Rulemaking - Clean Fuels Program Rule and Air Quality Fee Rule

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Comment From: Erik Thomas

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly 50% of Washington's ...↓greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this source. We have the potential to help transition to a cleaner, more just transportation system. To do this, I urge the state to strengthen the rule in the following ways: 1) Tribal consultation: Uphold existing requirements! All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must -explicitly- incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health & environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant UPWARD corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.I thank you for your consideration.Sincerely, Erik Thomas 509 Potter StBellingham, WA 98225

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Comment From: SHARON HEIM

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, SHARON HEIM 2460 NW Canal View WayPoulsbo, WA 98370

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Comment From: Heidi colkitt

8/30/22 @ 11:00 PM

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Comment From: Supportive Services

8/30/22 @ 11:00 PM

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Comment From: Lynn Stiglich

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.The state of Washington must lead by example. Time is running out. The climate is adversely affecting all of us. Please do everything you can to help the environment and all our citizens.Thank you for your consideration.Sincerely, Lynn Stiglich 4214 NE 136th CirVancouver, WA 98686

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Comment From: Marquam Krantz

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Marquam Krantz 5698 NE Wild Cherry LnBainbridge Island, WA 98110

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Comment From: Barbara Scavezze

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Barbara Scavezze 13268 NE 182nd StWoodinville, WA 98072

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Comment From: Derek Benedict

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule.Transportation is responsible for nearly half of Washingto...↓n's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system.To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Derek Benedict 709 212th Pl SWLynnwood, WA 98036

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Comment From: Dora Weyer

8/30/22 @ 11:00 PM

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Comment From: Joyce Grajczyk

8/30/22 @ 11:00 PM

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Comment From: Jack Laskowski

8/30/22 @ 11:00 PM

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Comment From: Katherine Nelson

8/30/22 @ 11:00 PM

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Comment From: Eric Zimdars

8/30/22 @ 11:00 PM

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Comment From: Laurie Dils

8/30/22 @ 11:00 PM

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Comment From: Adrianna Hulscher

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision of these tracking systems to ensure their sufficiency and their alignment with other regulatory requirements across state agencies.Thank you for your consideration.Sincerely, Adrianna Hulscher 8726 17th Ave NWSeattle, WA 98117

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Comment From: Nancy Jacobs

8/30/22 @ 11:00 PM

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Comment From: james hipp

8/30/22 @ 11:00 PM

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Comment From: Valerie Rose

8/30/22 @ 11:00 PM

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Comment From: Lori Erbs

8/30/22 @ 11:00 PM

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Comment From: Jennifer Horner

8/30/22 @ 11:00 PM

Dear Ms. Rachel Assink,Thank you for the opportunity to comment on the proposed rule language for the Clean Fuels Program, Chapter 173-424 WAC and all the work to date in developing this rule. Transportation is responsible for nearly half of Washingt...↓on's greenhouse gas emissions. The Clean Fuels Program is a critical part of our statewide strategy to reduce climate pollution from this sector and has the potential to help transition to a cleaner, more just transportation system. To do this, I urge you to strengthen the rule in the following ways: 1) Uphold existing requirements for tribal consultation: All processes in the rulemaking and all actions resulting from the Clean Fuels Program must respect tribal sovereignty and treaty rights. This rule must explicitly incorporate Ecology’s existing obligation to proactively and meaningfully consult with federally recognized tribes, with sufficient time and information made available for this purpose.2) Ensure alignment with HEAL Act requirements and evaluate and track reduction of environmental health disparities: The Clean Fuels Program has the potential to deliver air quality improvements, especially to people living near and along roadways and transportation hubs. At the same time, there are unique air quality impacts and risks associated with different fuel types that require more thorough analysis and evaluation. It is critical that the program does not inadvertently incentivize increased emissions of pollutants harmful to human health and environment. This rule must include requirements for Ecology to track and remedy air pollution impacts, including through compliance with the HEAL Act's Environmental Justice Assessment requirements detailed in RCW 70A.02.060 and the collection of sufficient information to satisfy the requirements of RCW 70A.535.140. Ecology should require adequate information and build in an explicit process to review the air quality impacts of the program. 3) Update iLUC values to reflect best available science: The draft rule proposes to use California's protocol to calculate the indirect land use change (iLUC) values for crop-based biofuels made from sugarcane, corn, sorghum, soybean, canola, and palm feedstocks. While this is a step in the right direction and an improvement from earlier drafts of the rule, these values likely need significant upward corrections in light of emerging science, and Ecology should adjust the rule to reflect a more rigorous and accurate accounting of iLUC values for crop-based biofuels at the outset of the program. Ecology should then use the process proposed by WAC 173-424-600(2) to conduct an ongoing review of iLUC impacts with feedback from stakeholders, experts, and regulators in order to continue to correct the values as the science advances. 4) Ensure strong and transparent accounting of environmental attributes: Tracking the environmental attributes of biomethane and hydrogen is an area of emerging importance across multiple clean energy policies in Washington. The tracking systems established under the Clean Fuel Standard should be coordinated and consistent with other state policies governing how environmental attributes for these fuels are calculated and verified. This includes retaining the proposed rule's requirements for the use of independent tracking systems for hydrogen and pipeline-delivered biomethane and adding requirements for continued review and revision 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 Horner 19601 NE 165th StWoodinville, WA 98077

