Dear Rachel Assink,

Thank you for the opportunity to submit joint comments on rules pertaining to the Clean Fuel Standard. Our organization is the primary advocate of the BC LCFS; we have worked for over a decade to support the success of the standard...↓

We believe that WA very plausibly set a target of 20% CU reduction by 2034. When the BC and California LCFS were established, the compliance options were limited. Notwithstanding this, obligated parties have adapted to stringent requirements. A WA CFS will have a plethora of compliance choices, a number of which were in their infancy a decade ago.

We believe that a 20% reduction by 2034 can be reached through electric mobility, advanced biofuels, renewable natural gas, and hydrogen. To reach a 20% target, WA does not need credit generation to come from CI improvements in fossil fuels. Given that the largest portion of tailpipe GHG comes from the crude in gasoline and diesel, it is important to ensure that the majority of crediting comes from actions that displace crude oil.

We would be pleased to offer additional information relative to the BC LCFS.

Sincerely,

Ian Thomson
President
Advanced Biofuels Canada
No attachments

Comment From: Clean Fuels Alliance America (Floyd Vergara)

4/18/22 @ 4:22 PM
Please replace the April 8th comment letter we submitted earlier with this version, which corrects a typographical error on page 3 (replaces "10%" with "20%" in the heading).
Attachments:

Comment From: SRECTrade, Inc (Iman Nordin)

4/13/22 @ 8:16 AM
Attachments:

Comment From: Clean Fuels Alliance America (Floyd Vergara)

4/13/22 @ 1:08 AM
Attachments:

Comment From: Public Utility District No. 1 ... (James White)

4/07/22 @ 10:33 AM
Chelan County PUD's spreadsheet "WA Utility LCFS Credit Calculator 3-30-22.xlsx", that was presented and discussed with the Department of Ecology and electric utilities at their meeting that was held at 3 PM on March 31, 2022, has been emailed to Deb...↓
No attachments

Comment From: WSPA (Jim Verburg)

4/01/22 @ 7:53 PM
Attachments:

Comment From: bp America Inc. (Mark Bunch)

3/31/22 @ 3:09 PM
Please find bp comments relating to workshop #4 of Washington Clean Fuels Program Rule. Thank you.
Attachments:

Comment From: Spokane City Council Members (Breean Beggs)

3/29/22 @ 9:38 AM
Attachments:

Comment From: Avista Corp (John Rothlin)

3/25/22 @ 7:37 PM
Attachments:

Comment From: WSPA (Jim Verburg)

3/25/22 @ 4:43 PM
Attachments:

Comment From: Washington Environmental Counc... (Rebecca Ponzio)

3/25/22 @ 1:49 PM
Attachments:

Comment From: POET, LLC (Janie Kilgore)

3/25/22 @ 12:08 PM
Attachments:

Comment From: Avista Corp (John Rothlin)

3/25/22 @ 9:31 AM
Attachments:

Comment From: CalPortland (Brent Ludeman)

3/24/22 @ 11:13 AM
Attachments:

Comment From: Smart Charging Technologies LL... (MAN ALTAHER)

3/15/22 @ 11:46 AM
Regarding Forklifts credit, we do advocate that credit goes to the charging equipment owner, not to the fleet owner. This will avoid problems with rentals.
No attachments

Comment From: Multiple organizations (Leah Missik)

3/14/22 @ 10:49 AM
Please see the attached comments from Audubon Washington, Climate Solutions, Climate Reality WA State Coalition, Coltura, NW Energy Coalition, Sierra Club Washington State Chapter, The Nature Conservancy, Union of Concerned Scientists, Washington Bla...↓
Attachments:

Comment From: PineSpire (Ryan Huggins)

3/14/22 @ 5:06 AM
Thank you for considering the attached comments on the proposed Rule
Attachments:

Comment From: Alliance for Automotive Innova... (Dan Bowerson)

3/11/22 @ 12:46 PM
Please find the attached letter from the Alliance for Automotive Innovation.
Attachments:

[ Previous Page / Next Page ]