Chapter 173-446 WAC: Cap-and-Invest US Forest Offsets Protocol Informal Comment Period #1

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Comment From: CarbonPlan (Grayson Badgley)

8/18/25 @ 11:55 PM

Please find CarbonPlan's comments for the Cap-and-Invest US Forest Offsets Protocol Informal Comment Period #1 attached.

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Comment From: Chao Wu

8/18/25 @ 9:30 PM

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Comment From: Steve Hinton

8/18/25 @ 8:26 PM

I am attaching our comments on behalf of the Tulalip Tribes.

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Comment From: Makah Tribe (Timothy Greene Sr.)

8/18/25 @ 6:46 PM

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Comment From: Washington Conservation Action (Katie Fields)

8/18/25 @ 6:33 PM

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Comment From: Washington Department of Fish ... (Harriet Morgan)

8/18/25 @ 5:21 PM

The Washington Department of Fish and Wildlife appreciates the Department of Ecology's leadership in developing a rigorous forest carbon offset protocol as part of the state's cap-and-invest program. The program reflects important improvements over e...↓

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Comment From: Washington Forest Protection A... (Olivia Jacobs)

8/18/25 @ 5:11 PM

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Comment From: New Forests (Justin Meier)

8/18/25 @ 4:11 PM

Department of Ecology

State of Washington

300 Desmond Drive SE

Lacy, WA 98503 USA

18 August 2025

Re: Chapter 173-446 WAC Cap-and-Invest Offsets, US Forest Protocol Draft Rule Language

Dear Department of Ecology Forest Offset P...↓

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Comment From: Hampton Lumber (Heath Curtiss)

8/18/25 @ 4:00 PM

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Comment From: Institute for Policy Integrity... (Erin Shortell)

8/18/25 @ 3:54 PM

Please see the attached comments of the Institute for Policy Integrity at NYU School of Law.

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Comment From: National Indian Carbon Coaliti... (Bryan Van Stippen)

8/18/25 @ 3:40 PM

The National Indian Carbon Coalition (NICC) appreciates the opportunity to provide feedback on the proposed revisions to the Washington Cap-and-Invest Program's U.S. Forestry Protocol. NICC is a tribal-led program formed by the Indian Land Tenure Fou...↓ndation and the Intertribal Agriculture Council that supports Tribal Nations in evaluating and developing high-integrity carbon projects. Over the past several years, we have partnered with multiple Washington-based Tribal Nations to assess participation in Improved Forest Management (IFM) offset projects under the Climate Commitment Act's Tribal Carbon Offset Assistance Program grants. To date, only one Tribe has listed an IFM project; the remaining Tribal Nations are still weighing the current program rules, the management adjustments necessary for compliance, and the financial incentives associated with participation.

Introducing protocol changes at this juncture would require Tribal governments to restart fiscal analyses, operational planning, and internal approvals, creating additional burdens for staff and leadership. As proposed, the revisions would raise development and compliance costs, reduce financial predictability, and materially complicate participation. In practical terms, they would alter the underlying value proposition for Tribes and substantially decrease the likelihood that many will be able to move forward in the Cap-and-Invest market.

NICC urges a path that preserves momentum while strengthening program integrity: (1) grandfather projects already initiated under the existing protocol; (2) provide a clear, multi-year transition period with definitive guidance so Tribes do not have to re-tool midstream; (3) engage in government-to-government consultation to co-develop any substantive changes, including consideration of a Tribal-specific compliance track that reflects Indigenous stewardship practices and tenure realities; and (4) offer targeted technical assistance and funding to cover the re-evaluation costs created by any revisions. These steps would maintain rule stability, enable Tribal participation at scale, and advance the CCA's climate and equity objectives.

NICC stands ready to share data, project timelines, and case examples from our work with Tribal partners and to collaborate on a durable framework that both protects environmental integrity and is workable for Tribal governments. Thank you for your consideration.

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Comment From: Greenline Climate (Tim Kramer)

8/18/25 @ 3:37 PM

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Comment From: Clean Air Task Force (Zoe Jee)

8/18/25 @ 2:27 PM

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Comment From: Libby Blanchard

8/18/25 @ 2:10 PM

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Comment From: William Anderegg

8/18/25 @ 11:49 AM

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Comment From: Port Blakely (Gareth Waugh)

8/18/25 @ 9:40 AM

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Comment From: Anew Climate (Josh Strauss)

8/18/25 @ 9:38 AM

Thank you for the opportunity to provide comment. Please see uploaded file.

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Comment From: Edward Mann

8/17/25 @ 8:46 AM

please see attached document.

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Comment From: University of California, Berk... (Barbara Haya)

8/15/25 @ 9:21 PM

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Comment From: Green Diamond Resource Company (Jason Callahan)

8/15/25 @ 11:24 AM

Please see attached memo.

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Comment From: Sam Mundel

8/07/25 @ 4:25 AM

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Comment From: Green Diamond (Shana Leshko)

7/30/25 @ 2:38 PM

Two clarifications:

1. 3.6.2.2 - Could Ecology please clarify the types of areas that count as harvest retention areas to meet Basal Area retention requirements for even aged management? E.g. are riparian zones counted toward the harvest retention ...↓

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Comment From: Rick Schmeling

7/28/25 @ 2:24 PM

As a small private forest landowner, I do not think your proposed changes go far enough away from the copied California rules to make a viable offset protocol in Washington state. My two small tree farms contain 80-90% healthy Douglas Fir trees, but...↓

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