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Comment From: Steven Woolpert

8/30/22 @ 11:00 PM

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Comment From: Kate O'Malley

8/30/22 @ 8:48 PM

Dear WA Department of Ecology,

Thank you for the opportunity to comment on Washington's Clean Fuel Standard. I am very supportive of the draft Clean Fuel Standard and applaud the Department of Ecology for setting our/clean fuels trajectory to be the s...↓

At each weekly service, our community prays to be in right relationship with all of God's creation.� Reducing pollution from the transportation sector is an important part of our "right relationship" and stopping the harm we do daily to the environment.

Time is of the essence with our response to the climate crisis. Ambitious implementation of this law is critical for a just transition to clean energy that addresses our moral obligation to heal our climate and communities. Please ensure that the final rule maintains the strong carbon intensity standards of a 20% reduction by 2034.

In addition to the urgent need to reduce transportation pollution, I believe/how/we respond to the climate crisis is also a moral issue.� Please ensure the following points are reflected in the final rule:

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

I have faith that Washington can and will meet our greenhouse gas reduction goals through our gifts of innovation and dedication to stewardship. Thank you for putting us on that path and demonstrating our state's commitment to a clean energy future by implementing the strongest possible Clean Fuel Standard.

Sincerely,

Kate OMalley

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Comment From: Jennifer Hiebert

8/30/22 @ 8:46 PM

Dear WA Department of Ecology,

My faith calls me to live in such a way that all people, and indeed all the earth, suffer as little as possible. In a summer when the lower 48 states experienced not one, but four, 1,000-year flood events it should hardly be necessary to highlight the urgency of action to mitigate global warming--but please know that environmental destruction tops my list of concerns. I want to help as an individual, but we citizens need our governments to foster the structural changes that will address well-being and justice.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Jennifer Hiebert

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Comment From: Troy Faith Ward

8/30/22 @ 8:44 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Troy Faith Ward

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Comment From: Michael Siptroth

8/30/22 @ 8:42 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Michael Siptroth

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Comment From: Karen Bray

8/30/22 @ 8:41 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Karen Bray

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Comment From: Krista Mathistad

8/30/22 @ 8:38 PM

Dear WA Department of Ecology,

I am a person of faith - Lutheran specifically. The Bible tells us that we are stewards of God's creation, but we have been doing a very bad job of it recently. Climate change is an emergency issue, and folks who are from lower socio-economic backgrounds and historically marginalized groups are experiencing the devastating effects of it first. It is important that Washington's Clean Fuel Standard is implemented as soon as possible.

Not only is it critical that steps are quickly taken to reduce transportation pollution, but HOW those steps are taken and what is needed in addition to them is incredibly crucial. The following additional points need to be included in the final rule. Firstly, the initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances needs to be strengthened. Secondly, an environmental justice review in compliance with the HEAL Act (including requirements for Ecology to remedy and track air pollution impacts) should be required. Thirdly, utilities must be held accountable to justice-oriented, equitable reinvestments that significantly lower pollution in overburdened communities (required by law). Lastly, the Department of Ecology's existing obligation to meaningfully and proactively consult with Native Nations must be explicitly incorporated; expectations for sufficient time and information need to be included.

Thank you for giving this opportunity to comment on Washington's Clean Fuel Standard.

