Greenhouse Gas Assessment for Projects Rulemaking CR-101

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Comment From: Washington Physicians for Soci... (Max Savishinsky)

8/27/20 @ 2:30 AM
Thank you for making time for public comment today. Appreciate it very much. My name's Max Savishinsky of Washington Physicians for Social Responsibility we are a membership organization here in Washington State made up of healthcare professionals ac...↓

As everyone knows climate change is a major health crisis, and it's critical to ensure responsible and accurate measurement and mitigation of emissions in order to protect health and the environment. And our members recognize this fact, it's inescapable. And this process holds huge health implications. And so it's very important that it be done, quote unquote, correctly, but with health at the forefront of the considerations being made.

The health professional members of Washington Physicians for Social Responsibility want to see every proposed possible fuel project tested against our goals of a low carbon future. In other words, utilizing us for climate test for projects like this, with the widespread understanding of the importance of taking bold, but also responsible action to protect the climate and to protect people's health from the harms posed by fossil fuel emissions and pollution.

So, you know, our on behalf of our organization, 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 projects should include a detailed climate test.

Plain and simple, we really cannot afford to lock ourselves into dirty technologies. Environmental analyse smust compare the proposal to other technologies, both existing and those that are emerging, that would achieve the same purpose.

We know very well--I think everybody here knows, that business as usual and timid or incremental steps forward are not enough to protect the environment and to protect health. There's a clear and really present urgency for fossil fuel projects to be evaluated, based not only against the baseline for emissions today, but against the baseline of major reductions that are urgently needed in the coming decades.

Thank you for taking my comments.
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Comment From: Marathon Petroleum (Miles Heller)

8/27/20 @ 2:30 AM
I know that you're not answering questions today. So, Bill, I would just request that in the next workshop that you come back and provide an example of what's meant by the gross and net analyses, that would be really helpful. And a related question—t...↓
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Comment From: Christina Anonymous

8/27/20 @ 2:30 AM
Hi, I'm a physician and I was raised by other physicians. I've been around healthcare my whole life, and I've seen plenty of patients suffering from the health consequences of climate, change heat stroke, fire, smoke inhalation, water scarcity, starv...↓

From all the consequences that are physical effects of climate change, the mental health repercussions are significant. Many of my close friends and many patients suffer from anxiety, depression, PTSD. They feel immense fear and hopelessness related to climate change. I have a friend who can barely function and day to day life because he's constantly contemplating what feels like a very stark future.

Health systems themselves are suffering from consequences of climate change. And if we don't make changes, this will further overwhelm and destroy healthcare systems.

In order to protect our people and planet. We cannot rely on speculative displacement theories. (There) is no way to reliably predict whether a given product will displace a dirtier or product or a cleaner one.

We must consider the real growth emissions (of these) proposals in order to understand their impact. That any SEPA process measuring the impact of greenhouse gas emissions must account for the total gross admissions. Not (inaudible) net emissions that are based on conjecture.
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Comment From: Washington Public Ports Associ... (Gerry O'Keefe)

8/27/20 @ 2:30 AM
It's good to participate in this today. I appreciate it from the perspective of the Washington public ports Association. We recognize it's a serious issue. It’s certainly an issue that our members’ communities expect them to pay attention to and act ...↓

Yes, just a quick survey of what ports do--many of our ports are very involved in reducing emissions from their facilities and helping their customers, their clients, lessees, and people who use their facilities also reduce emissions in a broader sense. So we recognize there's a broader perspective here, or a broader responsibility, I should say to deal with climate issues.

I did note some of that some of so, from our perspective, a lot of our engagement with this is sort of a  practical thing. As lead agencies, what's required of us? And I think that it was, I guess one of the things that stood out to me today, in Bill Drumheller’s presentation, which I appreciated and learned a lot from. But the statement that the analysis is circular is something that is problematic for folks who are in the process of trying to develop an EIS under SEPA. I think, what would be most helpful in addition to have some clarity about issues is really clear guidelines from the Department of that say, “you need to do this and then that's enough.” So, it's a very clear sort of bright line on the agencies part to eliminate uncertainty for the lead agencies and project proponents.

You've heard me say previously that from our point of view greenhouse gas is a greenhouse gas is a greenhouse gas, regardless of whether  that’s a large industrial facility or another action or facility that emits greenhouse gases, they all emit greenhouse gases. And if you are a lead agency or project proponent for and need are required to do a SEPA analysis, you need to have some sense of what significant emission and what to do about it. Some of that, we're starting to talk about here in terms of calculation.

