Rulemaking - Clean Fuel Standard

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Comment From: Joint Utilities (Seattle City ...

8/01/25 @ 11:59 PM
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Comment From: CleanFuture, Inc. (John Thornton)

8/01/25 @ 11:53 PM
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Comment From: Donna Albert

8/01/25 @ 11:45 PM
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Comment From: ACT Commodities (Elise Miller)

8/01/25 @ 9:59 PM
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Comment From: American Biogas Council (Jonathan Harding)

8/01/25 @ 9:12 PM
Please see attached file for comments.
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Comment From: DVO, Inc. (Doug VanOrnum)

8/01/25 @ 8:36 PM
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Comment From: Farm Power Northwest LLC (Kevin Maas)

8/01/25 @ 7:16 PM
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Comment From: Douglas County PUD (Shiloh Burgess)

8/01/25 @ 4:56 PM
Please see Douglas PUD's comments via the attached file. Thank you.
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Comment From: Energy Vision (Matthew Tomich)

8/01/25 @ 4:49 PM
See comments attached. Thank you for your time and consideration.
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Comment From: Washington Conservation Action (Caitlin Krenn)

8/01/25 @ 4:41 PM
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Comment From: Bonneville Environmental Found...

8/01/25 @ 4:36 PM
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Comment From: Washington Green Hydrogen Alli... (Michael Lord)

8/01/25 @ 4:06 PM
Please see attached file.
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Comment From: Washington State Dairy Federat...

8/01/25 @ 4:02 PM
Please See attached comments
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Comment From: Washington State Department of... (Nina Gibson)

8/01/25 @ 3:23 PM
Please find our comments (attached) to the proposed rule as part of the CR-102 process labeled August 1, 2025, along with comments sent in December 2024 as part of the pre-rulemaking process. Thank you!
Attachments:
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Comment From: Zeem Solutions (Margaret Boelter)

8/01/25 @ 3:09 PM
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Comment From: Newtrient LLC (Mark Stoermann)

8/01/25 @ 3:01 PM
Newtrient, representing a coalition of leading U.S. dairy cooperatives and organizations committed to reducing the environmental impact of dairy production, appreciates the opportunity to provide comments on the proposed amendments to the Climate Pol...↓
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Comment From: Avista Corporation, Cascade Na... (Scott Novak)

8/01/25 @ 3:00 PM
Attached please find the joint comments of Avista Corporation, Cascade Natural Gas Corporation, Puget Sound Energy, Inc., and NW Natural regarding Washington's Clean Fuels program proposed rulemaking.
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Comment From: Maas Energy Works (Dallas Spiecker)

8/01/25 @ 2:51 PM
Re: Maas Energy Works Comments on Washington Clean Fuels Program – Draft Rule (Chapter 173-424 WAC)
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Comment From: Renewable Hydrogen Alliance (R... (Rebecca Smith)

8/01/25 @ 2:25 PM
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Comment From: Maple Grove Dairy, LLC (BRIAN BOSMA)

8/01/25 @ 2:20 PM
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Comment From: Hydrogen Fuel Cell Partnership (David Park)

8/01/25 @ 2:03 PM
Please see the letter and accompanying California Hydrogen Mobility Vision and Roadmap from the Hydrogen Fuel Cell Partnership as feedback to the Clean Fuel Standard Rulemaking.
Attachments:
Download
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Comment From: Jason Sheehan

8/01/25 @ 1:36 PM
Resubmitting as PDF
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Comment From: RPMG Inc. (Jesse Nowicki)

8/01/25 @ 1:14 PM
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Comment From: Jason Sheehan

8/01/25 @ 1:09 PM
Please see attached Word document
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Comment From: Air Products (Miles Heller)

8/01/25 @ 1:07 PM
Please find our comments on this rulemaking attached
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Comment From: Valerie King

8/01/25 @ 12:56 PM
Stop taking away incentives for farmers to invest in environmental improvements. Your rules discourage greenhouse gas reductions and renewable energy projects on dairies. Cows have been around for CENTURIES providing for civilization. Quit punishing ...↓
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Comment From: King County (Marissa Aho)

8/01/25 @ 12:39 PM
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Comment From: The Coalition for Renewable Na... (Sam Wade)

8/01/25 @ 12:37 PM
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Comment From: Amp Americas (Cassandra Farrant)

8/01/25 @ 11:57 AM
Amp Americas appreciates the opportunity to submit comments in response to the rulemaking for the Clean Fuel Standard. Please see our comments.
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Comment From: Clean Energy (Ryan Kenny)

8/01/25 @ 11:55 AM
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Comment From: Food & Water Watch (Tyler Lobdell)

8/01/25 @ 11:12 AM
Please see attached document.
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Comment From: Earthjustice (Sara Gersen)

8/01/25 @ 11:09 AM
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Comment From: Neste (Oscar Garcia)

8/01/25 @ 10:53 AM
Neste is pleased to submit the attached comments. Thank you
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Comment From: Kentucky Soybean Association (Becky Kinder)

8/01/25 @ 10:22 AM
See Attached.
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Comment From: Pacific Merchant Shipping Asso...

