Greenhouse Gas Assessment for Projects Rulemaking CR-101

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Comment From: Jeanne Deller

3/17/21 @ 8:57 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Perry Gx

3/17/21 @ 8:57 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Charlene Lauzon

3/17/21 @ 8:56 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Stephan Classen

3/17/21 @ 8:56 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Janet Wynne

3/17/21 @ 8:55 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Jesse Taylor

3/17/21 @ 8:54 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Joel Leitner

3/17/21 @ 8:54 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Leo Kucewicz

3/17/21 @ 8:53 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Power Past Fracked Gas (Stephanie Hillman)

3/17/21 @ 6:13 AM
Attachments:

Comment From: Elizah DeMartini

3/17/21 @ 1:57 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet.
No attachments

Comment From: Hillary Sanders

3/17/21 @ 1:26 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea-level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible, not to mention unethical. How can we look young people in the eyes years from now and say with authenticity we did everything we could when we are not even holding our state's biggest polluters accountable?

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

The first step in addressing the climate crisis is telling the truth. Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Graham Golbuff

3/15/21 @ 5:51 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

No attachments

Comment From: Julie Martinson

3/08/21 @ 7:23 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Alan Kaptanoglu

3/08/21 @ 4:24 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!
No attachments

Comment From: Joshua Rubenstein

3/08/21 @ 1:00 AM
Dear Rulemaking Lead Fran Sant,

We have known for half a century that we must stop burning fossil fuels for the health of our communities and climate. We have known that we must therefore stop permitting fossil fuel infrastructure. Yet fossil fuel pro...↓

Please use this rulemaking as an opportunity to stand up for Washingtonians who's health, homes, and lives will be sacrificed by regulators and industry if climate and environmental health are not prioritized in the regulatory process. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of communities being targeted and/or systemically harmed by heavy industry is clear in our local health disparities maps, the disproportionate impact of COVID-19 on communities near polluting industries and distribution lines, and the proximity of current and past toxic industries to Indigenous communities and communities of color.

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Joshua Rubenstein
WA

No attachments

Comment From: Elana Sulakshana

3/07/21 @ 12:18 PM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Elana Sulakshana
915 16th Ave Seattle, WA 98122-4529

No attachments

Comment From: Margie Bone

3/06/21 @ 12:19 PM
Dear Rulemaking Lead Fran Sant,

As a physician, it is clear that people of color and low income communities are both most impacted and least able to respond to protect themselves in response to pollution and the worsening impacts of climate change. Th...↓

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of communities being targeted and/or systemically harmed by heavy industry is clear in our local health disparities maps, the disproportionate impact of COVID-19 on communities near polluting industries and distribution lines, and the proximity of current and past toxic industries to Indigenous communities and communities of color.

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Margie Bone
120 NE 53rd St Seattle, WA 98105-3727

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Comment From: Gregory Denton

3/06/21 @ 7:58 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet! We are in climate, biodiversity and systemic racism crises, act now!

Sincerely,
Gregory Denton
5600 Kirkwood Pl N Apt 103 Seattle, WA 98103-5964 greg.denton@gmail.com

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Comment From: Laura Gibbons

3/05/21 @ 11:48 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Laura Gibbons
5021 43rd Ave S Seattle, WA 98118-2305

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Comment From: Elizah DeMartini

3/05/21 @ 11:02 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Elizah DeMartini
11516 6th Ave NW Seattle, WA 98177-4727 elizah.demartini@gmail.com

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Comment From: James Little

3/05/21 @ 9:25 AM
Dear Rulemaking Lead Fran Sant,

Please correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of communities being targeted...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
James Little
5208 Latona Ave NE Seattle, WA 98105-3744 littlejamesw@gmail.com

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Comment From: Stacy Oaks

3/05/21 @ 9:25 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.

  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.

  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Stacy Oaks
2417 86th St NE Tulalip, WA 98271-8040

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Comment From: Emily Johnston

3/05/21 @ 9:13 AM
Dear Rulemaking Lead Fran Sant,

This rulemaking is a chance to correct systemic harms that have gone unchecked and unanalyzed for far too long. Industry and regulators have ignored that health and climate impacts are directly connected. Evidence of co...↓

The new rules must:

  *Acknowledge and uphold Treaty rights. Engage in meaningful consultation, and fulfill the trust responsibility to protect and preserve the natural ecosystems and resources.
  *Include community health assessments. Understanding the impacts to Washington communities and communities, potentially affected by any part of the project's life cycle, must be a prerequisite to good decision-making by permitting authorities.
  *Safeguard communities from inadequate assessments. Create prerequisites that would preclude agencies with conflict of interest, e.g. monetary interest in a project, from being in charge of the permit process as lead SEPA agency. Accountability is critical for ensuring accurate and full analysis.

Ecology’s Greenhouse Gas Assessment (GAP) rule comes at a critical time, as the harm from climate change becomes increasingly evident. Wildfires, decreased snowpack, and sea level rise threaten the very existence of our communities. These harms will fall hardest on the people who already bear a disproportionate share of our environmental burdens.

At a time when WA and the world must dramatically reduce emissions as quickly as possible, any proposal to construct a massive new source of greenhouse gas emissions is irresponsible.

The new rules must also:

  *Require a climate test based on the best available science to assess a project’s impacts.
  *Require assessment methods of a project’s full lifecycle carbon footprint.
  *Include strong, enforceable mitigation requirements grounded in equity and with an aim of reducing emissions.
  *When evaluating methane emissions, the more potent 20-year impact value should be used, in recognition of the International Panel on Climate Change identifying a timeline of less than a decade to make the unprecedented changes needed to avoid climate catastrophe.
  *Cumulative impacts must be included in the decision-making process, meaning that the emissions of new or revised construction shall not be analyzed by itself, but must include the gross emissions of all emissions in the region with the impacts to the residents.

Please take a stand for justice, healthy communities, and a liveable planet!

