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, 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,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, 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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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 Rader 120 S 295th PlFederal Way, WA 98003
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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 Risser 1822 Wold RdFriday Harbor, WA 98250
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, 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.Thank you for your consideration.Sincerely, LuAnne Swainson 2601 N Barker RdSpokane Valley, WA 99027
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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, Danielle Rowland 1654 153rd Ave SEBellevue, WA 98007
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Sally Neary 22608 115th Pl SEKent, WA 98031
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Tina Matzke 26285 238th Ln SEMaple Valley, WA 98038
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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, Patrick McKee 9233 SE 59th StMercer 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, Angela Dickens 18501 NE 59th CtRedmond, 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, Kristin Blalack 1018 Central St 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, Amanda Dickinson 1322 S 18th AveYakima, WA 98902
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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, Alana Khayat 4108 46th 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, Jared Howe 4107 Martin Luther King Jr Way SSeattle, WA 98108
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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, Pawiter Parhar 22626 NE Inglewood Hill RdSammamish, WA 98074
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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, Nadine Wallace 2709 N Cedar 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, Debbi Pratt 3535 27th Pl WSeattle, WA 98199
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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 Risser 1822 Wold RdFriday Harbor, WA 98250
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Cynthia Lachance 11002 SE Petrovitsky RdRenton, WA 98055
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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, Celia Cruz 8912 SE Hillcrest DrVancouver, 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, Elizabeth Call 102 Otis StWalla Walla, WA 99362
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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, Melissa Miner 2526 Elizabeth StBellingham, WA 98225
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Mary Keeler 1102 NW 83rd StSeattle, WA 98117
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, 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, Stan Parker 2520 Jefferson StBellingham, WA 98225
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Diane Sullivan 1231 SW Kalama LoopOak Harbor, WA 98277
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Randal Ternes 2125 4th Ave WSeattle, WA 98119
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, 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, Jennifer England 4730 Lost Creek LnBellingham, 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, MaryJo Wilkins 315 W 50th AveKennewick, WA 99337
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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, Jeanie Bein 4911 Coronado LnBellingham, 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, Gary Brill 13000 Linden 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, Sarah BAUMAN 695 Chuckanut Dr NBellingham, 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, Brandie Deal 301 225th St SWBothell, WA 98021
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Amy Heyneman 10579 NE Manor LnBainbridge 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, Dianna MacLeod 3513 Wildes RdClinton, WA 98236
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways, and to do it IMMEDIATELY!: 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, Patrick Conn 22018 126th Ct SEKent, WA 98031
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Karen Fortier 28129 Florence Acres RdMonroe, WA 98272
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Dear Ms. Rachel Assink,Time to take care of our life supporting planet before it isn't life supporting any more. 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 Washington's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Mary Lynn 3705 N Gove 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, Michelle Pavcovich 11351 20th Ave 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, J. Alexander 22910 90th Ave WEdmonds, WA 98026
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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, Margie Heller 731 S Garfield StSpokane, WA 99202
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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. 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, Thom Lufkin 212 21st Ave SEOlympia, WA 98501
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Deborah Kaye 6915 Holeman AveBlaine, WA 98230
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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, Emily Van Alyne 6749 Whitestone StWest Richland, WA 99353
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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, Brenda Michaels 1240 W Sims WayPort 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, J K 15120 Starr Rd SEOlalla, WA 98359
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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 Shirlock 1409 Rainbow LnCamano, WA 98282
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, 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, jane frazer 201 E 63rd StTacoma, WA 98404
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, 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, James Williams 9614 50th Pl WMukilteo, WA 98275
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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, Susanna Smith 2702 E Denny WaySeattle, 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, Diane McCutcheon 3130 NE 117th StSeattle, WA 98125
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Rebecca Glass 18003 Stone Ave NShoreline, WA 98133
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Judy Palmer 361 Rehmke RdTonasket, WA 98855
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Carlo Voli 9605 239th St SWEdmonds, WA 98020
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Michael Shurgot 6536 31st 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, Bob Schuessler 4249 S Kenny StSeattle, WA 98118
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Eric Holtz 716 2nd StKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Phil Ritter 1737 211th Pl NESammamish, WA 98074
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Barbara Blackwood 11916 E 25th AveSpokane Valley, WA 99206
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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 Snyder 5904 53rd St Ct WUniversity Place, WA 98467
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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, Brad Hanson 14508 Edgewater Ln NELake 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, Daniel Henling 1412 NW 61st StSeattle, WA 98107
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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, Jim Roberts 629 Kirkland WayKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 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 Habib 555 5th Ave WKirkland, WA 98033
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Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Ann Smith 7912 Woods Estate Ln NEOlympia, WA 98506
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