Sincerely,

Krista Mathistad, Director of Community Engagement at Bethel Lutheran Church in Shoreline

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Comment From: Pat Millen

8/30/22 @ 8:36 PM

Dear WA Department of Ecology,

As a person of faith, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington. We are witnessing environmental changes to our planet that harm Earth and the quality of life of her inhabitants. Warning signs are all around us. We must take a stand now to save our common home

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Sr. Pat Millen OSF

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Comment From: Annie Bailey

8/30/22 @ 8:34 PM

Dear WA Department of Ecology,

My faith inspires me to speak up on behalf of communities most affected by climate change. I believe it is our responsibility to care for creation and to be good stewards of the earth. We need to move toward cleaner fuels and invest in these so that do not rely on the oil industry and continue polluting the earth (and our own state) to the extent that we currently are. Addressing transportation in our state is an important step toward this goal.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mrs Annie Bailey

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Comment From: Brian Rulifson

8/30/22 @ 8:32 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Brian Rulifson

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Comment From: Tish Levee

8/30/22 @ 8:30 PM

Dear WA Department of Ecology,

As a Jew, I am called to tikkun olam, repairing the world, and to steward all of Creation. This Clean Fuel Standard will go a long way towards making it possible for us to mend the world that was given to us by the Creator.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Tish Levee

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Comment From: Margaret Botch

8/30/22 @ 8:28 PM

Dear WA Department of Ecology,

I also favor increasing electic cars.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Sr. Margaret Botch

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Comment From: Thuymai Fee

8/30/22 @ 8:26 PM

Dear WA Department of Ecology,

My values urge you to make this law as strong as possible, not just for me, but for future generations who inherit this planet.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Thuymai Fee

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Comment From: Carol Schneider

8/30/22 @ 8:24 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Carol Schneider

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Comment From: Catharine Cline

8/30/22 @ 8:22 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Rev. Catharine Cline

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Comment From: Fay Garrett

8/30/22 @ 8:20 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Fay Garrett

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Comment From: Broehe Karpenko

8/30/22 @ 8:17 PM

Dear WA Department of Ecology,

As a person of faith, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will be of benefit to the well being of the entire web of life, upon which we depend, and which we must steward and guard against harm, for our posterity and the generations to come.

Thank you very much for your service,

Broehe Karpenko

Ordained Minister

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Broehe Karpenko

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Comment From: George Burazer

8/30/22 @ 8:14 PM

Dear WA Department of Ecology,

Our actions should be positive, direct and responsible to the people of little means.� It is moral and ethical to have all share in

the nation's CLEAN AIR.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mr. George Burazer

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Comment From: Brel Froebe

8/30/22 @ 8:12 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Brel Froebe

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Comment From: Bernice Chouery

8/30/22 @ 8:10 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Bernice Chouery

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Comment From: PineSpire (Ryan Huggins)

8/30/22 @ 6:34 PM

PineSpire appreciates the opportunity to propose on the Draft Rule for the Clean Fuels Standard

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Comment From: Yale Carbon Containment Lab (Anastasia ORourke)

8/30/22 @ 1:33 PM

Attachments:

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Comment From: Shell - Hydrogen Mobility (Neil Bhagia)

8/30/22 @ 12:51 PM

Attachments:

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Comment From: Smart Charging Technologies (MAN ALTAHER)

8/30/22 @ 11:41 AM

Greetings,

Please find Smart Charging Technologies comments attached.

Best Regards,

Ma'n Altaher

Attachments:

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Comment From: The International Emissions Tr... (Joey Hoekstra)

8/30/22 @ 11:38 AM

Attachments:

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Comment From: Pacific Merchant Shipping Asso... (Thomas Jelenić)

8/30/22 @ 1:49 AM

Please find attached PMSA's comment letter.

Attachments:

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Comment From: Carbon Removal Companies (Annie Gilleo)

8/29/22 @ 12:23 PM

Please see attached for comments from members of the carbon removal industry.

Attachments:

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Comment From: ChargePoint (Evan Neyland)

8/29/22 @ 8:46 AM

Dear Ms. Assink,

ChargePoint appreciates the Department of Ecology's (the Department) work on developing a Clean Fuels Standard (CFS) rule in Washington on such an accelerated timeline and the opportunity to comment. ChargePoint is a strong advocate o...↓

Support for the carbon intensity (CI) reduction schedule.