Sincerely,
Emily Johnston
2418 E Aloha St Seattle, WA 98112-4120

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Comment From: Erik Jaszewski

3/02/21 @ 2:18 PM
1. The environmental assessment shouldn't analyze "how the project could change energy flows or uses" but instead how the project could increase/impact GHG emissions from energy flows or uses. SEPA after all focuses on impacts, and not benefits (whic...↓
2. Mitigations shouldn't be "decreased or eliminated based
on the projects' contribution to a future decarbonized economy." The normal SEPA process would account for projects that contribute to decarbonization through the cumulative analysis. A project should be subject to any appropriate mitigation measures for its direct and indirect impacts; and a decarbonization project would appropriately not result in cumulative impacts--and therefore would not have any cumulative impact mitigation measures.
3. The GHG emissions that should be included in the mitigation plan are all that can be reasonably attributed to the project. That should include, if appropriate, all inputs, in- and out-of-state emissions, and upstream/downstream emissions. Otherwise the impact analysis will have major information gaps.
4. There's no need to create a special category for decarbonization projects. If these trigger the screening criteria, then their GHG impacts should be evaluated. Simply because they don't have cumulative impacts (i.e. through supporting decarbonization), doesn't mean that their direct or indirect impacts are any less relevant.
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Comment From: Marathon Petroleum Company (Drechsel Chris )

3/01/21 @ 1:56 AM
As we noted during the meeting, MPC believes the GAP rule could improve how GHG emissions are reviewed for projects under SEPA and provide the business community more regulatory/permitting certainty when implementing projects in the State of Washingt...↓

For your review is an attached table with a list of relevant projects that have been permitted at the MPC Anacortes Refinery since 2003 and the associated GHG direct and indirect emissions. If the GAP rule were to have been in effect since 2003, 45% of the permitted projects at the refinery would have been covered by the rule (highlighted in orange), with two additional projects (highlighted in blue) very close to the threshold. Note that these project emission estimates include certain indirect emissions, but are not considered full “life-cycle” evaluations of these projects. A consideration of a broader range of indirect emissions would essentially bring in all permitted projects at the refinery into the rule. 

MPC appreciates the opportunity to provide these comments and data, and we would request that Ecology consider this information when drafting the proposed rule and determining the appropriate applicability threshold. I am available to respond to any questions you may have or if you require additional information.
Attachments:

Comment From: Western States Petroleum Assoc... (Robert Poole)

2/23/21 @ 2:04 AM
Attachments:

Comment From: Renewable Energy Group (Kent Hartwig)

2/09/21 @ 7:45 AM
Attachments:

Comment From: Renewable Energy Group

2/09/21 @ 7:45 AM
Renewable Energy Group, Inc. (REG) Carbon Intensity Report: Renewable Diesel Produced from Soy Oil, Used Cooking Oil, Animal fats, Canola Oil, and Corn oil
Attachments:

Comment From: Stockholm Environment Institut... (Peter Erickson)

1/14/21 @ 2:52 AM
Attachments:

Comment From: bp (James Verburg)

1/05/21 @ 5:05 AM
Attachments:

Comment From: Western States Petroleum Assoc...

12/31/20 @ 1:01 AM
Attachments:

Comment From: Port of Seattle (Elizabeth Leavitt)

12/30/20 @ 1:31 AM
Attachments:

Comment From: Washington Public Ports Associ... (Gerald O'Keefe)

12/21/20 @ 7:04 AM
Attachments:

Comment From: BlueGreen Alliance (Jessica Koski)

12/15/20 @ 5:00 PM
Attachments:

Comment From: Stockholm Environment Institut... (Peter Erickson)

12/15/20 @ 10:17 AM
Dear Department of Ecology GAP Rulemaking Team:

Please see attached comments that respond to some of the questions posed in your November 17, 2020 webinar.

We are grateful for the opportunity to provide these comments and would be happy to answer any q...↓

Sincerely,

Peter Erickson, Michael Lazarus, and Derik Broekhoff
Senior scientists
Stockholm Environment Institute, U.S.

Attachments:

Comment From: Ports of Longview, Kalama, Woo...

12/15/20 @ 10:11 AM
See attached letter in response to Ecology's request to receive informal input and feedback during the ongoing CR-101 phase for GAP rulemaking process.
Attachments:

Comment From: Avista Utilities (Kevin Booth)

12/15/20 @ 8:53 AM
See attached.
Attachments:

Comment From: Northwest Pulp & Paper Associa... (Christian McCabe)

12/14/20 @ 5:00 PM
Attachments:

Comment From: Nucor Steel Seattle, Inc. (Matthew Lyons)

12/14/20 @ 5:00 PM
Attachments:

Comment From: Kaiser Aluminum Washington, LL... (Kyle England)

12/13/20 @ 5:00 PM
Attachments:

Comment From: State of Washington House of R... (Gerry Pollet)

12/08/20 @ 12:36 PM
Attachments:

Comment From: Earthjustice (Amanda Goodin)

12/01/20 @ 5:03 AM
Please see attached Comments on Chapter 173-445 WAC, Greenhouse Gas Assessment for Projects (GAP) Rule submitted by Earthjustice, Front and Centered, Friends of the San Juans, Sierra Club, Washington Environmental Council/Washington Conservation Vote...↓
Attachments:

Comment From: Ian McCluskey

12/01/20 @ 2:29 AM
Include Scope 3 emissions in all assessments.
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Comment From: Washington State Petroleum Ass... (Tiffany Roberts)

11/30/20 @ 11:49 PM
Attachments:

Comment From: Robert Briggs

11/30/20 @ 8:18 AM
Attachments:

Comment From: Therese Livella

11/30/20 @ 1:28 AM
Environmental Assessment Questions

Are there special considerations we should take into account for projects that may lack a central facility or clear “on site” emissions (e.g., linear projects)?  They should be subject to strict review and mitig...↓

Is it more important to focus on the net emissions or on the gross emissions of a project? What should be the role of global economic analysis (e.g., developing a project global supply and demand curve) in the assessment?  Net.  Taking global supply and demand into consideration is useful but is only part of the assessment.  It is impossible to predict what new technology may emerge in 40-50 years or how the prices may fluctuate.   

What should the role of economics play in the Energy Analysis? Is it enough to note where supplies of energy will change, or should the price effects of those changes feed into a dynamic price model (or similar analyses)?  It is useful to consider economics but those are just projections.  The environmental impacts are certain.  Those should be valued higher.

 What should the time period for the assessment be? Under SEPA, the analysis usually considers the typical operational lifespan of a project and construction but the time period could be longer to align with the GHG emission limits, or for other reasons.  The time period should be the entire life span of the project from construction all the way through to cleanup afterward.  I am so very tired of superfund sites paid for by the American people.  If we knew the true cost of fossil fuels we may choose conservation on our own.

Should the rule identify starting and ending points of the life cycle analysis for project inputs and outputs? This could be at specific points, or the rule could provide more general direction, depending on the project type.The time period should be the entire life span of the project from construction all the way through to cleanup afterward.  I am so very tired of superfund sites paid for by the American people.  If we knew the true cost of fossil fuels we may choose conservation on our own.

