Rulemaking - Clean Fuels Program Rule and Air Quality Fee Rule
Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Jo Harvey 204 Eastgate Ave NPacific, WA 98047
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Judy Palmer 361 Rehmke RdTonasket, WA 98855
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, John Macdonald 136 3rd Ave NEdmonds, WA 98020
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Lynn Rabenstein 201 N Section StBurlington, WA 98233
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.a Clean Fuels Program must prioritize the reduction of environmental health disparities, uphold requirements for Tribal consultation, be guided by the best available science, and be publicly transparent and accountable. And of coarse the use of the best available scientific information!Thank you for your consideration.Sincerely, d robinson 1 River StCurlew, WA 99118
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.We need to take better care of what is left of our environment, for wildlife, marine life, plant life, and people.Thank you for your consideration.Sincerely, Priscilla Martinez 35411 SE English StSnoqualmie, WA 98065
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Dear Ms. Rachel Assink,Thank you very much for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half o...↓f Washington's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Steve Brown 460 Big Leaf LoopSequim, WA 98382
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, STEPHANIE BELL 21507 42nd Ave SSeatac, WA 98198
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC, and all the work to date in developing this rule. Transportation is responsible for nearly half of Washing...↓ton's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track the reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. The program mustn't inadvertently incentivize increased emissions of pollutants harmful to human health and the environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect the best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, and corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Matthew Boguske 8500 148th Ave NERedmond, WA 98052
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Melanie Kenoyer 708 W 24th StVancouver, WA 98660
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Joan Truskoff 118 N 58th StSeattle, WA 98103
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Jennie Blake 1112 O'Farrell Ln NWOrting, WA 98360
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, John Guros 308 10th St SMontesano, WA 98563
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Nina Minsky 2788 Nevada Ave EPort Orchard, WA 98366
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Kristin Fitzpatrick 1501 30th AveSeattle, WA 98122
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Jeff Green 2097 Tidepool Pl EPort Orchard, WA 98366
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Karen Fortier 28129 Florence Acres RdMonroe, WA 98272
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Steve Shapiro 2511 30th Ave SSeattle, WA 98144
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Dear Ms. Rachel Assink,Re: proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. I can’t say it any better than this from Washington Environmental Council, an environmental group I s...↓upport:Transportation is responsible for nearly half of Washington's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for the opportunity to comment.Sincerely, Sara Bhakti 521 7th AveKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Andrea Gruszecki 19705 Sunnyside Dr NShoreline, WA 98133
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, William Sneiderwine 14901 SE Sunpark DrVancouver, WA 98683
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Judy Ryan 602 Terry AveSeattle, WA 98104
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Andrea Speed 1618 154th St ETacoma, WA 98445
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Marilee Wood 126 Madrona DrFriday Harbor, WA 98250
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Barbara Brock 3302 Walnut CtCamano, WA 98282
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Barbara Scavezze 13268 NE 182nd StWoodinville, WA 98072
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. The Clean Fuels Program is a critical part of our statewi...↓de strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I ask you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Mitch Leffler 15210 NE 4th PlBellevue, WA 98007
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Brandie Deal 301 225th St SWBothell, WA 98021
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1. Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2. Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3. Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4. Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Virginia Davis 17721 NE 156th StWoodinville, WA 98072
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Tina Brown 5526 Sugarloaf StAnacortes, WA 98221
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Susan Vossler 12945 64th Ave NEKirkland, WA 98034
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Aaron Clark 4920 NE 65th StSeattle, WA 98115
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Kimberly Teraberry 532 18th Ave ESeattle, WA 98112
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Suzanne Nevins 123 Grand Fir StChimacum, WA 98325
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, JENNIFER VINING 5119 Palatine Ave NSeattle, WA 98103
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Steven Campana 4615 NE 25th CtVancouver, WA 98663
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Cheryl Biale 7711 Greenridge St SWOlympia, WA 98512
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Julia Kladnik 15 5th StTonasket, WA 98855
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, melodie martin 2339 11th Ave ESeattle, WA 98102
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Vanessa Jamison 7724 87th St NEMarysville, WA 98270
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, David morgan 10405 Titus RdLeavenworth, WA 98826
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Barbara we 3846F Deer Creek RdValley, WA 99181
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Charles Dreyfus 424 72nd Way NEOlympia, WA 98506
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, James Lanz 1713 SE Manor AveVancouver, WA 98683
