Rulemaking - Clean Fuel Standard

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

To the Washington State Department of Ecology,

I am adding my name to the many individuals writing to object to language in the updated CFS that encourages biogas from farms. I oppose provisions incentivizing biogas and provisions encouraging hydroge...↓n produced from farm gas.

California made mistakes with its LCFS resulting in a new income stream from manure from large farms that does the opposite of what was intended - encourages these large farms to get bigger and pollute more instead addressing problems experienced by lower-income people impacted by farm pollution from these same large farms. Avoid the controversy, and lawsuits by not taking a similar path in Washington.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

To the Washington State Department of Ecology,

I 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 “avoided metha...↓ne crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

We need to take better care of what is left of our environment, for people, wildlife, marine life, and plant life.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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...↓ “avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 “avoided methane crediting” and related provisi...↓ons that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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...↓ “avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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...↓ “avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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...↓ “avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 “avoided methane crediting” and related provisi...↓ons that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 “...↓avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 “...↓avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

Tothe 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 “a...↓voided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 “...↓avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

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 ...↓“avoided methane crediting” and related provisions that increase incentives for factory farm gas, and to the provisions encouraging hydrogen produced from or in association with factory farm gas.

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!

One issue I would like to raise that you did not have a chance to discuss yet today is the opportunity to improve support from the clean fuel standard for transit agencies by making a similar amendment to your rule to what the California Low Carbon F...↓uel Standard incorporated in its most recent amendments by which it allowed all fixed guideway systems to earn full credits aligned with their EERs, regardless of when the systems were built.

This is a great way to increase support for transit agencies when they really need that additional funding to increase their capacity, increase their service when they're facing a lot of fiscal difficulties. And these systems are providing a real GHG benefit regardless of when they were billed, that should be credited accordingly. So thank you so much for the consideration.

I've lived in Washington for 32 years and in Yakima for 10. I'm a climate activist with 350 Yakima Climate Action and I speak today on behalf of my organization and as a mother, grandmother and great grandmother deeply concerned about the impacts of ...↓industrial agriculture on our communities and climate.

I urge you to eliminate avoided methane credits for CAFOs, concentrated animal feeding operations that produce biogas through anaerobic digesters under the Clean Fuel Standard. These digesters are often promoted as climate solutions, but in reality they incentivize larger herds, leading to more methane pollution and consolidation of factory farms, hurting small farms in the process. They divert resources from truly sustainable solutions like regenerative agriculture and dry manure management, and they expose rural communities like the lower Yakima Valley to toxic pollutants like ammonia and hydrogen sulfide.

My son has suffered from asthma most of his life. Watching your child struggle to breathe is terrifying, and I know we are not the only family in Yakima County living with these impacts. Let's be clear, manure does not naturally produce high levels of methane. It's the giant lagoons used by cathodes that create it.

Digesters capture this methane, but the problem is these lagoons shouldn't exist in the first place. By rewarding digesters, we're encouraging farms to create more waste and pollution just to generate profit. The artificially low carbon intensity scores that biomethane will receive under the Clean Fuel Standard only encourages more manure and more emissions, the opposite of what we want. Small sustainable dairies can't compete and earn these credits and communities pay the price.

Washington should not greenwash factory farm pollution. As climate progress, we have the opportunity to lead where states like California have fallen short if ecology decides to move forward with the avoided methane credits. Alternatively, we urge you to include these guardrails.

• Prohibit herd size increases during the 15-year crediting period
• Close loopholes that allow farms to expand gas production and re-qualify for a new credit period
• Require updated nutrient management plans to account for digester waste and revoke credits for any CAFOs that violate environmental laws.

If Washington is serious about environmental justice and real climate action, it must stop rewarding pollution and start investing in climate resilient, sustainable transformation. Thank you.

My name is Molly Armus and I'm representing Friends of the Earth, a national environmental and social justice organization. On behalf of our members and supporters here in Washington, we echo a lot of what 350 Yakima Climate Action said and urge you ...↓to eliminate avoided methane credits for manure based biomethane production.

We are Very much concerned about the intensification of large-scale polluting manure management practices. We definitely see this as a penalty for sustainable small-scale livestock farms that are managing manure through practices that actually avoid methane creation.