ChargePoint supports the proposed CI reduction schedule, specifically to reach a 20% CI reduction target by the earliest allowable year (2034). Bringing forward the CI reductions will accelerate investment in clean fuels and infrastructure, and transportation decarbonization. While some stakeholders have expressed concern regarding the 2033 to 2034 incremental CI reduction, we believe this concern mischaracterizes the dynamics of the credit market. Obligated parties take a longer-term view than a single compliance year and will begin procuring towards the 2034 target starting in 2023. This will smooth credit supply/demand from 2023 through 2034 and mitigate volatility and stress on the bank. As BRG's own cost benefit analysis concluded in its assessment of the Accelerated Reduction scenario, setting a 20% CI target in 2034 is "achievable". Furthering the viability of a 20% 2034 target, BRG's analysis did not consider recent expansions in renewable diesel production capacity, which Bloomberg estimates has the potential to more than saturate US west coast diesel markets by 2025 . This will create significant credit supply in California, Oregon, and Washington CFS programs. Despite this, BRG still concluded a 20% 2034 target is achievable. We urge the Department to look to what has happened in California with the precipitous fall in credit prices over the past year due to increased supply and set commensurate CI targets to accommodate growing supply. The trajectory in the proposed rule better aligns with other west coast CFS programs as well and will result in more investment coming to Washington.

Non-residential EV charging crediting.

For non-residential EV charging crediting, including at multifamily housing sites, we reiterate that the Department should align with Oregon's program and enable the owner or network service provider to generate credits as the first fuel reporting entity. This will enable greater flexibility between owners and network service providers to allocate the credit to the entity in the core value chain best suited to utilize the value of the credit and report under the program. This will also minimize stranded credits and return more value to those making investments. It may be that the Department intended to write WAC 173-424-2020(3)(a) this way since (3)(b) states, "If the owner or service provider of the electric-charging equipment does not generate the credits...", in which case (3)(a) should be redrafted to read "The owner or service provider of the electric-charging equipment may generate credits from each piece of equipment.".

In addition, we caution against designating utilities as a non-residential backstop without stricter reinvestment requirements. WAC 173-424-420(7)(a) only requires utilities to report revenues from the sale of residential credits; it does not require the same level of scrutiny around utility reporting and reinvestment for non-residential credits. This risks the utilities potentially collecting non-residential credits and not reinvesting the credit value back into transportation electrification, which goes against the market-based principle of a CFS. Credits should first go to the entities investing in and maintaining the charging station and network; where this is not feasible due to administrative reasons (e.g., EV drivers and residential crediting), the entity designated to collect the credits must reinvest those proceeds back into transportation electrification. Otherwise, the market signal that the CFS is designed to send is lost.

Registration.

We recommend the Department amend WAC 173-424-300(b)(vii)(A) to read, "Unless described in WAC 173-424-2020(3)(a) as a first fuel reporting entity, provide ecology with a copy of a written contractual agreement demonstrating the registered entity acquired the designation of the first fuel reporting entity status;". This change will clarify that first fuel reporting entities do not need to provide the Department with contracts for stations where they are already the first fuel reporting entity. Without this clarification, the draft rule could be misconstrued to require amending thousands of EV charging contracts, which would be burdensome and costly.

Under WAC 173-424-300(b)(vii)(B), the draft rule requires registrants of non-residential charging stations to provide the number of chargers located in Washington as well as the estimated annual discharge of electricity per location, among other data points, upon registration. The number of charging stations and electricity discharge is constantly changing making these estimates difficult and subject to large errors. Moreover, no other clean fuels program requires this information upon registration. We recommend the Department drop this requirement from the registration requirements.

Electric utility reinvestment and reporting.

Because a large majority of EV charging happens at drivers' homes, a large majority of credits from on-road EV charging will be generated by utilities under the proposed rule. Therefore, it is critical that the rules developed around utility reinvestment and reporting are sound to ensure that this majority value makes its way back to the market and advances transportation electrification in Washington. Rebates for level 2 home chargers and installation have advanced electrification (and data collection on EV charging) in other programs, as have utility funding programs that cover line extensions and other front of meter costs that help enable transportation electrification. These types of programs aimed at EV drivers and public charging operators have the added benefit of returning value to the drivers whose investment in EVs was the original source of the credit revenue to begin with, which fosters a more equitable CFS.