8/01/25 @ 10:16 AM
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Comment From: The Transport Project (Sherrie Merrow)

8/01/25 @ 10:00 AM
Please see attached letter from The Transport Project containing our comments on the proposed WA CFS Rule Updates. Thank you.

Sherrie Merrow
The Transport Project
Director, State Government Affairs
smerrow@transportproject.org
307.761.9717
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Comment From: Iowa Biodiesel Board (Grant Kimberley)

8/01/25 @ 9:16 AM
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Comment From: Avista Corp (Rendall Farley)

8/01/25 @ 9:05 AM
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Comment From: National Oilseed Processors As...

8/01/25 @ 8:30 AM
August 1, 2025
Adam Saul
Clean Fuels Program
Washington State Department of Ecology
Climate Pollution Reduction Program
P.O. Box 47600
Olympia, WA 98504
Via electronic submission
Re: Comments on Proposed Amendments to the Washington C...↓
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Comment From: Powering America's Commercial ...

8/01/25 @ 8:27 AM
Please find attached PACT's comments on the Clean Fuel Standard Rulemaking.
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Comment From: Public Utility District #1 of ...

8/01/25 @ 7:58 AM
Please see attached letter.
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Comment From: Western States Petroleum Assoc...

8/01/25 @ 7:48 AM
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Comment From: Growth Energy (Dallas Gerber)

8/01/25 @ 7:37 AM
Please see the attached comments from Growth Energy on the current CFP rulemaking.
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Comment From: Beta Analytic (Benjamin Kling)

8/01/25 @ 7:35 AM
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Comment From: Friends of the Earth et al. (Molly Armus)

8/01/25 @ 6:21 AM
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Comment From: Gevo, Inc. (Nancy Young)

8/01/25 @ 5:22 AM
Please see the attached comments from Gevo, Inc.
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Comment From: Michigan Soybean Association (Ben Steyer)

8/01/25 @ 4:46 AM
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Comment From: Dan DeRuyter

7/31/25 @ 10:27 PM
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Comment From: The Electric Vehicle Charging ...

7/31/25 @ 8:55 PM
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Comment From: Samuel Walker

7/31/25 @ 7:26 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies. In California, just over 2% of carbon reduction dollars were spe...↓
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Comment From: Promus Energy, LLC. (Dan Evans...

7/31/25 @ 4:36 PM
Please see comments attached.
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Comment From: Sound Transit (Amy Shatzkin)

7/31/25 @ 3:51 PM
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Comment From: Mainspring Energy (Franco Ghad...

7/31/25 @ 3:19 PM
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Comment From: Poder Latinx (Merivet Lombera)

7/31/25 @ 2:59 PM
My name is Merivet Lombera and I am speaking on behalf of Poder Latinx, a non profit, non partisan organization dedicated to empowering Latinx communities to build sustained political power and actively participate in democracy. I'm also a resident o...↓
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Comment From: POET, LLC (LLC POET)

7/31/25 @ 2:28 PM
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Comment From: Crissy Impero

7/31/25 @ 2:01 PM
As a lifelong resident of Whatcom County, Realtor and a member of the Whatcom County Cattlemen's Association, I am writing to strongly oppose the Department of Ecology's effort to remove voluntary incentives for farmers who invest in environmental im...↓
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Comment From: Mark DeRuyter

7/31/25 @ 1:51 PM
My name is Mark DeRuyter. I am reaching out because of the new suggested language put anerobic digestors in jeopardy due to Department of Ecology's new proposed rules that would exclude dairy from qualifying for renewable biogas energy projects in W...↓
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Comment From: Green Plains Inc. (Chris Knuts...

7/31/25 @ 1:21 PM
Public Comment on Proposed Amendments to Chapter 173-424 WAC (Clean Fuels Program Rule)
Submitted on behalf of Green Plains Inc.

To: Washington State Department of Ecology
Re: Proposed Amendments to WAC 173-424 (Clean Fuels Program Rule)
Docket No.:...↓
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Comment From: CityServiceValcon, LLC (Christ...