I also do want to address Ecology's assertion that there's little evidence of avoided methane credits causing an increase in herd sizes in California.California does not maintain accurate data on dairy herd sizes. CAFOs and California report varying herd sizes across county data, across federal data, state permits, as well as part of LCFS pathway applications, and as part of the California Dairy and Livestock Database CAD, which was put together by the California Air Resources Board.

Based on all of those different sources, all of this data is self-reported with no substantive oversight.

Anecdotally, several California dairies with digestors have increased their herd sizes and exacerbate their pollution, and there is evidence that dairies with anaerobic digesters are more likely to increase their herd sizes relative to similar sized dairies without digesters.

In light of the gaps and inconsistencies in herd sizes self reported by the dairies across California, Ecology's assertion that LCFS has not incentivized capo growth is not only questionable, but does also directly conflict with the lived experiences of communities on the ground near these operations.

Simply because you know something is renewable does not make it sustainable or climate friendly.

We urge Washington not to follow California's lead.

Resist incentivizing methyl methane emissions from CAFO's, and I really urge you to remove the voided methane credits from the proposed rule.

Thank you.

I want to thank Ecology staff for their work on this rule. I want to just point to a couple of things and that has to do with what we think is the unnecessary stringency on the book and claim accounting for renewable natural gas and the use of renewa...↓ble energy credits to lower carbon intensity for electricity.

They don't we don't believe serve a public policy purpose for clean fuel program and we will be submitting written comments along with other gas and electric fuel providers to that effect.

But I did want to highlight just one point with regard to the carbon intensity reduction method using renewable energy credits and the limitation it it requires that it be facilities built after 2019 and only in Washington, Oregon and Idaho. And I don't think it's as important as when the facility is built as it is when the renewable energy credit was generated.

Utilities don't typically just build a renewable facility to meet new load. We have a lot of other tools available to us including non wire solutions such as energy efficiency and demand response and these are different ways and more cost effective ways to meet new load and and achieve just the same amount of reduced emissions.

Furthermore, the limitation on Oregon, Washington and Idaho geography is doesn't align with the physics of the grid. We are interconnected across the West.

Avista and other utilities have and are building renewable energy systems in Western Montana, for example, which is directly intertwined with the balancing area that Avista serves and the rest of the of the utility system in the West.

We think renewable energy credits certified within the REGIS system, which is the system by which Washington utilities generate, transact and retire RECs would qualify, should qualify for reducing the carbon intensity for electricity.

So thanks for the opportunity to comment today.

My name is Jean Mendoza and I'm the executive director for Friends of Toppenish Creek, a nonprofit in the Yakima Valley.

I would like to bring your attention to one big problem. Concentrated animal feeding operations damage the environment. They are n...↓ot sustainable in the long term, and I hope the Ecology will look closely at the adverse impacts of subsidizing and supporting capital dairies in our state. I'm Hoping Ecology will take a broad view of how the low carbon fuel standards impact this industry.

The Ecology only looks at the benefits of capturing manure methane. The agency fails to account for the increased damage that occurs when dairies increased herd size in order to make more money from manure methane. There's clear evidence that dairies in Wisconsin and California have consolidated and enlarged when manure methane biodigesters are introduced due to badly written clean fuel policies.

With more cows, there will be more volatile organic compounds in the ambient air and this will lead to higher ozone levels. Ozone levels in the Yakima Valley and the Tri-City area are already near current safety levels with occasional exceedances. Ozone is not only damaging to human health, but ozone in the air also damages crops and leads to decreased yields.

And this is very important in Central Washington where we're economically dependent on agriculture. More cows means increased withdrawal of groundwater, and this is a big problem throughout Eastern Washington where the aquifers are falling and there's very little recharge.

Please look at the big picture and reconsider how this rule is currently written. Would subsidizing the dairy industry increase cow numbers and increase environmental damage when there are too many cows?

Thank you.

For the record, my name is Jay Gordon. I am with the Washington State Dairy Federation and an eighth-generation farmer in Western Washington.

A few things for the record, we will be submitting additional comments on this.

99.2% of all the dairy farms i...↓n Washington state are family owned. There is one WSU dairy that is not, and there's another dairy that is a corporate dairy. Our oldest dairy family in the state has been milking cows since the 1300s.