At what point should the analysis terminate downstream? Should the first potential use be included in the life cycle analysis as the end point?The time period should be the entire life span of the project from construction all the way through to cleanup afterward.  I am so very tired of superfund sites paid for by the American people.  If we knew the true cost of fossil fuels we may choose conservation on our own.

For example, in the case of fossil fuels the combustion of that fuel if some other use is not known, or if the first potential use is not demonstrable? The most environmentally harmful use of the fuel should be used when making calculations.  As we have seen with NWIW, unscrupulous companies will change their plans based on mood of the moment just to get a permit.  This is why mitigation efforts must be made in advance.  

For non-fossil fuel products should the first potential use be considered to be the first use, or analyzed as multiple uses, or a final end use of the product?  It is acceptable the analyze multiple uses however, any permits and mitigation should be based off the worst case scenario.  If the company and the public still want to proceed and it can be proven that the project is not as environmentally harmful as predicted, then efforts to reimburse the company can be made.  The environment and the public have footed the bill for corporations long enough.

 

Mitigation Questions

What types of emission should mitigation address? On-site emissions, in-state emissions (on-site, upstream and downstream), upstream out-of-state emissions?  All of it.  These large energy projects specifically choose certain areas because of lax restrictions.  The time for the public and the environment paying for the hidden costs of these projects is done.  The state who issues the building permits must take the responsibility to ensure the project progresses in an ethical manner.  

The Washington State Legislature has established GHG reduction goals for the future; how should these GHG reduction goals influence the mitigation plan?  They should be a central point along with other major pollutants and quality of life issues.

Should mitigation vary for different types of projects, such as factories, export facilities, or linear projects like pipelines or electricity lines?  No.  They are all part of the project.  If a company spots a loop hole they will exploit it.  NO LOOPHOLES!

If the environmental assessment includes a net emissions analysis, how should this be treated in the mitigation plan?  Mitigation based on net emissions should happen before any building permits are issued.  If it is determined later that the company has over mitigated, public reimbursement could be considered.  

How should emissions involving projects that modify an existing facility be calculated?  As transparently as possible.

What process should be used to track and verify emissions subject to mitigation?  The results/progress should be made public.

How would changes to calculation methods or emissions be handled?  Through a public process.

How should mitigation projects be prioritized?  The public should have the final say as to weather a mitigation project is approved.  Because basically a mitigation project is saying "we are willing to trade this thing for that thing".  If I have learned anything through the years of following environmental and political issues, it is that the more points of view you hear, the more informed your decision can be.  If we did not have such a well informed group of citizen activists in this state, we would have total environmental collapse already.  

Are there types of mitigation projects which should or should not be included?  Absolutely no cap and trade.  Mitigation projects must be fully completed prior to the start of any construction permits for new facilities.  For current facilities seeking to mitigate, those efforts must be subject to a citizen process to be sure that all voices have been heard.  Mitigation efforts must be meaningful to the community in which the facility is located and/or where the upstream/downstream effects are felt the most.
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Comment From: Querido Galdo

11/27/20 @ 4:10 AM
There should be 'cradle to grave' assessment and mitigation of GHG emissions. They should be assessed onsite, as well as upstream and downstream--from the point of extraction, through distribution, all the way to use by the consumer.
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Comment From: Climate Action of Southwest Wa... (Don Steinke)

11/26/20 @ 3:36 AM
Thanks for your hard work on this.  Your questions tend to force me into the weeds instead of the birds eye view.

According to the IPCC and to our State law, we need to get to net zero by 2050 or sooner.
 
Your questions are similar to: I...↓
 
It is the same with greenhouse gases. We don’t want new sources, or other sources. We can’t afford either.
 
Globally, we need to stop new sources before capital is invested in them and all the other sources need to stop.
 
A greenhouse gas assessment for projects should include:
 
·         The methane leaks from the wells when they become obsolete.  There are millions that have not been properly sealed and decommissioned.
 
·         The methane leaks from operating well fields, pipeline gathering areas, pipelines, compressor stations and around end users.   Assume the fugitive emissions of methane are at least 3%, unless verified to be less.
One study discovered that the methane leaks from fertilizer manufacturing plants was far higher than anyone imagined.
 
·         All the downstream ghg over time.  Much plastic is burned because it is cheaper to use virgin feedstock than to recycle.  Assume all petrochemicals such as plastic, tires, and  fertilizer will become CO2 plus other gases over time. 
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Comment From: bp (Jim Verburg)

11/19/20 @ 7:16 AM
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Comment From: Pete Stoppani

11/18/20 @ 5:26 AM
greenhouse gas (GHG) emissions must be assessed onsite, as well as upstream and downstream- meaning that for a new fossil fuel project like a pipeline, emissions from the point of extraction (often via fracking) through distribution (and the leakage ...↓
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Comment From: Jeanne Poirier

11/18/20 @ 2:50 AM
The most important way to control GHG assessment is to just simply not allow any new fossil fuel infrastructure to be built! The entirety of the project and lifespan would be next. By this I mean is it on water? Is on Native land? Is it a pipelin...↓
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Comment From: John Rothlin

11/17/20 @ 3:15 AM
I would like to echo Bob's request to have an opportunity to review and respond to rule language during the rule development period prior to the CR-102 being released.
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Comment From: Western States Petroleum Assoc... (Bob Poole)

11/17/20 @ 2:30 AM
Bob Poole with the Western States Petroleum Association, a couple of request going back. Obviously you, you're not going to be able to respond today, but we'd like you to address some issues. One of them particularly has to do with the general catego...↓

So, it seems that in summary the GAP rule discriminates against private party projects versus public, and yet SEPA doesn't do that. So we'd like to have some information on explanation around that. And speaking of SEPA, it seems as though with the inclusion of the life cycle analysis, what occurs to us, the effective 10K threshold, while it's a significant trigger accounting for the indirect source issues relative to the energy supply analyses, etc.; it seems like that you're effectively looking at a separate nontraditional SEPA process by imposing these dynamics. So those are some of the thoughts I have relative to input in this area, and hopefully we can get some feedback at a point on some of these more global issues.

