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, Erik LaRue 17598 Maiben RdBurlington, 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.Thank you for your consideration.Sincerely, Craig Swanson 16220 SE 28th PlBellevue, WA 98008
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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, Noah Ehler 32115 NE 110th CtCarnation, WA 98014
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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, Michael Hill 701 Mineral Hill RdMineral, WA 98355
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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, Gloria McClintock 1411 Northview CtMount Vernon, WA 98274
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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, Tim Rettmann 5406 NE 194th PlLake Forest Park, WA 98155
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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, Debbie Spear 20928 133rd St SEMonroe, 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, Thomas Cox 11682 Holmes Point Dr 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, Don Worley 1949 WA-25Kettle Falls, WA 99141
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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 Hand 7169 NE Hidden Cove RdBainbridge Island, WA 98110
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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 Arntson 1615 208th St SEBothell, WA 98012
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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 Schwinberg 6341 5th 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, Peter Reagel 15719 4th Ave SBurien, WA 98148
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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, Maxwell Hanson 218 W Crockett StSeattle, 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, Larry Leveen 243 S 55th StTacoma, WA 98408
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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, Lizzy Combs 2923 S MeridianPuyallup, WA 98373
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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, Jody Caicco 23402 NE 108th StVancouver, WA 98682
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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 Baine 32116 42nd Pl SWFederal Way, WA 98023
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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, Becky Anderson 2043 Ponderosa CtBellingham, WA 98229
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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, Grace Padelford 11807 100th 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, Lori Stefano 22440 Vale Ct SEYelm, WA 98597
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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, Felicity Devlin 2417 N Washington 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, Jane Barron 1202 S 3rd StDayton, WA 99328
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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 inadvertentlyt 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, Paul Elder 5020 117th Ave SEBellevue, WA 98006
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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, Candice Cassato 6417 54th Ave NWOlympia, WA 98502
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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 Burger 21428 86th Ave SWVashon, WA 98070
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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, kat thomas 1007 E Alder StSeattle, 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, Susan Shouse 2919 Leonard DrEverett, WA 98201
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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, Lindell Haggin 15418 N Little Spokane DrSpokane, WA 99208
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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, Dan Rogers 3331 H StWashougal, WA 98671
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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, Norman Baker 3789 Lost Mountain 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, Rebecca Durr 2703 Riverview DrAberdeen, WA 98520
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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. Clean Fuels Program must prioritize the reduction of envi...↓ronmental 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, Tina Brakefield 7327 NE 13th Ave Apt F15Vancouver, WA 98665
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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 time and your consideration of these comments.Sincerely, Dorothy Jordan 1407 Abbot RdLynden, WA 98264
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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, r wood 4326 University Way NESeattle, WA 98105
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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, Phyllis Hatfield 2239 Fairview 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, Rita Hogan 4437 31st Ave SELacey, WA 98503
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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, Jeffrey Kaufman 26110 NE 209th StBattle Ground, WA 98604
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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, Patti Brent 13717 NW 2nd AveVancouver, WA 98685
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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, Heather Murawski 17929 W Spring Lake Dr SERenton, WA 98058
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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 Jacobs 117 Eldorado PlChelan, WA 98816
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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, Joseph Lopez 1411 N Clogston WaySeattle, 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, Gail Atkins 6299 Wilson Creek RdRaymond, WA 98577
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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. We are facing climate catastrophe with profound ill effec...↓ts throughout our planet, all thanks to our addiction to fossil fuels. 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. There is no time to lose.Sincerely, E. O'Halloran 16916 N Dartford DrSpokane, WA 99208
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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, Alfred Ferraris 1340 Corona 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, Lori Benton 13210 SE 7th 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, Jim Byrne 28501 NW 7th AveRidgefield, WA 98642
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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, Marianne Eddington 20520 NE 221st CirBattle Ground, WA 98604
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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, MLou Christ Dayton 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, JENI Woock 3412 Lewis StGig 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, Gena DiLabio 3124 Dakota DrMount Vernon, WA 98274
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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, Judith Schwab 9142 N Mercer WayMercer Island, WA 98040
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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, Tim Emineth 5585 E Evergreen BlvdVancouver, WA 98661
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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.Additionally, consider incentives for providing electric plug-in stations/outlets at businesses and corporations. For example, we have a Honda Clarity Plug-in car. My husband resides in an apartment on the second floor at Patriots Landing senior living in DuPont. For several months, he has requested a way to connect our car to an electric outlet to charge the battery. Nothing has happened. Senior living residences are run by big corporations. What an opportunity to include them in embracing the use of electric vehicles for a large segment of the American population. Thank you for your consideration.Sincerely, S. Jacky 2411 Lexington StSteilacoom, WA 98388
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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, Tom Craighead 28203 137th Ave SWVashon, WA 98070
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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, Teresa Allen 2323 St Clair StBellingham, WA 98229
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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, Holly Graham 5900 Brenner Rd NWOlympia, WA 98502