Over 700 years, they've learned how to take care of and feed and care for animals. A confined animal feeding operation is what we do. It's used as an expletive, but we can find animals in things called barns. We feed them because not feeding them would be animal abuse.

It gets old hearing that CAFOs are polluters. The Department of Ecology, the Department of Agriculture, the EPA, and the local health districts all have regulatory authority on various aspects of dairy farming. Dairy farmers are the most regulated sector of agriculture. Dairy farmers do not pollute. Our intent, our plans, our everyday activities are to prevent that.

Go down the hall, Adam, and ask Department of Ecology has a division that regulates dairies. Ask them when the last time they farmed a dairy. If we pollute so much, why do we have so few, if any, penalties by EPA, Ecology or the Department of AG?

Every dairy in the state without exception has a manure storage system that produces some methane. Those systems were put in in the 60's, the 70's, the 80s and the 90s to prevent pollution. That includes small farms, large farms, old farms, farms that are growing, which we do.

There is no proof that adding a methane digester expands dairy.

The profit levels amongst our 6th digesters in Washington are abysmal. They are struggling to stay afloat. They are not making a profit. It does not drive growth. It is not a profit center and it is not something that's going to attract Shell Oil to buy our dairies to make methane.

A 14-year avoided methane credit is too short to support the capitalization to catch the methane that we have coming off of our lagoons to the last 30-40. Fifty years of getting rid of the avoid of methane would shortchange an energy source, it would shortchange the environment, it would shortchange the dairy farmers ability to reduce their carbon footprint.

Thank you and we will be submitting comments.

I'm a climate activist with 350 Seattle. I believe our country and our state need to move away from concentrated animal feeding operations and large corporate-run dairy farm which are polluting our atmosphere and our communities. Specifically, our s...↓tate needs to develop policies that result in cleaner and more environmentally sound practices on dairy farms, such as dry manure management. Yet, with the Clean Fuels Program and state subsidies for biodigesters, dairy agriculture is moving in the opposite direction. This is because the artificially low CI score that dairy gas receives incentivizes an increase in herd size to maximize the amount of manure created. Dairies then, as you know, using a biodigester, sell the resulting gas.

While it's technically true that manure biodigesters are diverting methane from the atmosphere into gas tanks, giving it a low CI score due to avoided methane rests on a faulty premise. That's because cower manure doesn't inherently contain methane. It's the lagoons that create the methane. Dairies with biodigesters aren't sucking greenhouse gases out of the air, like carbon dioxide removal projects. They're generating new methane they didn't need to generate in the first place, and then they're trapping it.

Also important is the fact that CAFOs harm nearby rural communities, including in Washington, and impact residents' air and water quality. Pollution from manure contributes to asthma, respiratory illnesses, contaminated drinking water, and degraded quality of life.

I also want to just note, before I conclude, that Washington's draft climate action plan notes that manure management strategies that shift away from liquid manure stored in anaerobic conditions mitigate methane emissions from manure. Even our own draft climate action plan is noting the importance of moving away from lagoon systems. I urge you to please eliminate avoided methane credits in connection with CAFOs. And thanks so much for your time and consideration.

My name is Yanni Psareas. I'm the Legislative Affairs Manager for the RNG Coalition, and a resident of Vancouver, Washington. We're a national trade association representing approximately 400 member organizations who collectively produce 90% of all r...↓enewable natural gas in North America. We appreciate the opportunity to provide comments on the draft rule and we appreciate the department's leadership in advancing the clean fuel standard.

Our members are committed to advancing policies that reduce lifecycle carbon intensity in the transportation sector, and expand investment in methane mitigation and clean fuel deployment. While we strongly support the Clean Fuel Standard Program, the draft rules constraints on avoided methane crediting periods, and pipeline limits for RNG supply significantly constrain RNG developers' ability to help achieve the program goals. We're particularly concerned with the 15-year avoided methane crediting period that falls short of what's needed to support viable RNG project development in Washington. 

Most projects in agricultural and organic space are underwritten based on crediting over 20 to 30 years. Capping this at 15 years, especially when paired with Washington's lower credit values, will chill investment and undermine the program's ability to drive real methane reductions. Second, we urge Ecology to remove pipeline deliverability restrictions. RNG, once injected into the pipeline, is indistinguishable from fossil gas and should be treated as fully fungible. 