And in closing we'd like more information on how the GAP could be more flexible with the life cycle analysis. Thank you.
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Comment From: Phillips 66 (Steven Smith)

11/17/20 @ 2:30 AM
Steve Smith with Phillips 66. Two questions, and I'll keep them brief and maybe come back with more later. So, a question on biogenic emissions. So, you touched on that earlier in the slide set, that biogenic emissions should be included in the evalu...↓

Another question just to fill out my second one, and I think I've raised this before. I would really encourage the agency in thinking about a value assessment in mitigation, to think about the potential for double counting of mitigation requirements. So simple example, we have your state to the South, Oregon, considering a cap and reduce regulation that would potentially require continual reduction of emission, so, that would be mitigation of an emissions. And so if there's a requirement for mitigation of ongoing emissions there and yet there's a requirement to the North in Washington for the same product that is produced in Washington and that goes to Oregon, I think there's huge potential for double counting of mitigation requirements. So, I would ask you to really as a group, we should all be thoughtful about a double counting, especially as you get to assessment in mitigation. And I will stop there to allow others to speak. I may come back later. 
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Comment From: Brandon H

11/17/20 @ 2:30 AM
So I guess a question, you guys referenced the Governor's Executive Order, which we're all familiar with. But the legislature also weighed in on this with the budget proviso that they've provided in this last biennium. And they made it clear that the...↓
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Comment From: Evergreen Carbon (Wolf Lichtenstein )

11/17/20 @ 2:30 AM
I'm Wolf with Evergreen Carbon. So, I do a lot of work on the mitigation side and just quickly, so the double counting it's not a huge issue; in fact, it's a non-issue. Each carbon credit has a unique serial number that's retired only once. So, two p...↓
Like that Vera might offer a project and climate action reserve doesn't actually have a program of co-benefits, but many of their projects do have them. So, how do you define that? And then what percentage; What portion can a project actually use carbon credits? The 100% down to 10,000? If they have a million tons of greenhouse gas in one year do we expect them to purchase that much, every year?
And so, yeah, anyway, so I'm just kind of bringing up some issues around that and I'll have some other written comments later on. 
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And Steve thank you for the clarification, because actually what my recommendation, which I didn't get to, is that on the greenhouse gas assessment as far as applying like mitigation; you should only apply to scope one and scope two perhaps, for people to offset. You don't offset the products themselves, because that is indeed double counting because those greenhouse gases were used to create those products, so they're already counted for. And so somebody else buys those products. No, they shouldn't be trying to mitigate upstream and downstream, which is scope three; it's not practical. And a life cycle assessment scope three at best is a good estimate, at worst it's kind of a poor estimate. It depends on how you draw boundaries and stuff and you can provide some assurance to it, but they're not absolute, like, you do with scope one and scope two assessment. And so on the mitigation side, you can really only kind of focus on what the facility is doing, not the upstream and downstream. I think the LCAs are important as an area of judgment and to see this is really huge, this is really small; so this is kind of cool, this is bad. But you can't put a dollar or an absolute greenhouse gas value and then apply a dollar amount that someone needs to pay to offset, like a steel vector purchasing, for their products.
For instance, it's the steel manufacturer needs to be responsible for their own greenhouse gases. That is how the whole thing is set up. So, I appreciate Steve’s comments and clarification and I agree with him. I think you need to just cut out trying to mitigate upstream and downstream, but use those values those, those estimates, for sound judgment. And as sound yes or no for reasons. So, I guess that's what I want to talk about those boundaries. 
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So, as I think more about this, as far as the mitigation requirement, I would encourage you to focus on just scope one, just what the facility will be doing in a direct manner. Because the electricity, the scope two is essentially taken care of through the energy analysis work that you're conducting is part of the GAP rule as well. And so, you have that area covered and then again the LCA is an estimation tool and a good thing for information.
And then the whole thing is; my next question would be, what is being verified? Are you bringing in a 3rd party via IOS standards? So a lot of the consulting work I do is up in Canada where they actually have a pretty solid regulatory framework at a province level and at a federal level and these things, they tend to work together. And I can see the GAP rule being kind of an effective tool and effective bridge tool, that what we might get at next out of even national regulatory frameworks, which I'm hopeful for. So, get back to my initial point on the mitigations. Like, look at scope one and then consider what percentage, how much mitigation overtime? Are you going to expect an organization to be offsetting for a 20 or 50 years? Is that what they're going to be doing under this GAP rule if they are a accepted project?
I'm just trying to put some kind of boundaries around how to apply this once a project is accepted under the GAP rule and how it's going to work. 
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Comment From: Virginia Lohr

11/17/20 @ 2:30 AM
My understanding is that this is our last chance for input before the draft rules are written. I have not heard details about how you propose to calculate the greenhouse gas upstream emissions. What I do know from reviewing things and talking to scie...↓
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Comment From: Washington Public Ports Associ... (Gerry O'Keefe )

11/17/20 @ 2:30 AM
My name's Gerry O'Keefe, I am the senior director of Environmental Affairs for the Washington Public Ports Association. Our members are interested in, and supporting many of them, greenhouse gas emissions in the state broadly as well as for their loc...↓
I think my other comment would be, I have a question about how with the legislature getting ready to adopt comprehensive carbon policy designed to get to net zero on a pretty aggressive schedule; how the Department of Ecology sees this policy meshing with that policy or avoiding a duptation of that policy? And whether or not that will be reflected? The need to make sure that this rule dovetails with whatever legislation might, for a comprehensive greenhouse gas reduction strategy might put into place either in this session, or in a future legislative session.
So, I hope I've made myself clear on that; one, it's hard to play if we can't share sort of a framework to talk about. And secondly, just how the rule might to address the policy issues that will be or may be established by the legislature. 
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Comment From: Evergreen Carbon (Wolf Lichtenstein)

11/10/20 @ 7:00 AM
Okay. Hi, this is Wolf from Evergreen Carbon. I am not noticing methane in table C1 of the CFR. 40 CFR--I guess that’s the EPA list. So, methane should be included, as well as HFCs and BFCs. And sulfur hexafluoride, these are all greenhouse gasses. A...↓
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Comment From: Sierra Club (Victoria Leistman)

11/10/20 @ 7:00 AM
I’m an organizer at the Sierra Club, thank you so much for providing this space today, and for all the valuable information about the process that you're anticipating for this role making, I just have two brief comments.