Regarding the utility reinvestment requirements laid out in 70A.535.080(1)(a) vs (2)(a), (1)(a) offers more ambiguity for utilities due to less detail provided (as opposed to (2)(a) which points to a specific list of projects to be developed by the Department). We flag this so that the Department can embed sufficient structure and oversight in the rules around utility reinvestment reporting (WAC 173-424-420(7)) to ensure that this value � 50% of utility residential base credit proceeds � makes its way back to the market to advance electrification and benefits drivers, with a large share aimed at benefitting disproportionately impacted communities. Finally, utility programs funded through CFS credit proceeds should be competitive and open to market participation. These funds being administered by utilities stem from individual driver � not utility � investments thus should be open to competitive bidding. Competition for funding will lower costs and increase benefits to drivers, charging, and fleet operators, too.

Fast charging infrastructure (FCI) crediting.

ChargePoint supports the FCI pathway and applauds the Department for including it in the initial rule. The FCI pathway has been an overwhelming success of California's CFS and will be equally effective in Washington at accelerating transportation electrification. The one adjustment we recommend the Department make is to begin FCI crediting the first quarter the station is activated following application approval, instead of commencing crediting the quarter following application approval, as currently written. By starting crediting the quarter following application approval, regardless of activation status, projects that pre-applied but are not yet active get penalized by missing out on quarter(s) of credits. This is a relatively new lesson the market has learned from experience under California's FCI provision and ChargePoint as well as others are currently in discussion with CARB to implement this change under California's CFS as well.

Advance crediting.

Advance crediting under CFS is a creative and impactful way to accelerate electrification and decarbonization of transportation. The core concept is to fund projects that would not have happened otherwise, thus generating net new electrification. To this end, we recommend the Department loosen the eligibility requirements of advance crediting beyond just projects receiving funding through an omnibus transportation appropriations act to include all projects. The rationale is projects funded through an omnibus transportation appropriations act are already receiving funding thus may be less in need of financial assistance than other projects. To maximize the impact of the advance crediting provision, the Department should remove this requirement. Projects receiving funding through an omnibus transportation appropriations act will still be eligible.

Thank you for considering our comments. We look forward to continued participation in this rulemaking.

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Comment From: Matthew Riggen

8/28/22 @ 4:53 PM

Thank you for this opportunity to comment on the draft Clean Fuel Standard for Washington State. I am very supportive of the Department of Ecology's proposed rules and the reduction of carbon emissions of transportation fuels on the fastest timeline...↓

Sincerely, Matthew Riggen

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Comment From: Terri Lindeke

8/28/22 @ 2:52 PM

Our state has the most native tribes in the country. They have extensive land holdings throughout the state of Washington. You must include them in any discussions about the use of our lands in Washington State. This is their land.

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Comment From: Annie Phillips

8/27/22 @ 9:23 AM

Please strengthen our new Clean Fuel Standard by ensuring consultation with Native Nations, requiring environmental justice reviews, using best available science on biofuels lifecycle analysis, and ensuring equitable utility reinvestments in communit...↓

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Comment From: City of Everett, WA (Tony Cademarti)

8/26/22 @ 1:04 PM

173-424-530 says:

(3) Credit seller requirements. When parties wish to transfer

credits, the credit seller must initiate an online "credit transfer

form" provided in the WFRS and must include the following:

(a) The date on which the credit buyer and cred...↓

their agreement;

(b) The names and FEINs of the credit seller and credit buyer;

(c) The first and last names and contact information of the persons who performed the transaction on behalf of the credit seller and

credit buyer;

(d) The number of credits proposed to be transferred; and

(e) The price or equivalent value of the consideration (in U.S.

dollars) to be paid per credit proposed for transfer, excluding any

fees. If no clear dollar value can be easily arrived at for the transfer, a price of zero must be entered and a qualitative description of

the transaction's valuation must be entered in the seller's notes

field.

In section (e), specifically, it says: "The price or equivalent value of the consideration (in U.S.

dollars) to be paid per credit proposed for transfer"

How the price or equivalent value per credit is determined is not explained here. Recommend that there be more specific direction or a chart explaining how much each credit is, based on the public utility utilized, i.e. 1 kWH from Snohomish County PUD #1 = $"X" dollars for the month of "TBD". Otherwise, the cost-benefit analysis of installing "smart" vs "dumb" chargers and metered vs. non-metered chargers cannot be completed. A low-use charging station will generate less credits than one with more use, thus there is a break-even point for being willing to pay for different types of installations.

