Thank you for the opportunity to comment. I appreciate it.
We have specific comments to offer and we'll submit our comments in more detail to the department in writing. As a public port districts we’re a local government in the state of Washington tha...↓
In our view, the rule should broadly recognize that greenhouse gas emissions are indistinguishable by the source of emissions. All emissions contribute to climate change identically and are, in fact, identical to each other, regardless of the source.
Furthermore, the rule should establish a threshold of emissions beyond which, below which, actions direct and indirect emissions of greenhouse gases will not be significant adverse impacts.
When the total of emissions is exceeded, the rule should establish lead agency methodology they can use to evaluate whether these emissions are significant.
The rule should provide guidance to lead agencies for determining the circumstances in which it's appropriate to issue a DNS or MDNS, as a basis of the direct and indirect, on the basis of the indirect impacts of an action.
The rule should require lead agencies to consider the same scope and context the lead agency uses to quantify the inventory of indirect emissions, such as the significance of global life-cycle emissions that they’re evaluated in the context of global carbon emissions and the significance of emissions that occur within Washington State are evaluated in the context of total greenhouse gas emissions that occur within the boundaries of the state.
We believe the rule should acknowledge that the existence of significant cumulative impacts caused by other sources of greenhouse gas emissions does not constitute substantial evidence that the proposed actions contribute, contribution to global emissions are cumulatively significant.
The rule should provide direction to lead agencies to evaluate market substitution or displacement effects when assessing the significance of the full impacts of an action.
The rule should provide guidance to lean agencies for addressing greenhouse gas reduction targets in chapter 70.235 for new source emissions. Targets should accommodate and encourage new technology intended to substitute for or replace existing technologies that achieve the same production goals with fewer greenhouse gas emissions.
The rule should establish a framework for lead agencies to use a calculated inventory of direct and indirect emissions recently attributed to an action. We'll provide more details about what should be included in our written comments.
If the rule requires consideration of global lifecycle emissions in any fashion, it should also establish a threshold of direct emissions attributable to an action below which the lead agency may not consider global lifecycle emissions associated with that action.
The rule should establish a methodology by which a lead agency must identify reasonable mitigation measures when they determine conditions are necessary to mitigate greenhouse gases of an action pursuant to RCW.43.21C.060. We'll provide more detail about what should be included in this methodology in our written comments.
The rule should establish a methodology which a lead agency may address impacts of climate change on a proposed action through resiliency and adaptation planning, including, but not limited to site design and other measures to address sea level rise and increased risks of severe storm events and wildfire.
To support the implementation of this rule, we believe it is important for the department to develop and maintain inventories of and anticipated trends for emissions for categories of industries and activities, including transportation activities, and how inventories and trends may be used in project and non-project environmental review. Inventory should use the same scope and context for emissions as a required rule adopted to this chapter for lead agencies when quantifying inventory of indirect emissions. The Department of Ecology shall update its reports; we would like that report updated every three years.
At the, at the end of the day, for us we deal with a lot of different kinds of projects. We're aware that there are projects in folks’ recent experience that have raised concerns, but (inaudible) this question being asked (inaudible) Washington Public Ports Association, it's much broader than a narrow focus on emissions, from carbon (inaudible), the same questions about threshold, (inaudible) exist for any project that would like to proceed within the state of Washington, the same uncertainties in the appeal process exist for any project that would proceed within the State of Washington. And we think it the rule should rightly address those issues as it proceeds.
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