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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, Lorraine Johnson 13716 Lake City Way NESeattle, 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, Jennifer Valentine 313 1st Ave NSeattle, WA 98109
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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, Michelle Pappas 3617 E Euclid AveSpokane, WA 99217
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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 Burrows 424 S Chestnut StSpokane, WA 99201
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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, Dianne Hurst 4753 Orcas St NELacey, WA 98516
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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, Sandra Aseltine 2790 Tracyton Beach Rd NWBremerton, WA 98310
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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, Louis Richard 688 Tiffany Meadows Dr NEBainbridge Island, WA 98110
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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, Sally Hurst 3303 Cascadia Ave SSeattle, WA 98144
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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.It is critically important that we get the details right. Time to effectively mitigate the damage of climate change is running out. Thank you for your consideration.Sincerely, Lynn Lichtenberg 501 Colby AveEverett, WA 98201
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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, Elena Rumiantseva 3807 West Lake Sammamish Pkwy 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, Joanne Watchie 2440 Alki Ave SWSeattle, WA 98116
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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, Paul McMurray 16521 SE Auburn-Black Diamond RdAuburn, WA 98092
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Dear Ms. Rachel Assink,This letter is in support of your work on a strict, enforceable Clean Fuel Standard for the state of Washington. I know what it is like to creep along I-5 at 5 miles an hour after work trying to get home from Portland, Oregon t...↓o Vancouver, Washington. Engines idle and idle and idle – cars, trucks, pickups, freighters, motorbikes. The car windows close. The air conditioners or heaters go on. The outer air intake is shut off. And we wait -- the air smelling fumey. And when it’s dank and foggy, like it so often is in Portland, we know the air is heavy with much more than rain. Even if the I-5 bridge between Washington and Oregon is replaced, and includes, light-rail, though the commute should be easier, cars will not instantly go away. And all the people living in the small homes lining the freeway? They must be keeping their windows shut tight too. We know the cancer rates and asthma rates, not to say the incidence of recurrent and debilitating headaches are high there, and the outdoor living that we prize in the suburbs is outright dangerous. I hope you will stay firm in setting the significant reduction of emission standards you are considering, both in their extent and in the sooner rather than later timeline. At last we seem to have in this state the political will to do this. Thank you for your resolve and for all of your work.Sincerely, Mary Siciliano 1505 NW 62nd StVancouver, WA 98663
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Dear Ms. Rachel Assink,The clock on acting to curtail climate change began ticking the moment we could track the impact of greenhouse gases on the atmosphere. Scientists began sounding the alarm 150 years ago. Then academia presented the emerging fac...↓ts to students like me, who first became aware of the dangers in the early 1970s. Fossil fuel and other businesses acted to protect their short-term interests with advertising and lobbying efforts. This influenced many voters to dismiss or ignore the greatest challenge of our lifetimes. Recently, Mother Nature has grabbed the pulpit and is showing the catastrophic impact of a fossil fuel economy through megafires, 1000 year droughts, unbearable heat waves, superstorms and other catastrophes that will only increase. For businesses, the financial impact is inescapable and there are new opportunities through the adoption of EVs, hybrid vehicles, sustainable power generation and other technologies, and renewed government incentives like the Clean Fuels Program. Please lead us in the necessary transition to sustainable energy by making the new rules as effective as you can. This starts with reducing transportation emissions that cause almost half the impact. I ask you to be bold. When the rules take effect, public opinion will be catching up with you. They will be increasingly won over as their health, safety and their businesses and farms are threatened. Indigenous people modeled a sustainable vision. They are important allies to include in your considerations as are the minority communities that live near emissions sources, and the vulnerable elders and children who are most affected by exposure to fossil fuel emissions.Sincerely, Gary Seeman 24009 NE 26th AveRidgefield, WA 98642
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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 Wesley 4446 Eden Valley RdPort 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, Arnold Strang 23607 46th Pl WMountlake 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, Alex Fay 1819 23rd Ave Apt E220Seattle, 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, Eric Zimdars 14902 12th Dr SEMill Creek, WA 98012
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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, Shary B 1950 Alaskan WaySeattle, WA 98101
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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, Matt Lennon 409 Ruby StEllensburg, WA 98926
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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, Nicholas Jurus 9412 SW Gorsuch RdVashon, WA 98070
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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, Kathy Dawson 5806 Greenwood 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, Laurie Dils 1107 Olympia Ave 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, Amy McKay 1818 Main StLynden, WA 98264
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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, Aminah Lamb-McMurray 14610 Cedar Grove Rd SEIssaquah, WA 98027
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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, Adina Parsley 20420 Marine DrStanwood, WA 98292
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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, Anita Penuelas 7315 56th 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, Desiree Nagyfy 1120 E Westmoreland RdDeer Park, WA 99006
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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, Derya Ruggles 4121 E 16th StVancouver, WA 98661
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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. I fully support these actions.Sincerely, Evelyn Bittner 10710 Whitman 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, Faye Bartlett 3382 Southbend PlBellingham, 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, Sarah Campbell 4120 50th Ave NESeattle, WA 98105
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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, Eileen Thompson 221 A 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, Sally Clark 5309 N 43rd StTacoma, WA 98407
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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, Kate Lunceford 1527 232nd Pl 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, Judith Beaver 500 W Hendrickson 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, Hannah Liu 3008 NE 141st StVancouver, WA 98686
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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, Caroline Bowdish 1531 N 16th AvePasco, WA 99301
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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, Tika Bordelon 1400 Hubbell PlSeattle, WA 98101
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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 Saul 10102 NE 10th StVancouver, WA 98664
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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, Kindy Kemp 565 Blue Sky DrPort 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, Sean O'Dell 14011 143rd Ave SERenton, WA 98059
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