If the cost of a credit is going to follow a bid process or a "hand-shake agreement" between credit generators and deficit generators, then for municipal and county governments, there has to be a way to show the value per credit is "fair and reasonable". The bidding process has to be fair and open to all deficit generators, if that's what's being used, and properly documented (with copies given to the credit generator for their files). If it's a "hand-shake agreement", then that process won't be allowed per our local policies.

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Comment From: Gretchen Rehberg

8/26/22 @ 11:28 AM

Dear WA Department of Ecology,

As a follower of Jesus, it is of vital importance to me how we care for the earth and care for the most vulnerable among us. Transportation is our largest source of pollution in Washington. It is essential that we have a strong clean fuel standard that protects our home and allows all of us to flourish.

In addition to the urgent need to reduce transportation pollution, I believe/how/we respond to the climate crisis is also a moral issue. Please ensure the following points are reflected in the final rule:

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Rt. Rev. Gretchen Rehberg

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Comment From: Bob Carey

8/26/22 @ 10:53 AM

Dear WA Department of Ecology,

As an ethical person, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington - so that we can leave our children and grandchildren a healthy future. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mr. Bob Carey

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Comment From: Nancy Corr

8/26/22 @ 10:52 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. NANCY CORR

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Comment From: City of Everett, WA (Tony Cademarti)

8/26/22 @ 10:19 AM

173-424-300 (vii) (B) states:

For nonresidential EV charging for on-road application, must

provide the number of chargers located in Washington, their locations,

the estimated annual discharge of electricity per location, the owner

of the charging equipm...↓

charging equipment by the original equipment manufacturer (OEM) and

the name of the OEM. If there are multiple FSEs at the same location,

each unique piece of equipment must be registered separately;

How is an agency or organization supposed to estimate their annual electrical charging kWH information if they currently use "dumb" chargers without meters to charge their vehicles? Obviously, there will have to be metering added either physically (with a meter install) or via some other means moving forward. But for forecasting for 2023, the data is simply not there. Recommend removing this requirement from the rule, and make it only if it is possible (if you have a meter or some other way to gather the estimated electrical use information, that agency or organization must provide it).

Also, that same section requires registration of each electric vehicle charger. If multiple electric vehicle chargers are on one metered line with one meter, then that one meter should be allowed to track the electric charging information for all chargers on that one electrical line.

See recommended wording below:

"For nonresidential EV charging for on-road application, must

provide the number of chargers located in Washington, their locations,

the estimated annual discharge of electricity per location (if available,

if not available, explain), the owner

of the charging equipment, and the serial number assigned to the

charging equipment by the original equipment manufacturer (OEM) and

the name of the OEM. If there are multiple FSEs at the same location,

each unique piece of equipment must be registered separately (unless

metered on one electrical meter, then the meter will be registered

with a note stating what electric vehicle chargers by make, model,

and serial number, are serviced by that meter);"

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Comment From: Oolaa Kaplan

8/26/22 @ 10:14 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Oolaa kaplan

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Comment From: Gloria Thiele

8/26/22 @ 10:13 AM

Dear WA Department of Ecology,

Gloria Thiele

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Gloria Thiele

No attachments

Comment From: Veronica D'Orazio

8/26/22 @ 10:11 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Veronica D'Orazio

No attachments

Comment From: Paul Litwin

8/26/22 @ 10:10 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mr. Paul Litwin

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Comment From: Francie Rutherford

8/26/22 @ 10:08 AM

Dear WA Department of Ecology,

continue on this path.

Francie Rutherford

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Francie Rutherford

No attachments

Comment From: Kristin Barber

8/26/22 @ 10:07 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Kristin Barber

No attachments

Comment From: Jillian Froebe

8/26/22 @ 10:05 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Jillian Froebe

No attachments

Comment From: City of Everett, WA (Tony Cademarti)

8/26/22 @ 10:04 AM

173-424-300 (vii) (A) states:

Registered entities that are charging electric vehicles must:

Provide ecology with a copy of a written contractual agreement demonstrating the registered entity acquired the designation of the first fuel reporting entity s...↓

If an organization already owns the charging stations, why would this be required?

Recommend this wording be changed to "If the organization or agency owning electrical vehicle charging stations desires to have an third-party aggregator aggregate credits for reporting on their behalf, then the organization or agency shall provide ecology with a copy of a written contractual agreement demonstrating the registered entity acquired the designation of the first fuel reporting entity status.