And and I think, maybe just one broad, broad comment. There is an inter-relationship between--in a large sense--our economy, our communities, and our environment and that, that triangle is the core of what sustainability is. And wise, public policy tries to balance those things and, you know. There are elements of what we're talking about here that require a thoughtful engagement and balancing of interest and it's not from our view, from the point of view of Washington Public Ports, it's not this part of the community against that part of the community. It's a very thoughtful deliberative of conversation about how to protect our interest in our community. Our health interest and our other community interests are obvious environmental interests and the competitive--competitiveness of our economy, which arguably is a foundation of being able to achieve our community and environmental goals. So, and that's the challenge before the State of Washington. It also happens to be the challenge before the United States of America and more broadly the world, as we take on this problem that we gotta take on.

So, thank you for the presentation today. I'm learning from other comments here I look forward to and hope very much to talk with some of the other people who are involved in this process about how we can work together to shape a rule that meets broad needs. So thank you very much for the chance to to present.
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Comment From: Sierra Club (Victoria Leistman)

8/27/20 @ 2:30 AM
Hi there. Yeah, my name is Victoria Leistman and I’m an organizer with the Sierra Club. Thank you all so much for the presentation today and forgiving us the opportunity to make some comments.

I just wanted to respond directly to the gentleman who spo...↓
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Comment From: Tad Anderson

8/27/20 @ 2:30 AM
Oh, great. So I'm tad Anderson. I'm a retired climate scientists. And I'm for the most part, trying to come up to speed on this issue as we go through this process. I grateful that it's so open, transparent, and that it stretches out over a long enou...↓

So, I would urge the discussion on this to be centered around a simple equation that I've provided to Ecology, which calculates the effect of methane leakage--in terms of a leak rate, and a global warming potential--on the increase in carbon effective carbon emissions that you get from methane leakage adding to the entire carbon footprint of using or burning natural gas. There is a very simple way to look at that. And if you put if you plug in leak rates of one percent, and the global warming potential associated with a hundred year timeframe, you've got a pretty small effect about a ten percent increase in net carbon emissions.

If you put in a leak rate of five percent--or I should say, even lower than that maybe three point eight percent--and look at twenty year timeframe, you get an increase in effective carbon emissions of over one hundred percent, which makes natural gas worse than burning coal.

So, it's really important for us to have some process, or some methodology, or some principles for how we adjudicate this basically scientific controversy, so I would urge the rulemaking process to think about that. And, and in particular, to consider, are we going to be stipulating a kind of a best guess methane leakage rate or a 95% confidence methane leakage rate.

In other words, we can try to set it that leakage rate at a level where we have high confidence—say 95% confidence—that the actual leak rate is not greater than the one that's being specified.

So, that's basically my comment if I go through the IPCC greenhouse gas guidelines and just use their tier one, a numbers for all of the different processes associated with natural gas and add all those up in terms of a leakage rate for using kind of clean assumptions for how the natural gas delivery system is set up and using a best guess, I get a little under a one percent net leakage rate. But if I put in that sort of dirtier assumptions that are in the in the IPCC guidelines and use a 95% confidence threshold, I get over a 3% net leakage rate.

So, the truth is somewhere, it may be greater than that 95% confidence number because these things are being, re-analyzed all the time. But some kind of process, I think would be good to have in writing about how we're going to adjudicate this and whether we're gonna go for a best guess, or a 95% confidence number in the ultimate rules. Thank you.
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Comment From: Vashon Climate Action Group (Virginia Lohr)

8/27/20 @ 2:30 AM
I’m Virginia Lohr, with the Vashon Climate Action Group. I support the comments of Amanda Goodin with Earthjustice about a robust climate test. it's important that the rules developed as a result of this rulemaking that you're working on right now pu...↓
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Comment From: Phillips 66 (Steven Smith)

8/27/20 @ 2:30 AM
Thank you. Steven Smith from Philips 66. First, thank you for this webinar and I think the much more detailed discussion of the process about assessment, and particularly lifecycle assessment.

I wanted to maybe echo an earlier comment made by another ...↓

And an example, something, and I'll just give you one that pops to head. Let's say, an example of something like a vehicle manufacturer in a global economy, where half of the vehicle’s components are produced in Mexico, and the balance of the vehicle components in final assembly is in Washington state.

And then of that vehicle half the vehicles were sent and used in Washington and the other half were sent and used, let’s say, overseas. And so there, I think, mitigation questions come to mind, so I just might suggest that, I think that could further this conversation along quicker.

And maybe, maybe very productively to think about pros and cons in different lifecycles assessments in real world situations like that. Thank you.

 
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Comment From: Westbrook Associates LLC (Patrick Binns)

8/27/20 @ 2:30 AM
Hello I’m Patrick Binze from Seattle. Two comments I wanted to make one is in assessing emission alternatives, particularly with renewable energy sources, I think it's imperative that the department use credible, peer reviewed data regarding emerging...↓

Another point I'd like to make is that in looking at the carbon sequestration process of some of these different fuels’ production schemes, it would be important that when carbon is sequestered, that it is given basically, it's a three point seven, roughly factor value carbon dioxide equivalency rate since carbon put stable in the ground has is actually taking out three point seven tons of CO2 in the atmosphere.