7/31/25 @ 12:55 PM
Please see attached file with comments.
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Comment From: Charles Anderson

7/31/25 @ 12:15 PM
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Comment From: Pamela Gross

7/31/25 @ 12:15 PM
Reform Washington's Clean Fuel Standard (CFS)
Submitted online via DOE Public Comment Form 7/31/25
Washington State Department of Ecology
Climate Pollution Reduction Program


Dear Casey Sixkiller, Department of Ecology Staff, and Adam Saul,

My fa...↓
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Comment From: Climate Solutions (James Hove)

7/31/25 @ 12:10 PM
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Comment From: Suburban Propane

7/31/25 @ 10:52 AM
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Comment From: Michael Hebdon

7/31/25 @ 10:47 AM
Please make sure that agriculture gets supported for the long term with these rules. The backbone of the American dream is in jeopardy. Limiting income streams and reducing benefits will destroy family farms.
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Comment From: Greg Pike

7/31/25 @ 10:13 AM
Department of Ecology rule language discourages investment in greenhouse gas reduction and renewable energy projects on dairies.

In California, just over 2% of carbon reduction dollars were spent on projects providing more than 29% of carbon reducti...↓
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Comment From: IL Soybean Growers (David Kubi...

7/31/25 @ 10:07 AM
Attached.
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Comment From: SkyNRG Americas (John Plaza)

7/31/25 @ 9:58 AM
See attached comments
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Comment From: Rosemary Moore

7/31/25 @ 9:55 AM
I am extremely concerned at the state's reliance on alternative or "sustainable" aviation fuel as a prime method of reducing the high greenhouse gas emissions produced by aviation. This will have only a very marginal effect on GHG emissions. However...↓
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Comment From: Missouri Soybean Association (...

7/31/25 @ 9:16 AM
Missouri Soybean Association comments attached
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Comment From: North Dakota Soybean Growers A...

7/31/25 @ 8:28 AM
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Comment From: Kansas Soybean Association (Ka...

7/31/25 @ 6:49 AM
Please see attached letter for Kansas Soybean Association comments.
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Comment From: Chad Kaler

7/31/25 @ 6:17 AM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.

In California, just over 2% of carbon reduction dollars were sp...↓
No attachments

Comment From: Jason Milkowski

7/31/25 @ 6:10 AM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.
In California, just over 2% of carbon reduction dollars were spe...↓
No attachments

Comment From: Washington State Transit Assoc...

7/31/25 @ 4:19 AM
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Comment From: Gail Shelton

7/30/25 @ 9:51 PM
Please STOP the Department of Ecology from taking away incentives for farmers to continue investing in environmental improvements!

Ecology's proposed rules discourage greenhouse gas (GHG) reduction and renewable energy projects on dairies�precisely ...↓
No attachments

Comment From: Cheryl Anonymous

7/30/25 @ 8:35 PM
Please STOP the Department of Ecology from taking away incentives for farmers to continue investing in environmental improvements!

Ecology's proposed rules discourage greenhouse gas (GHG) reduction and renewable energy projects on dairies�precisely ...↓
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Comment From: Jack Parriera

7/30/25 @ 6:16 PM
ACTION ALERT
COMMENTS NEEDED NO LATER THAN August 1, 10 PM. Please ask as many people as possible from your farm and family to submit comments.

Whether you have current, planned, or even possible environmental projects on your farm, it is IMPORTANT ...↓
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Comment From: Laura Gibbons

7/30/25 @ 5:24 PM
I am a Senior Research Scientist at the UW and a volunteer member of the 350 Seattle Aviation Team. I have done lots of investigating into the feasibility of so-called Sustainable Aviation Fuels (SAF), and I have to say they are neither sustainable n...↓
Attachments:
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Comment From: Debra Sytsma

7/30/25 @ 5:04 PM
Please STOP the Department of Ecology from taking away incentives for farmers to continue investing in environmental improvements!



Ecology's proposed rules discourage greenhouse gas (GHG) reduction and renewable energy projects on dairies�precisel...↓
No attachments

Comment From: Benjamin Tindall

7/30/25 @ 3:27 PM
Please STOP the Department of Ecology from taking away incentives for farmers to continue investing in environmental improvements!



Ecology's proposed rules discourage greenhouse gas (GHG) reduction and renewable energy projects on dairies�precisel...↓
No attachments

Comment From: 3Degrees (Theresa Keith)

7/30/25 @ 2:51 PM
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Comment From: Pacific Ag Renewables (Harriso...

7/30/25 @ 2:41 PM
The uploaded letter is from Pacific Ag Renewables CEO, Bill Levy.
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Comment From: Bobbie Piety

7/30/25 @ 2:36 PM
Enough with the harassment of farmers! We all know that methane and CO2 are blamed for natural climate variations. The climate has been changing for 500 million years, long before humans existed. Leave the farmers alone-- they produce less polluti...↓
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Comment From: Kevin Roberts

7/30/25 @ 1:59 PM
Please STOP the Department of Ecology from taking away incentives for farmers to continue investing in environmental improvements!