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Comment From: Judy Ryan

8/26/22 @ 10:03 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Judy Ryan

No attachments

Comment From: Julie Kageler

8/26/22 @ 10:01 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Julie Kageler

No attachments

Comment From: Rich Voget

8/26/22 @ 10:00 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Rich Voget

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Comment From: Elaine Clark

8/26/22 @ 9:59 AM

Dear WA Department of Ecology,

Now is the time, we are the ones! It is important that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Elaine Clark

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Comment From: Faye Bartlett

8/26/22 @ 9:57 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mrs. Faye Bartlett

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Comment From: Pauline Druffel

8/26/22 @ 9:50 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. PAULINE DRUFFEL

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Comment From: Daniel McCloskey

8/26/22 @ 9:48 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Daniel McCloskey

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Comment From: City of Everett, WA (Tony Cademarti)

8/26/22 @ 9:47 AM

The application process, as currently listed in the proposed rule, to enter the program is archaic and vague. Recommend an online form be created that can be with blanks for required information that can be filled in electronically and e-signed by th...↓

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Comment From: Suzanne Duncan

8/26/22 @ 9:46 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Suzanne Duncan

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Comment From: Seth Goldstein

8/26/22 @ 9:44 AM

Dear WA Department of Ecology,

In the Jewish tradition, we see ourselves as partners with God in the ongoing work of Creation. As a person of faith, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Rabbi Seth Goldstein

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Comment From: Kathleen Forman

8/26/22 @ 9:43 AM

Dear WA Department of Ecology,

We must act as quickly as possible to radically decrease the carbon pollution our vehicles pump into the air. Our health and the well being of our planet and all forms of life depend on our taking responsible action NOW.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Kathleen Forman

No attachments

Comment From: Kelsey Herschberger

8/26/22 @ 9:41 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Kelsey Herschberger

No attachments

Comment From: Jim Young

8/26/22 @ 9:39 AM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Jim Young

Spokane WA

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Comment From: bp America Inc. (Mark Bunch)

8/26/22 @ 8:14 AM

Please find bp America rulemaking comments for WA CFP in the attached file.

Thank you

Attachments:

Download

Comment From: Veronica D'Orazio

8/26/22 @ 7:30 AM

I strongly support the Clean Fuels programs. Thank you for your initiative and response to community calls for climate change reform.

Thank you,

Veronica D'Orazio

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Comment From: Tamara Erickson

8/25/22 @ 3:47 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Tamara Erickson

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Comment From: John-Otto Liljenstolpe

8/25/22 @ 3:45 PM

Dear WA Department of Ecology,

As a person of faith, I urge you to suport the current legislative efforts to establish a "Clean Fuel Standard for our state. Much more needs to be done. But that at least would be a good beginning.

Pr. John-Otto Liljenstolpe

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

John-Otto Liljenstolpe

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Comment From: Joyce Ramee

8/25/22 @ 3:43 PM

Dear WA Department of Ecology,

As a person of faith, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive. Simply imagining that we can prevent people from driving and force them onto mass transit options isn't the means to this end. The infrastructure and routing of buses and light rail is skewed and does not allow for safe travel in economically challenged neighborhoods. Access to alternaitve non-fossil fuels is critical, and emission standards have to be strictly set and enforced. Please do what you can for thsi important issue.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Joyce Ramee

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Comment From: Lucinda and Donald Wingard

8/25/22 @ 3:37 PM

Clean Fuel Standards: We support the Department of Ecology for setting our clean fuels trajectory to be the strongest possible per the law. Please ensure that the final rule maintains the strong carbon intensity standards of a 20% reduction by 2034.

W...↓

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Comment From: Ron DiGiacomo

8/25/22 @ 3:35 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ron DiGiacomo

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Comment From: Mike Mallory

8/25/22 @ 2:55 PM

Dear WA Department of Ecology,

The world's economists agree that pricing carbon is one of the best ways to encourage the transition from fossil fuels to clean electric. This bill would establish a policy which would help Washington meet the goals of the United Nations, the Federal Government and the State of Washington related to the current Climate Crisis.

Thank you

Mike Mallory

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mr. Mike Mallory

No attachments

Comment From: Elizabeth Kerwin

8/25/22 @ 2:54 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. elizabeth kerwin

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Comment From: John Doherty

8/25/22 @ 2:51 PM

Dear WA Department of Ecology,

It is important to me that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive. Thank you for what you do and for helping to build a better future for the generations to come.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

JOHN DOHERTY

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Comment From: Eleana Pawl

8/25/22 @ 2:49 PM

Dear WA Department of Ecology,

As a responsible human being, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington.