One is to thank you for the no...↓

And then, I'd also just like to make a comment in response to, I believe it was the gentleman from the business association, just about some of the points in terms of defining geographic boundaries within Washington state is incredibly limited and it would totally defeat the entire purpose of evaluating for upstream emissions and this rulemaking. Fracking is not allowed in Washington State. Right? So any fracked gas projects that are coming in, that upstream emissions sources are outside Washington, so it's just a little bit of a ridiculous proposal to me and, you know, also it would be ridiculous to keep the same measurement numbers as we currently because again, my understanding is the point of the rulemaking is the current numbers has been insufficient in actually evaluating what the impact of these projects are gonna be.

So that's all I wanted to share. Thank you so much for the space and I really appreciate you all getting a wide spectrum of voice is involved so early on.
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Comment From: Sierra Club (Bill Sampson)

11/10/20 @ 7:00 AM
I live in Seattle and I volunteer with several environmental groups, including the Sierra Club. Thank you for the presentation and it was interesting to hear from different organizations and associations involved and thanks for letting the public spe...↓

I have a question about when this rulemaking would apply, I'm wondering, would there rules apply to all permitting agencies from the beginning of looking at a project, or would they only apply once Ecology has a permit decision to make?

And I'm also wondering how this project would apply if indigenous treaty rights are an issue. One of the first ways that I was involved in environmentalism was the Cherry Point coal export terminal. And I was as student at Western Washington University at that time, and attended the first scoping hearing that was on Saturday, October 27th in 2012. And then eventually, the Army Corps of engineers rejected the permit on Monday, May 9th in 2016. And so there were several years once the permitting process started and then the, the Army Corps said that the Lummi Nation’s treaty rights would be violated. And so, I'm hoping there’s gonna be a way, in the permitting process, for, you know, treaty rights issues to be dealt with first before going through a long environmental impact review process, so thank you very much. I see my time is almost up.
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Comment From: Marathon Petroleum (Miles Heller)

11/10/20 @ 7:00 AM
A couple of points and questions, I just want to put on the record, appreciate the opportunity to comment on the public process you're laying out.

One was I didn’t hear the term “major” used or defined, but I believe that was in the Governor's executi...↓

You hear a lot of talk about the upstream and downstream emissions and whether those will be outsider in the state, but I assume those discussions would then also include where those mitigations could happen, um whether mitigation could be in state or out of state. I assume that will be in an upcoming topic as well.

And then, thirdly, the Governor’s executive order mentioned, specifically, fossil fuel projects and you both used refineries as an example, and yet, as far as the speakers (inaudible) for today, there was nobody representing that industry or that viewpoint, so I just urge you to do that in an upcoming public meeting as well. And that's all I have. Thank you.
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Comment From: Don Steinke

11/10/20 @ 7:00 AM
And we keep on hearing people say, well, look at Texas, they’re far worse than Washington. Look at China. Okay. India, but we can't do anything about Texas. We can't do anything about China and India. We can do something about about (inaudible) the s...↓

And so, as Angela Merkel said in 1996, we need to--the rest of the world needs to know that we are doing our part. And we, and we need to do our part and That’s the only way we'll get other people to do theirs. The people in China said, why should we do, why should we cut our, our essential emissions when the people in America and Washington state are continuing with their luxury emissions, so we need to go to net zero or beyond as…
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Comment From: Matt Anonymous

11/10/20 @ 7:00 AM
Okay, can you hear me? Yes, sir. Okay. I just have a comment, or concern that rule 442 got thrown out in court, because indirect emissions of that rule I’d just hate to see that happened again to this rule. And just wondering, what's different? Well,...↓
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Comment From: David Anonymous

11/10/20 @ 7:00 AM
I apologize in advance for any background noise. In the beginning of the presentation, some scoping was described, and some things where not included in the scoping I think it was roads, housing, (inaudible).

Since this is not a Q&A, I would just ...↓
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Comment From: Rick Berkholtz

11/10/20 @ 7:00 AM
Okay, hi, my name is Rick Berkholtz and I am a volunteer with several environmental and social justice organizations, including Sierra Club. I just want to be sure that in this rule making process, that methane emissions are going to be tied to LNP p...↓
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Comment From: Kerry Anonymous

11/10/20 @ 7:00 AM
I'd like to see, see these rules, encourage development of sustainable projects. I think there's a lot of new technology coming down the road that can replace fossil fuels and provide good jobs at the same time and instead we're pursuing fossil fuels...↓
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Comment From: Act for Climate (Jane Lindley)

11/10/20 @ 7:00 AM
Hi, Jane Lindley here. I live on Bainbridge Island and I’m with Act for Climate, I just wanted to underscore what Amanda from Earthjustice said. I think it's important that the Department of Ecology’s new greenhouse role aid in emission reductions as...↓
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Comment From: Sierra Club (Doug Howell)

11/10/20 @ 7:00 AM
This is Doug Howell with the Sierra Club. Thank you so much for holding this meeting today. I think it's incredibly important and I applaud you in your efforts, and just to give an example of why this is so important, we have found in some of the cal...↓

But I also want to share with you another bit of analysis we had done as just an example of what this threshold could be important. We did an assessment of Puget Sound Energy’s…did a review of potential new gas plants that they were considering. The smaller ones are the peaker plants at about fifty megawatts and running at the capacity factors that they had looked at for these small plants and it was very interesting to see that a small peaker plant that they're considering investing in as a potential new investment is right around the threshold of ten thousand tons and we really would want to make sure that we're capturing these new gas plants. So, I offer as a recommendation, as a starting point, it looks is to have a very strong rationale to use a ten thousand ton threshold for your definition of major projects. Thank you so much for holding this.
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Comment From: Sierra Club (Stephanie )

11/10/20 @ 7:00 AM
This is Stephanie (last name inaudible) and I am a campaign rep. with the Sierra Club as well as being a Co-lead for Power Past Fracked Gas, and I just, first of all want to thank you very much again for providing this time for input and what have yo...↓
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Comment From: Kaiser Aluminum (Edgar Scott)

11/10/20 @ 7:00 AM
Good afternoon. Um, Kaiser Aluminum is part of a small group of what we call energy intensive trade exposed entities. We refer to ourselves as EITEs. And I want to be clear—we don't represent all the EITEs in the state. There are others. But, on beha...↓

Some things that we would like to be considered as part of the process is that…

We request the rulemaking prevent the leakage of both greenhouse gas emissions and jobs associated with EITE facilities to both other states and other countries, where the result would actually end up being in an overall increase in global greenhouse gas emissions. We don't believe anybody wants that. EITE facilities in Washington, for those that don't know our facilities that are operating for the most part in a globally based marketplace, which is extremely highly competitive. In addition, the manufacture of our products require a lot of energy, they’re energy intensive. And they represent a very high portion of the manufacturing cost. EITEs that end up being captured under carbon policy are placed therefore, at an economic disadvantage with these global competitors that aren't operating under a similar carbon policy, as these costs can't easily be passed on to our customers.