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Jean Avery 13314 SE 19th StVancouver, WA 98683
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Julie Rodgers 8121 NE 141st StBothell, WA 98011
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Chad Evans 1928 SW Bay StPort Orchard, WA 98366
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Rebecca Frank 3065 Monterey DrMalaga, WA 98828
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Anna Inghram 4222 NE 74th StSeattle, WA 98115
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Katherine Nelson 9445 S 232nd StKent, WA 98031
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Mechelle Hannahs 10607 50th Ave ETacoma, WA 98446
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Dennis Ledden 183 Webb RdSequim, WA 98382
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Eric Holtz 716 2nd StKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Mark Canright 11589 Martin RdRockport, WA 98283
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Robert Bamford 2315 26th Ave ESeattle, WA 98112
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Dear Ms. Rachel Assink,These are my comments on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washington's greenhouse gas...↓ emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Randall Collins 530 4th Ave WSeattle, WA 98119
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Kathryn Lambros 8339 25th Ave NWSeattle, WA 98117
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, james hipp 609 Rosette CtBellingham, WA 98226
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Chris Nolasco 3119 151st St SWLynnwood, WA 98087
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Cheryl Speer 410 SW Park StCamas, WA 98607
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, jane frazer 201 E 63rd StTacoma, WA 98404
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Florie Rothenberg 3125 SW Raymond StSeattle, WA 98126
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Virgene Link-New 2004 10th StAnacortes, WA 98221
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Stephanie Trasoff 2447 Crestline StFerndale, WA 98248
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Lori Erbs 5310 Marda LnAcme, WA 98220
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Dear Ms. Rachel Assink,As an environmentally motivated voter who is deeply concerned about the role of dirty fossil fuels in the increasing climate crisis, I thank you for the opportunity to comment on the proposed rule language for the Clean Fuels P...↓rogram, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washington's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help our transition to a cleaner, more just transportation system. To achieve this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Linda Carroll 215 W Waverly PlSpokane, WA 99205
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, John S 10726 Stone Ave NSeattle, WA 98133
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Dianna MacLeod 3513 Wildes RdClinton, WA 98236
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Jim Roberts 629 Kirkland WayKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Arthur Ungar 612 W 36th StVancouver, WA 98660
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. A Clean Fuels Program must prioritize the reduction of environmental health disparities, uphold requirements for Tribal consultation, be guided by the best available science, and be publicly transparent and accountable.To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Deborah Bancroft 665 Burnt Ridge RdOnalaska, WA 98570
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Carole H 4807 Willamette StPort Townsend, WA 98368
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Marilee Henry 14042 97th Ave NEKirkland, WA 98034
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Nancy Quackenbush 56 Grove StEastsound, WA 98245
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Janice Wilfing 1515 W 6th StPort Angeles, WA 98363
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Linda Ellsworth 61 Rosehip RdEastsound, WA 98245
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Derek Benedict 709 212th Pl SWLynnwood, WA 98036
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Jean Pauley 414 Malden Ave ESeattle, WA 98112
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Steve Uyenishi 7301 40th Ave NESeattle, WA 98115
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Joyce Grajczyk 12026 SE 216th StKent, WA 98031
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Tina Bartlett 617 Oppelt RdChehalis, WA 98532
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Barbara DuBois 5020 N 18th StTacoma, WA 98406
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Peggy Butler 7710 Brown Rd SWOlympia, WA 98512
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Linda Erickson 222 NW 196th PlShoreline, WA 98177
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Nancy Peacock 2504 NE 117th StSeattle, WA 98125
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Tanara Saarinen 4418 Rosedale St NWGig Harbor, WA 98335
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Peter Mastenbroek 12323 NE 97th StKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Bob Schuessler 4249 S Kenny StSeattle, WA 98118
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Bourtai Hargrove 9822 Dempsey Ln SWOlympia, WA 98512
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Elizabeth Johnson 90 SW Russell AveStevenson, WA 98648
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Betty Barats 1710 Donovan AveBellingham, WA 98225
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Sophia Keller 851 SW 127th StSeattle, WA 98146
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Dagmar Fabian 1480 Birchwood Ave Apt 101Bellingham, WA 98225
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Alison Quinn 901 N 71st StSeattle, WA 98103
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Ben Moore 4823 243rd St SWMountlake Terrace, WA 98043
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Geno Lazerwitz 6126 12th Ave NESeattle, WA 98115
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Diane Sullivan 1231 SW Kalama LoopOak Harbor, WA 98277
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Nancy McMahon 3123 Scotch Meadows Ct SEOlympia, WA 98501
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Randal Ternes 2125 4th Ave WSeattle, WA 98119
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