A strong final Clean Fuel Standard will help all of us embody our obligation to live more lightly on Earth so that all may thrive.

--Eleana Pawl

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Eleana Pawl

No attachments

Comment From: Helen Sargeant

8/25/22 @ 2:47 PM

Dear WA Department of Ecology,

As a person of faith, it is so very important to me that that we move rapidly to address Washington' largest pollution source - transportation. Implementing a strong final clean fuel standard will help me to fulfill my value of living more lightly on the Earth, thus enabling all to thrive.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

HELEN M. SARGEANT

No attachments

Comment From: Mary Ellen Smith

8/25/22 @ 2:45 PM

Dear WA Department of Ecology,

As a person of faith, I believe that it is my moral and ethical responsibility to live in a manner that encourages me and others to live more lightly on this beautiful plant that we call home. I encourage you to take swift action to address transportation as our largest source of pollution in Washington.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

MS Mary Ellen SMith

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Comment From: Kathy Roberg

8/25/22 @ 2:43 PM

Dear WA Department of Ecology,

As a person of faith, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive. I believe that even the smallest approach or action we take on the Climate Situation today will help make a difference, therefore I fully support investing in alternative transportation, however there are many folks who will not be able to purchase electric or alternative means for transportation. We need to encourage them to do their part ( recycling, being conscious of Mother Earth) in whatever way they can take action. We are all members of this planet Mother Earth and need to join all effort and forces to heal her. Thank you

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Sr. Kathy Roberg

No attachments

Comment From: Lorraine Hartmann

8/25/22 @ 2:41 PM

we need to save our planet and push each other and all entities to do the best they can, hard though it may be. That will save our planet; nothing else will.

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Comment From: Linda Gaines

8/25/22 @ 2:41 PM

Dear WA Department of Ecology,

I have a 6 year old great-granddaughter and will soon have a great grandson. I want them to life in a world that hasn't the pollution that we have now.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mrs. Linda Gaines

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Comment From: Sharon Wilson

8/25/22 @ 2:40 PM

Dear WA Department of Ecology,

As a person of faith, it is important to me that we take swift action to address transportation as our largest source of carbon pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Ms. Sharon Wilson

No attachments

Comment From: Jeannine Lish

8/25/22 @ 2:38 PM

Dear WA Department of Ecology,

People on limited resources may not be able to afford the new vehicles that use electricity, but hopefully there will be some

incentives to have gas-powerelersd cars economically converted to non-polluting vehicles. There are people with these abilities

to do this type of conversion, & with enough across our country 'buying-in' on financially supporting these conversions, this could

help cut down on the current polluting exhausts,

With the number of older, 'junker' cars still on the road, incentives to help folks trade in these possibly unsafe, gas-guzzlers, would

be another way to begin to clean up.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Mrs. Jeannine Lish

No attachments

Comment From: Karen Dalenius

8/25/22 @ 2:35 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Karen Dalenius

No attachments

Comment From: Patrice Roberts

8/25/22 @ 2:31 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Patrice Roberts

No attachments

Comment From: Kristy Daniels

8/25/22 @ 2:26 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

Rev. Kristy Daniels

No attachments

Comment From: May Killorin

8/25/22 @ 2:23 PM

Dear WA Department of Ecology,

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

May Killorin

No attachments

Comment From: Paul Eldred

8/25/22 @ 2:13 PM

Dear WA Department of Ecology,

As a Lutheran pastor, it is important to me that we take swift action to address transportation as our largest source of pollution in Washington. A strong final Clean Fuel Standard will help me embody my call to live more lightly on Earth so that all may thrive.

- Explicitly incorporate Ecology's existing obligation to proactively and meaningfully consult with Native Nations, including expectations for sufficient time and information.

- Require an environmental justice review in compliance with the HEAL Act and include requirements for Ecology to track and remedy air pollution impacts.

- Hold utilities accountable to thoughtful and equitable reinvestments that further transportation electrification and reduce pollution in overburdened communities� as required by the law.

- Strengthen initial accounting of the impact of crop-based biofuels beyond California's baseline and plan for ongoing review as science advances.

Sincerely,

The Rev. Paul Eldred

No attachments

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