Ecology's proposed rules discourage greenhouse gas (GHG) reduction and renewable energy projects on dairies�precisel...↓
No attachments

Comment From: LoCI Controls, Inc. (Angeline ...

7/30/25 @ 1:43 PM
Please see attached PDF.
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Comment From: Jacqueline Rupard

7/30/25 @ 1:22 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.

In California, just over 2% of carbon reduction dollars were sp...↓
No attachments

Comment From: Patrick Farrell

7/30/25 @ 1:01 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.
In California, just over 2% of carbon reduction dollars were spe...↓
No attachments

Comment From: Darin Henry (DARIN HENRY)

7/30/25 @ 12:55 PM
To Whom it concerns, July 30,2025

RE: Chapter 173-424 WAC, Clean Fuels Program Rule

My name is Darin Henry. I have been a dairy consultant and veterinarian in WA for the past 30 years and currently assist a number of the most progressive a...↓
No attachments

Comment From: Electrochaea Corporation (Apri...

7/30/25 @ 9:21 AM
Re: WSR-25-13-080: Updates to Chapter 173-424 WAC � Clean Fuels Program

Electrochaea is a provider of an industrial-scale process for synthesis of renewable synthetic methane. e-methane, a form of synthetic methane, is produced when electrolytic hy...↓
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Comment From: Twelve Benefit Corporation (Ir...

7/30/25 @ 9:07 AM
Please see attached for Twelve's [corrected] comments.
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Comment From: United States Hydrogen Allianc...

7/30/25 @ 7:17 AM
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Comment From: Wade Essick

7/29/25 @ 8:55 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.
In California, just over 2% of carbon reduction dollars were spe...↓
No attachments

Comment From: Maren Bodine

7/29/25 @ 7:20 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.
In California, just over 2% of carbon reduction dollars were spe...↓
No attachments

Comment From: Tim Bodine

7/29/25 @ 7:17 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.
In California, just over 2% of carbon reduction dollars were spe...↓
No attachments

Comment From: Anita Kinghorn

7/29/25 @ 7:14 PM
Ecology should ensure credit is provided for a longer period of time for ALL on-farm environmental projects so we can work with the State on shared environmental projects and outcomes such as GhG reduction, renewable energy production and food waste ...↓
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Comment From: Stellar J Corporation (Bob Kin...

7/29/25 @ 7:04 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.
In California, just over 2% of carbon reduction dollars were spe...↓
No attachments

Comment From: Case VanderMeulen

7/29/25 @ 5:12 PM
Ecology should ensure credit is provided for a longer period of time for ALL on-farm environmental projects so we can work with the State on shared environmental projects and outcomes such as GhG reduction, renewable energy production and food waste ...↓
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Comment From: Jason Helaas

7/29/25 @ 4:37 PM
In California, just over 2% of carbon reduction dollars were spent on projects providing more than 29% of carbon reductions.�Our Legislature studied this great result and began funding similar projects in Washington State. Ecology's proposed rules un...↓
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Comment From: Troy Lenssen

7/29/25 @ 3:59 PM
Department of Ecology's proposal creates disincentives, rather than encouraging projects, it discourages investment in greenhouse gas reduction and renewable energy projects on dairies.

In California, just over 2% of carbon reduction dollars were sp...↓
No attachments

Comment From: Lauren Ranz

7/29/25 @ 2:58 PM

To the Washington State Department of Ecology,


I am writing to object to language in the updated CFS that encourages factory farm biogas, a dirty energy source that could pollute our water and worsen climate change. I oppose the express inclusion of ...↓


Washington should learn from the mistakes of California’s LCFS, which included avoided methane crediting. The LCFS kicked off a manure gold rush that has enriched the largest factory farms at the expense of people already severely impacted by factory farm pollution. The LCFS is mired in controversy, is currently the subject of numerous lawsuits, and is causing more harm than good when it comes to factory farm’s impact on the climate.


Avoided methane crediting perversely incentivizes factory farms to get bigger and pollute more to cash in on the policy, as opposed to simply polluting less in the first place. It prioritizes dirty fuels produced from factory farm pollution over truly clean energy like solar, wind, and EV charging infrastructure. This turns the CFS on its head and is bad for Washington and the climate.


It's important to note that Washington factory farms already have a terrible track record of environmental destruction and disregard for public health. Avoided methane crediting would turn Washington’s Clean Fuel Program into a massive payout for the worst of these polluters while increasing harms on environmental justice communities in our state.


As Washington aims to develop hydrogen that is green and environmentally friendly, encouraging hydrogen produced with factory farm pollution is moving in the wrong direction and will undermine any hope of achieving Washington’s climate goals.


Factory farm pollution must be aggressively regulated, not rewarded through loopholes in a climate program like the CFS. Please remove avoided methane crediting from Washington's CFS!

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