Chapter 173-424 WAC and WAC 173-455-150, Clean Fuels Standard Rulemaking Informal Comment Period

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Comment From: Reemah Karvir

3/04/26 @ 12:08 AM

To Whom It May Concern,

My name is Reemah Karvir, and I am a student in Washington State. I appreciate the opportunity to comment on rulemaking for Chapter 173-424 WAC – Clean Fuel Standard (CFS).

Decarbonizing transportation is extremely importa...↓nt, as it remains Washington's largest source of greenhouse gas emissions, accounting for 38.2 million metric tons. I strongly support the strengthening of the CFS to increase carbon intensity reduction requirements from 20% to 45% below 2017 levels by 2038.

Additionally. I support the planned update of the WA-GREET model in order to ensure that the carbon intensity calculations rely on the most current scientific methodology. However, I would like to also emphasize the importance of making the updated model accessible to the public. Providing clear explanations of how lifecycle greenhouse gas emissions are calculated would allow members of the community to better evaluate their effectiveness. Regarding the GREET model, how will it be reviewed or audited over time to ensure that its assumptions remain scientifically valid and aligned with emissions outcomes?

Another area that would benefit from clarification is the feasibility of meeting the increased reduction targets within the proposed timeline. The goal to reduce transportation fuel emissions by 45% by 2038 is definitely strong; I am curious to know in greater detail how progress will be monitored and adjusted. What benchmarks or targets will be used to ensure that the program remains on track?

I also support the consideration of technical amendments to improve implementation, fee structure, and the integrity of credited emissions reductions. There should be very clear safeguards in place to prevent inflated/inaccurate crediting. Reductions claimed under the program should reflect measurable (as well as verifiable) environmental benefits.

One area I urge the Department of Ecology to consider further is affordability. As the Clean Fuel Standard expands, it is important to ensure that the transition to low-carbon fuels doesn't disproportionately impact low-income communities that may have limited access to alternative fuels or electric vehicles. One last concern I have regarding this is that while this would promote sustainability in the long-term, the short-term price increases this comes with could disproportionately affect working families dependent on transportation for employments and to sustain themselves.

Overall, I support the rulemaking effort and believe that strengthening the CFS is a key step toward achieving Washington's climate goals.

Sincerely,
Reemah Karvir

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Comment From: FuSE (Todd Trauman)

3/03/26 @ 10:57 PM

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Comment From: Earthjustice (Sara Gersen)

3/03/26 @ 9:12 PM

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Comment From: RNG COALITION (Yanni Psareas)

3/03/26 @ 8:51 PM

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Comment From: RNG COALITION (Yanni Psareas)

3/03/26 @ 8:48 PM

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Comment From: Renewable Hydrogen Alliance (R... (Rebecca Smith)

3/03/26 @ 6:39 PM

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Comment From: Washington Conservation Action (Caitlin Krenn)

3/03/26 @ 6:23 PM

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Comment From: RHA and H2FCP (Rebecca Smith)

3/03/26 @ 6:22 PM

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Comment From: Promus Energy LLC (Dan Evans)

3/03/26 @ 5:51 PM

Please see comments attached.

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Comment From: Growth Energy (Dallas Gerber)

3/03/26 @ 5:45 PM

Please see the attached comments from Growth Energy.

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Comment From: Washington Green Hydrogen Alli... (Michael Lord)

3/03/26 @ 5:38 PM

Please see attached file.

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Comment From: International Council on Clean... (Andy Navarrete)

3/03/26 @ 4:58 PM

See attachment

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Comment From: Tesla (Mal Skowron)

3/03/26 @ 4:39 PM

Please see attached comments of Tesla, Inc.

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Comment From: Zeem Solutions (Margaret Boelter)

3/03/26 @ 4:33 PM

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Comment From: Bayer Crop Science (Chelsey Robinson)

3/03/26 @ 4:05 PM

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

3/03/26 @ 3:08 PM

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Comment From: Clean Air Task Force (Dan West)

3/03/26 @ 2:52 PM

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Comment From: Neste (Oscar Garcia)

3/03/26 @ 2:31 PM

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Comment From: Maddie (Maddie Carlyle)

3/03/26 @ 2:15 PM

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Comment From: Montana Renewables, LLC (Corey Lavinsky)

3/03/26 @ 2:05 PM

Thank you for advancing policies that support the renewable fuels industry and environmental sustainability. Our comments are set forth in the attached letter from our CEO Bruce Fleming.

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Comment From: Friends of the Earth (Molly Armus)

3/03/26 @ 12:58 PM

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Comment From: Angela Song (Angela Song)

3/03/26 @ 10:23 AM

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Comment From: POET, LLC (Paul Townsend)

3/03/26 @ 9:31 AM

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Comment From: Twelve Benefit Corporation (Ira Dassa)

3/03/26 @ 8:53 AM

Please see the attached for Twelve Benefit Corporation's informal comments.

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Comment From: Advanced Biofuels Canada (Fred Ghatala)

3/02/26 @ 7:04 PM

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Comment From: Clean Fuels Alliance America (Cory-Ann Wind)

3/02/26 @ 6:45 PM

Thank you for the opportunity to submit comments on behalf of the Clean Fuels Alliance America.

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Comment From: Climate Solutions (Leah Missik)

3/02/26 @ 5:02 PM

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Comment From: King County (David Eldred)

3/02/26 @ 11:25 AM

Thank you for the opportunity to provide written comment in the attached uploaded file. King County would welcome the opportunity to discuss our feedback further with Ecology staff. Please reach out to Peter Heffernan at
Peter.Heffernan@kingcounty.go...↓

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

3/02/26 @ 10:30 AM

See comments attached. Thanks for the opportunity to share feedback.

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Comment From: SkyNRG Americas (John Plaza)

3/02/26 @ 10:02 AM

See attached informal comments from SkyNRG Americas on Chapter 173-424 WAC and WAC 173-455-150, Clean Fuels Standard Rulemaking

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Comment From: Electrochaea Corporation (April Arbour)

2/27/26 @ 9:59 AM

Electrochaea provides industrial-scale technology for the production of renewable synthetic natural gas. This fuel is produced through methanation, a process that synthesizes synthetic natural gas (an e-fuel) using electrolytic hydrogen and carbon di...↓

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Comment From: Xpansiv (SRECTrade) (Ryan Huggins)

2/25/26 @ 11:31 AM

Please see our attached comments

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Comment From: Justin Barnhart

2/24/26 @ 2:44 PM

Washington State Department of Ecology
Clean Fuels Program Rulemaking

Thank you for the opportunity to provide informal comments regarding the proposed amendments to Chapter 173-424 WAC and WAC 173-455-150 implementing SSHB 1409.

I submit these com...↓

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Comment From: James Mladenik

2/24/26 @ 2:39 PM

My general comment is that due to the slowdown of electric vehicle sales and limitations on the availability of renewable diesel, the chances of being able to meet the higher carbon-intensity reduction levels scheduled in the 2030s are not good. The...↓

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Comment From: Laura Soma

2/10/26 @ 12:40 PM

I would like to see the State fuel taxes removed or discounted for R-99 diesel, R-99 Diesel mix, and bio-diesels. I don't believe that companies making extra efforts to utilize reduced carbon fuels should have to pay the same taxes. These reduced ca...↓

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Comment From: Kyle Hutchinson

1/21/26 @ 10:51 AM

The clean fuel standard imposes unnecessary cost and bureaucracy that costs everyday Washingtonians. Every product and service a citizen uses has a cost impact associated with the price of fuel. Further, society has not agreed upon a target CO2 level...↓

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