And finally, energy-intensive trade-exposed entities require flexibility in the fuels that are available to use in order to meet our production needs and a wide variety of industrial-specific compliance pathways. Thank you for the opportunity and look forward to working with everybody. 
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Comment From: bp (James Verburg)

11/10/20 @ 7:00 AM
I appreciate the opportunity to talk to everybody today. My name is Jim Verburg. I work at the Cherry Point Refinery and I help administer our GHG reporting programs for, for Washington and our federal reporting as well as some, some, some things and...↓

I commend you, Diane, Fran and Neil and Bill on this rule, making these stakeholder engagement sessions very helpful. I'm hopeful that they'll form the basis of a workable and effective rule for assessing emissions for major industrial projects under SEPA.

Although there are many potential benefits, we support this rule making for a couple of primary reasons and one ancillary one.

The first reasonis that the GAP rulemaking has the potential, a great potential to provide much needed guidance and a roadmap for SEPA lead agencies, Local, state and, and regional, for how to address GHGs for projects. I have seen--and I'm sure many on this call have seen, that are involved in permitting processes--have seen SEPA lead agencies struggle on how to do this, because of the shifting sands and then, especially as projects become, rightfully become more of a focus area for SEPA lead agencies. So did agree that this process can provide certainty in the permitting process. We, we are very excited about that opportunity.

Second, this this rule making has the potential to be a win-win. A good thing for the environment, giving our neighbors and public stakeholders confidence that GHGs from projects will not be at odds with Washington’s goals of reducing GHGs by 2050 and beyond.

And ancillarily for bp, from our perspective, this rulemaking allows with our…is aligning with our advocacy of progressive climate policies and our goal of becoming a net zero GHG company by 2050 or sooner.

Last week Friday, we submitted a comment letter and I invite everybody to take a look at that. That outlines some high level design components of what we think good GAP rule looks like. And in that letter, we state, “a successful transition to a low carbon economy will require new levels of collaboration across industry consumers, tribes, governments, aided by technology developments, and a well-designed government policy. The GAP rule and SEPA promises to play a key role in this effort. And this is no small undertaking, make no mistake. We recognize that conducting analysis of this nature can be a complex and challenging exercise. But with the right level of stakeholder and agency engagement, we are up to the challenge, in our opinion. We look forward to working together in the coming months.

Thank you, Diane. 
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Comment From: Erin Anderson

11/10/20 @ 7:00 AM
Great--two brief comments. One, I concur with the prior speaker. I think that if you’re going to go forward with a rule that is going to include upstream emissions, A, that those upstream missions need to be looked at expensively not just electricity...↓
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Comment From: David Anonymous

11/10/20 @ 7:00 AM
I’m with the organization (inaudible) in Seattle. I’m a volunteer. Our organization was involved with a pipeline project in North Seattle last year and I’m very interested in the rules that we discussed here and I really appreciate the opportunity to...↓
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Comment From: Jane Lindley

11/10/20 @ 7:00 AM
My name is Jane Lindley. I live on Bainbridge Island. I want to say that I agree with the comments from Amanda with Earthjustice, and I also have a question. If the Department of Ecologies GAP rule requires companies to report their methane emissions...↓
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Comment From: Steven Smith

11/10/20 @ 5:00 AM
Please expand on the 10,000 threshold discussed.  Is this the definition of “major”?  For an existing facility experiencing change, is a correct interpretation that there is applicability when there is an increase of 10,000 tpy?
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Comment From: Gayla Shoemake

11/05/20 @ 3:04 AM
First, mitigation should address all types of emissions: on-site; in-state- both upstream and downstream; and upstream out-of-state emissions in order to be the most effective.  

Second, one of the results from our Edmonds Taming Bigfoot Pro...↓

 Your agency can make an important contribution to greenhouse gas mitigation, by requiring the carbon costs to be included in the decision-making process, and publicizing the importance to all state agencies.  Perhaps your agency can propose that this additional cost be a required component of any cost/benefit analysis, not only for your agency, but for all Washington State purchases, beginning now.
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Comment From: Hank Landau

11/02/20 @ 2:45 PM
My suggestion is that for all large projects, the cost effectiveness should be based on two separate calculations. The first should be a standard benefit / cost analysis. The second should incorporate the costs for carbon release and carbon capture (...↓
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Comment From: Erica Shuhler

10/29/20 @ 7:35 AM
Greetings, and thank you for considering my comment. Please consider the Western Sustainability Exchange Montana Grasslands Carbon Initiative as a mitigation measure to reduce GHG emissions: https://www.westernsustainabilityexchange.org/soil-carbon
A...↓
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Comment From: Tad Anderson

10/29/20 @ 5:48 AM
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Comment From: Phillips 66 (Steven Smith)

10/29/20 @ 4:19 AM
My input was going to be around the potential for double-counting beyond WA’s borders, for both 1) counting upstream (raw material) and downstream (product) GHG emissions outside WA, and 2) mitigation for same.  There is often not good visibilit...↓
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Comment From: Tad Anderson

10/29/20 @ 2:38 AM
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Comment From: Mark Uhart

10/29/20 @ 2:30 AM
Webinar Chat Input - The mitigation should include in-state, out-of-state (which includes out-of-country) for on-site, upstream and downstream GHG emissions. Al types of emissions should be considered. Upstream GHG emissions should include the most r...↓

Webinar Chat Input - There must be effective governance in place for tracking and verifying emissions. Governance includes the governing (authority, standards, policies, procedures), risk management and methods of compliance. Methods of compliance is where governance usually fails. 

Webinar Chat Input - I don't think biomass energy projects should be allowed as a means of mitigation, nor any mitigation project that doesn't immediately result in a net reduction in GHGs. I would assume there are international safeguards to ensure a mitigation project is not applied against multiple project plans, when the GHGs from the sum of the projects exceeds the GHG reductions associated with the mitigation project. 