These limits introduce unnecessary complexity, raise costs for Washington fleets, and disconnect our program from broader North American RNG markets. Finally, we respectfully encourage Ecology to reflect HB1409's passing and the direction to align with other jurisdictions, particularly California, by adopting a harmonized framework that ensures stability for clean fuel markets and investor confidence in Washington state. 

Thank you very much for the opportunity to comment. 

I am Pamela Gross. I'm here today to testify, also joining in the company of others, to strongly oppose continued incentives for factory farm gas in the clean fuel standard. My home is in San Juan County, and I was shocked to learn that in neighborin...↓g Skagit and Whatcom counties factory farms confined thousands of milk cows in super close quarters.  I started educating myself, and the more I learned, the more offended I became. 

Corporations involved in factory farm gas schemes are not interested in protecting preserving or enhancing Washington's environment. They do not share DOE's vision to protect and sustain healthy land, air, and water. Big Ag and Big Oil and Gas, with their factory farms and gas production schemes, violate our values and violate our common sense. They are not good neighbors. Good neighbors don't pollute our air or water. 

Factory farms are an ecological, environmental, and public health disaster whose business model is not anywhere near aligned with the goals for clean fuel standards. Further incentivizing them as a source of energy is a false and impossibly cruel solution. Ecology claims its proposal incentivizes new and additional methane capture, but in reality, by including factory farms in the CFS this proposal is encouraging new and additional methane creation. Washington should not greenwash factory farm pollution as climate action. 

My family and I urge ecology to eliminate avoided methane credits. Washington has a chance to lead where California fell short. Please reform this policy. Protect communities, not polluters. Thank you for your time and consideration. 

My name is Jamie Hall. I am the Director of Policy for EV Realty. We build, own, and operate truck charging hubs to enable electrification of medium and heavy-duty commercial vehicles.

I just want to start by thanking you for your work to date on thi...↓s rule. I think this has been a good, transparent process with a lot of public input, and we appreciate it. I specifically want to support the heavy-duty FCI, or capacity credits. This is a really innovative and elegant way to support build-out of charging stations ahead of widespread truck development and kind of break this chicken-or-egg dilemma that that is kind of keeping us at a standstill here. 

It's really great specifically to see that shared charging depots are eligible, and we Appreciate the 10-megawatt cap. I think that's a reasonable limit to set and a good way to ensure a diversity of sites. 

And then one other quick comment, I think a longer crediting period would help send a stronger market signal. For what it's worth, California uses 10 years for both electricity and hydrogen and we think that will send a bit stronger signal and help ensure that we really get these chargers out there. 

We're continuing to review details, and we'll probably follow up with written comments on some more details around the capacity credits, verification, and some of the broader program goals, but I just wanted to touch on some of these high-level items that came up in the presentation earlier. 

I'll also say that Clean Fuel Standard is one of the most important tools the states have for supporting transportation electrification in particular. I know a lot of the discussion is around issues on the biofuel side, that are definitely complicated. I just want to note that this policy also helps with electrification. And what you're doing in terms of including a capacity credit provision for medium- and heavy-duty vehicles is a big step forward. So, thank you. 

Hello, my name is Lucero Mendez. I live in Yakima, Washington, and I'm testifying today to strongly oppose incentives for factory farm gas in the Clean Fuel Standard. Growing up, I spent much of my childhood in Sunnyside, as my mother worked in orcha...↓rds for years.  I would stay with my aunt, who lived near numerous dairies and small farms. I witnessed firsthand the heavy toll of air pollution and emissions from large, under-regulated factory farms. 

These concentrated animal feeding operations have overburdened our communities, outnumbering local cows. Beyond sustainable limits and violating manure managing guidelines. This has degraded Sunnyside's air quality. Contaminated soil and harmed the health of families and neighbors in our lower valley. Small farm families who have been part of our community for generations. Are being pushed out by these industrial operations, which prioritize profit over people. The clean fuel standard incentives for… Faculty Farm Gas, or biomethane create a perverse system that rewards pollution, in my opinion? By giving credits for the making captured for Manure Lagoons, the policy encourages CAFOs to produce more manure and expand herd sizes worsening our air and our water pollution. And this proportionally harms communities of color, low-income residents, like those in Yakima and Sunnyside, who face increased asthma respiratory issues and contaminated drinking water. 