But I think it's very important again to get substantially peer reviewed, credible data on the basis of your assessments of alternatives. That's basically my comments right now. Thank you for the opportunity to speak. 
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Comment From: Northwest Clean Air Agency (Agata McIntyre)

8/25/20 @ 11:36 AM
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Comment From: bp (James Verburg)

8/25/20 @ 4:31 AM
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Comment From: Tad Anderson

8/15/20 @ 2:51 AM
As a retired scientist, I'm trying to contribute my expertise to the GAP process,  focusing on the issue of methane leakage.  I've prepared a little primer on that topic (attached) which I'm hoping will facilitate communication among all pa...↓

 Assuming natural gas is pure methane, the relation is extremely simple:

   LE = LR * GWP / 2.75 

where LE (Leak Effect) is the relative increase in effective carbon emissions (%) associated with burning natural gas for energy, and 2.75 is the ratio of CO2 to CH4 molecular weights.  

 It seems to me this would be a useful formula to share with all participants.  The derivation is pretty trivial (see attached).  This formula provides an easy way to show how the impact of methane leakage ranges from small (~10%) to dramatic (>100% - i.e. making natural gas worse than coal), depending on what values are chosen for the two key parameters, LR and GWP.  That, in turn, sets the stage for discussing what values of LR and GWP are appropriate in Washington State policy.

 Here's my question:  Would Ecology be willing to incorporate this simple formulation in your own presentations?  (I could present it, but I think it would be more powerful and useful coming from Ecology.  By the way, I don't consider any of this original or proprietary.  Feel free to adapt and use it, with or without attribution to me.  It's all based on the work of others and "public domain" as far as I'm concerned!)

 PS  I'm also reaching out to active methane researchers to be able to consult with them as questions arise during the rulemaking process.  In that regard,  I've had a brief exchange with Alexander Turner, lead author of a recent perspective on methane in PNAS[1].  Alex has just been hired by UW and will be coming to Seattle in January.   He gave his blessing to the above simple formula as a good first approximation.

[1] Turner, A. J, Frankenberg, C. and Kort, E. A. (2019): Interpreting contemporary trends in atmospheric methane, Proc. Natl. Acad. Sci.,116, 2805-2813.
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Comment From: bp (Tom Wolf)

8/07/20 @ 4:34 AM
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Comment From: Tad Anderson

7/23/20 @ 7:35 AM
Will this GAP rulemaking include establishing a number for methane leakage as called for under HB 1597 (which did not pass this session)?  If so, when will that be discussed and how can I participate in those discussions?
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Comment From: Vashon Climate Action Group (Virginia Lohr)

7/23/20 @ 7:00 AM
Webinar Chat - I appreciate the length of time being provided for public comment during these webinars.  I wonder if limiting comments to 2 minutes is an option that you should use only when the number of people who wish to speak is larger than ...↓
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Comment From: Washington Public Ports Associ... (Gerry O'Keefe)

7/23/20 @ 7:00 AM
Thank you. I appreciate it. It's good to be here again today it's something this, this rule is an issue that the Washington Public Ports Association and our members care a great deal about. I think my comment is that it's not clear why we would regul...↓
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Comment From: Jennifer Seely

7/23/20 @ 7:00 AM
Webinar Chat - Is there any way to rewind the chat or watch a recording, in order to see the prior comments? Or will there be a record of the comments made orally during this event?
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Comment From: Matt Hamilton

7/23/20 @ 7:00 AM
Webinar Chat - Maybe you could cover in the next meeting, the timeline.  slide 8, would not apply as of date passed or implemented.
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Comment From: bp (Ken Taylor)

7/23/20 @ 7:00 AM
GHG seems to be the focus, but the scope of GHG is unclear - how far upstream and how far downstream will be considered? And, do WA state actually have the authority to regulate those calculated emissions?
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Comment From: bp (James Verburg)

7/23/20 @ 7:00 AM
I understand the idea around the 10k MT CO2e per year deminimis as a screen for when a GAP rule GHG assessment is required, however I'm looking forward to more detail on calculation methodologies.
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Comment From: bp (James Verburg)

7/23/20 @ 7:00 AM
The first two webinars are very good in terms of informing stakeholders on the basics surrounding the rulemaking. I'm looking forward to more detailed discussions on calculation methodologies particularly for upstream and downstream emissions.
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Comment From: AQP Enterprises, LLC (Alan Newman)

7/23/20 @ 7:00 AM
Discussions by Ecology are too general and not useful in determining what types of projects Ecology is considering as major industrial or energy facilities.
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Comment From: Washington Public Ports Associ... (Gerry O'Keefe)

7/23/20 @ 7:00 AM
It isn't clear why Ecology would propose a rule that covers limited project types. All GHG emissions have the same effect, regardless pf source.
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Comment From: Marathon Petroleum (Miles Heller)

7/23/20 @ 7:00 AM
Webinar Poll Response - If the purpose is simply to respond to the governor's executive order I think that is clear. the terms in the order are not all clear.