Webinar Chat Input - I also believe there should be any allowance for fossil fuel GHG displacement options, that a "cleaner" fossil fuel project can displace a "dirtier" fossil fuel project. Regardless of the source, we need to reduce consumption of fossil and biomass fuels. Cutting down a forest to burn the wood chips as a fuel, as a cleaner fuel, still releases CO2. 
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Comment From: Earthjustice (Amanda Goodin)

10/29/20 @ 2:30 AM
Thank you, as Diane mentioned my name's Amanda Goodin and I'm an attorney with Earthjustice. We appreciate the opportunity to provide comments today. Mitigation is one of the most critical components of the GAP rule. And that's because if we are goin...↓
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Comment From: Association of Washington Busi... (Peter Godlewski)

10/29/20 @ 2:30 AM
I do appreciate the opportunity to provide comment and appreciate all the word that Ecology staff has done in order to help bring some clarity to the rule with these webinars, it is appreciated by our members. As a brief introduction, Peter Godlewski...↓
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Comment From: Tad Anderson

10/29/20 @ 2:30 AM
My name is Tad Anderson. I am a retired Atmosphere Scientist from the University of Washington with expertise in climate forcing. Over the last few months I have attempted to familiarize myself with the current literature on climate forcing by methan...↓
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Comment From: Briggs Robert

10/28/20 @ 8:28 AM
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Comment From: Western States Petroleum Assoc... (Tiffany Roberts)

10/16/20 @ 5:48 AM
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Comment From: Earthjustice (Amanda Goodin)

10/13/20 @ 9:21 PM
Please see attached Comments on Chapter 173-445 WAC, Greenhouse Gas Assessment for Projects (GAP) Rule submitted by Earthjustice, Friends of the San Juans, Sierra Club, Stand.earth, Washington Environmental Council/Washington Conservation Voters, Col...↓
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Comment From: Department of Archaeology & Hi... (Greg Griffith)

10/09/20 @ 4:43 AM
On behalf of the Department of Archeology and Historic Preservation (DAHP), we want to put on the table greater recognition that historic preservation plays in minimizing greenhouse gas emissions. We advocate for recycling/rehabilitating existing/his...↓

We also note that while new construction may well incorporate energy saving designs and systems, what is overlooked is the significantly greater energy expenditures needed to extract, transport, process, and manufacture materials (often with negative impacts to environmental quality) used to assemble and construct new buildings.

In the updated State Historic Preservation Plan for 2021-26, DAHP has included a task to get a better idea of the energy investments in existing/historic buildings and the energy investment/greenhouse gas emissions that would be needed to replace a prototypical building with new construction. The goal of this task is to quantify what is lost by demolition and what additional costs are incurred by new replacement construction even when using green building standards. We would invite Dept. of Ecology to join with DAHP and the historic preservation community in helping to implement this task.

Thank you for the opportunity to provide these comments.
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Comment From: bp (James Verburg)

9/22/20 @ 10:23 PM
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Comment From: James Graves

9/04/20 @ 2:29 AM
I’m hoping that someone can shed light on the following general question about applicability of the rule:

I’m clear on these two points:

If facility emissions are equal to or greater than 10,000 metric tons of CO2e per year, the GAP Rule applies to the...↓
If a project’s facility GHG emissions are less than 10,000 metric tons of CO2e, then consider inputs and outputs to the project.

But with respect to this point:

If a single input or output, or a combination of multiple inputs or outputs, are > 10,000 metric tons of CO2e, the GAP Rule applies to the project and the greenhouse gas assessment described in the rule must be done

The plain language suggests that this input/output analysis is a separate analysis and comparison to 10,000 MT CO2e – separate from, and not additive to, the analysis regarding facility emissions.  Is that correct?  Or are the input/output numbers added to facility emissions numbers and then compared to 10,000?

E.g., Let’s say a project would have facility emissions of 9,000.  Do you start at 9,000 or 0 when counting GHGs from inputs and outputs? 

Lastly, to what extent will Ecology have discretion, project by project, in discerning the appropriate scope of inputs/outputs to consider – versus the criteria for identifying inputs/outputs being clearly set in the regulation?
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Comment From: Tad Anderson

9/03/20 @ 3:25 AM
Thank you for offering to help me gain access to these documents, despite the fact that they are copyrighted.  I write to explain why I no longer require that access and to provide additional comments on the ISO standards.

 As it turns out, ...↓

 Based on that information, I have determined that the ISO documents do not provide answers to my specific questions about methane leakage.  This appears to be a general feature of ISO documents - they describe a methodology for producing credible and transparent assessments of environmental impacts, but they do not specify what values of measurable quantities (like methane leakage rate) ought to be used in those assessments.

 The ISO 14040/44 documents provide a general framework for Life Cycle Analysis, with illustrative examples that involve Greenhouse Gas (GHG) emissions.  However, ISO provides much more detailed guidance on GHG reporting methodology in other documents (the "14060 family").  Therefore, these are likely relevant to the GAP rulemaking process as well.  I have perused the publicly available portions of these documents and very much agree with the goals and approach found therein.  For example, the Introduction to ISO 14064-1:2018 (available at https://www.iso.org/standard/66453.html) states, "Specifically, the use of the ISO 14060 family [along with other goals]: enhances the credibility, consistency and transparency of GHG quantification, monitoring, reporting, verification and validation."  That captures very well my own hopes for the GAP rulemaking process regarding the specific issue of methane leakage.

 
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Comment From: Tad Anderson

8/29/20 @ 5:09 AM
Thanks for your reply and your efforts to get me access to the ISO 14040/44 documents.

It’s an interesting dilemma: The Dept of Ecology is developing rules based on copyrighted documents that the agency cannot readily share with the public. That's an ...↓

Actually, though, I don't need access to the entire documents. All I'm after is a thorough understanding of how the issue of methane leakage is dealt with in estimating the life cycle GHG emissions for facilities and projects that use natural gas.

So if your agency could provide me just those portions of the documents that involve methane leakage (surely a tiny fraction of the total) that would satisfy my needs.

Specifically, I am looking for answers to these questions:

1. For a given amount of natural gas used in or produced by a project (as chemical feedstock, energy source, or deliverable commodity), what amount of methane is assumed to have leaked into the atmosphere during the extraction and delivery of that methane to the project? Let's call this the Leakage Rate (LR) with units of kg_methane_leaked per kg_methane_consumed.

2. How is this Leakage Rate (LR) determined and updated over time? That is, (a) what research articles and/or reports are relied upon? (b) does the value chosen represent a best-guess estimate of LR or the upper limit of the uncertainty range (and, if the latter, what confidence level)? and (c) what provisions exist for updating the value of LR as both industrial practices change and better leakage measurements become available?

3. Do the ISO documents use a single value of LR (as implied in question 2, above), or are multiple values of LR used, depending upon the source of natural gas and/or other factors?