Methane from manure is not a clean fuel. It relies on fossil fuel infrastructure and ignores emissions from feeding production and digestate waste. Sustainable manure management alternatives exist, but receive no support under this program, and I urge the Department of Ecology to eliminate methane credits from the clean fuel standard. If this isn't possible, prohibit herd sizes increased during the 15-year credit period, close loopholes allowing capitalists to re-qualify for new credits, and require updated nutrient management plans for digester waste and revoke credits for CAFOs that are violating environmental laws. I believe Washington must prioritize community health and real climate solutions, not greenwashed factory farm pollution. 

Thank you for the space, and thank you for your time. 

My name is Mark Ventura I work for The Philips66 Company, which operates a petroleum refinery in Washington State, as well as fuel terminals, and supplies fuels throughout the state as well as other western states. Philips 66,is a member of the Weste...↓rn State Petroleum Association, sometimes called WSPA, and we will be submitting comments through WSPA by the deadline. 

WSPA has already submitted a number of written comments through the prior workshops last year. We are encouraging Ecology to seriously consider the comments that has been submitted as well as the new comments that we'll be submitting. And they will be consistent with prior comments, so we hope that

consider that and update the proposed regulation to make it a more practical system and reporting system. As well as a fairer system.

For instance, there are a number of biased positions in the CFS. Where you would, for instance, make correction in the program and adjust deficits or increase deficits if it's appropriate. But you would not adjust the credits if they're credits would be adjusted. So, that's just a simple example, but the program should be fair if you make a correction one way, you should do it the other way as well.

So again, be on the lookout for those written comments, and feel free to reach out to WSPA as an organization or to Philips 66 if you have specific question about those comments. Thank you. 

I'm a Washington State resident of 51 years, and today we'll focus on the biogas provisions of this act - which, in general, rewards huge dairies and works to encourage consolidation in our industrial animal agriculture sector. That has severe associ...↓ated consequences for violations of our Clean Air Act and our Clean Water Act, and also social justice violations. That hurts most of our most vulnerable communities, where these consolidated operations are often located.

Well, it seems safe to follow in California steps. That experiment has demonstrated clear and disastrous secondary consequences. The Act and its proposed revisions is clearly an attempt to encourage the production of manure, dairy manure, source biogas, with the unintended consequence of financially supporting one of the most polluting industries of our state.

While on the surface it sounds wonderful that we can turn the huge manure from CAFOs into free energy, a careful analysis shows that this approach actually makes the problem far worse.

First of all, the industry likes to call them methane digesters, as if these operations get rid of methane - which is one of the worst greenhouse gases, far exceeding CO2. But the digesters actually produce methane and do not remove it and just seek to capture the newly produced methane. Second, the biogas plants produce a huge amount of CO2 along with the methane. And the disposition of that CO2 remains unregulated - likely, a large proportion is just released into the atmosphere, completely negating the entire purpose of the Clean Fuels Act.

And the other portion of the CO2 is actually refined and sold, largely to beverage companies. It drives me crazy that Coke does not make its own bubbles. We're actually partially drinking manure gas. It is no wonder that three of the largest fossil fuel companies in the world have each spent over $2 billion in the last year purchasing biogas infrastructure companies, and are actively working to convince Washington farmers to consolidate to be able to afford the biogas infrastructure. 

Why? Because they know that fossil fuels are under attack worldwide, led by the United Nations Sustainable Development Goals, and that energy source diversification makes good business sense. But with biogas, the proposed Washington Clean Fuels Act, they get paid for their business diversification. It doesn't take much thought to understand that with free carbon credits that are tradable out-of-state they can mitigate their fossil fuel activities. And this act becomes a fossil fuel. Corporate gold mine. I also worry about our state food security. It will not be long before the very large fossil fuel companies become shareholders in our largest farms. 

But I just end with that we have to be aware that these tax incentives and carbon credits have negative consequences that sometimes outweigh the positive work that we're trying to do. Thank you.