I can work out the answers to these questions myself if you provide me with the relevant content from the ISO documents. Alternatively, if your staff can provide me direct answers to the above questions, that would also satisfy my needs.

I hope this clarifies (and perhaps simplifies) my request.

I’m cc’ing a few others with whom I’ve been in contact regarding the methane leakage issue, since they will perhaps be interested in your response as well.
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Comment From: Tad Anderson

8/27/20 @ 5:36 AM
Thanks for a good webinar this morning and for helping me participate. Regarding Life Cycle Analysis, Ecology proposes to rely heavily on ISO 14040 and ISO 14044. I would like access to these documents. I can Google those words and I get a blizz...↓
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Comment From: Stockholm Environment Institut... (Pete Erickson)

8/27/20 @ 5:01 AM
It’s been awhile since we’ve connected, but I’ve been following along on the GAP for Projects rulemaking. You did a really terrific job laying out a general approach this morning.  As you pointed out, the market analysis component is potentially...↓

One point I’d like to add is about your characterization of this as time and resource intensive. At SEI, we have done quite a bit of work over the last few years trying to demystify these types of market analyses (E.g. here, here, and here.)

A big conclusion is that simpler approaches are possible. Further, the Governor’s motivation of holding warming to 1.5 degrees C could help provide some clear metrics. If it would be helpful, I’d be happy to discuss our analysis and the possible implications for the work you’re doing on the rulemaking.
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Comment From: Westbrook Associates LLC (Patrick Binns)

8/27/20 @ 2:30 AM
Webinar Chat - For carbon sequestration assessments, will you use the weight equivalency factor of 3.67 tons of CO2 sequestered for 1 ton of Carbon? 
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Comment From: WA Physicians for Social Respo... (Max Savishinsky)

8/27/20 @ 2:30 AM
We feel that this rule should help us determine--is this project part of a low carbon future? And that for sound evaluation, we need to align these rules with our emission reduction targets and that every environmental analysis for major fossil fuel ...↓
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Comment From: Earthjustice (Amanda Goodin)

8/27/20 @ 2:30 AM
Good morning. And I'd like to thank the Department of Ecology again for the opportunity to participate and this development of this critical role. There are a few issues relevant to methodology and the environmental assessment methodology that I'd li...↓

The first and most important issue I'd like to address is a climate test. On major fossil fuel and industrial projects, every environmental analysis must include a climate test. In the broadest sense, this climate test should help decision makers answer the question--is this project a part of a low carbon future? To answer that question, the analysis must look at lifecycle greenhouse gas emissions in context. There are at least three different frameworks that must be part of this content.

First, the climate task has to include greenhouse gas emission reduction targets, based in both law and science. Looking at a project submissions against the baseline of emissions today is not enough. We need to judge a project’s emissions against the baseline of the major reductions we need in decades to come.

As the second part of this climate test, the environmental analysis must also compare the proposed project, (to?) the lifecycle greenhouse gas emissions, or alternative products or processes that serve the same broad purpose. This must include both established and emerging products and technology. This will help show whether a given project is truly the greenest of it's kind or whether it is locking in dirty technology.

Finally, the climate test must require an analysis of how the project then to projections for a deeply de-carbonized economy. Before we come to new infrastructure that will be with us for decades, we need to understand what trade-offs we are committing to if those emissions continue. We also need this information to understand the risk that the project will lead to stranded assets.

Requiring a robust climate test, as part of every environmental analysis for major fossil fuel and industrial projects is critical. We can't make good decisions unless we know whether a project is consistent with the low carbon economy we must build.

I also want to briefly touch on the question of gross emissions versus net emissions that the Department of Ecology raised earlier. We've seen a lot of net emission analyses that have been speculative and incomplete at best. These analyses often rely on claims that a product will allegedly displace a dirtier alternative. But there's no way to reliably predict whether a given product will displace a dirtier product or whether it will displace a cleaner one.

There's also no way to reliably predict whether a new product will displace another source or whether it will simply be additive. Gross lifecycle emissions can be calculated with a high degree of certainty. Net emissions can't be. We can't rely on half-baked analysis to justify major, new polluting product. Thank you. Again for the chance to provide input today.
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Comment From: Northwest Gas Association (Dan Kirschner)

8/27/20 @ 2:30 AM
Yeah, hi, this is Dan Kirshner. I’m the executive director of the Northwest Gas Association. I think it's important to note that I don't represent, as you noted introduction, this broader group, that a very specific part of the group, and that is the...↓

So, thank you for the opportunity. I think it's really important to, as Ecology moves down this pathway, the GAP rulemaking moves down this pathway, that one principle it includes is in any environmental assessment, especially the lifecycle analyses that the metrics they’re using are used consistently and sourced from credible sources. And in this case, I would suggest a credible source is a government agency that has charge for regulatory oversight over the, the issues at hand.

So, I'm speaking and thinking, particularly of upstream emissions from, from perhaps natural gas production and the like, and as an example of a credible source that I would call a, a government agency would be, for instance, in the US, the EPA inventory of greenhouse gas emissions. And (inaudible), Canada's version of the same if to go outside of Washington state boundaries in that regard.

So they also need to be consistently applied. And, I mean, that regard, I'd say if you're gonna do a lifecycle analysis of any fuel that you that a life cycle analysis should be done for all fuels involved in in the project. So, as you're thinking about, it’s very easy to do a life cycle analysis for natural gas, for instance, but perhaps renewable energies are also are not a zero carbon, fuel lifecycle wise.

They are zero carbon at the point of generation, but they're not zero carbon overall and so consistent application of the life cycle analysis be very important part of this process.

I would also say, I appreciate the fact that the governor's executive order requires or calls for providing a twenty year and a hundred year assessment of global warming potential. Our hope would be that that assessment is provided without value or direction--just simply provided as an input to the process and something to consider and compare, but that when comparisons are made, they're made appropriately.

And I especially appreciate, Bill, your calling out the, AR5, comments AR5 of the IPCC about it being a value judgment which direction you go in the in the use of those.

I think it's also important to understand as you're conducting lifecycle analysis, that any lifecycle analysis can't really be generalize broadly. It really, in the Northwest, we have distinctives here in the Northwest and that's particularly true of the natural gas delivery systems as well, as natural gas production, where we receive about 70% of our supply in the Northwest comes from British Columbia, which has probably the most robust regulatory construct around natural gas production in North America. And so it's 
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