Webinar Poll Response - Need materials more in advance of workshops and need industry specif...↓

Webinar Poll Response - There are many additional details needed.
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Comment From: Sara Leverette

7/23/20 @ 7:00 AM
Webinar Poll Response - Selective regulation of limited industry groups does not appear to implement the purpose of SEPA nor has it been demonstrated to effectively evaluate all major sources of the state's GHG emissions.
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Comment From: Graham VanderSchelden

7/23/20 @ 7:00 AM
Webinar Poll Response - It is unclear to me whether a project that does directly related to production/distribution/use of fossil fuels but that has the potential to emit greater than 10,000 tpy of GHGs would be subject to the GAP rule.
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Comment From: Cascadia Law Group (Dennis McLerran)

7/23/20 @ 7:00 AM
Webinar Poll Response - While it is clear what the threshold for the GAP Rule will be, it is unclear what the SEPA evaluation will be for smaller projects as SEPA review will still be required.
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Comment From: City of Chelan Public Utilitie... (Shaun Seaman)

7/23/20 @ 7:00 AM
Webinar Poll Responses - I feel more informed now but going into this webinar I wasn't really clear what an industrial facility would be defined as and there wasn't good information on the web site to help me understand what would be covered and how ...↓
I think there was an assumption that the underlying purpose and terms used by Ecology were widely understood, but I don;t think they are.
I think it is clearer but more examples of what is covered and not would be helpful - especially what an industrial project is.
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Comment From: Environmental Science Associat... (Pam Xander)

7/23/20 @ 7:00 AM
Webinar Poll Responses - It is not fully explained as to why the GAP rule only applies to industrial and fossil fuels. I realize the Gov. only asked for these industries but that only accounts for about 10% of emissions. What about the other emission...↓
It's not clear why it only looks at this small bit of emissions? Will you do follow up rules for other industries? That is the biggest clarification needed. I don't agree that focusing on the largest projects will create the decrease in GHG that the state needs. If the state doesn't want fossil fuel projects, the Governor should just state that and not go through this exercise that will have such minimal impacts to reducing GHG emissions.
Really a mystery about why the Rule is targeting fossil fuel and industrial. It is because they are the most controversial? I think it should be made clear why these industries are being singled out and what will be done about the majority of emissions that come from other activities. If Ecology truly wants to reduce GHG emissions across the state, the Rule should apply to all activities that cumulatively release GHG emissions.
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Comment From: Olympic Pipe Line Company, LLC (Alexandria Crooks)

7/23/20 @ 7:00 AM
Webinar Poll Response - Requiring clarification; what are the thresholds for rule applicability? 10,000 metric tons of CO2?
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Comment From: Philips 66 (Steven Smith)

7/23/20 @ 7:00 AM
Webinar Poll Response - Wants to see an example in the next webinar "...that would encompass both assessment and mitigation."
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Comment From: Port of Longview (Chris Wills)

7/23/20 @ 7:00 AM
Webinar Poll Response - The intention appears to be aimed at reducing GHG w/in Washington State but it seems the rule has been crafted already based on last months presentation and this months. Maybe I am misunderstanding where the parameters of revi...↓
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Comment From: Shell (Tim Figgie)

7/23/20 @ 7:00 AM
Webinar Poll Response - Not sure what additional GHG assessment would look like if the project did not meet the GAP criteria. I thought the GAP was to address the GHG aspect. Not clear on how to determine input and output impacts.
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Comment From: Steve Rybolt

7/23/20 @ 7:00 AM
Webinar Poll Response - It was stated that the GAP rule would apply (or start with) to those that are currently required to report under the GHG reporting requirements. It is also stated that a lead agency has the option to consider the GAP rule once...↓
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Comment From: Jane Lindley

7/23/20 @ 7:00 AM
Webinar Poll Response - Surprised to hear you'll be using the existing system for the screening process - does CETA require any changes with regard to emission levels?
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Comment From: Stephanie Meyn

7/23/20 @ 7:00 AM
Webinar Poll Response - I'm not sure I see the relationship between a facility with 10K metric tons "stack" emissions and how that relates to the emissions associated with feedstocks/lifecycle that are also covered by this rule. Couldn't a project ha...↓
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Comment From: Erin Anderson

7/23/20 @ 7:00 AM
Webinar Poll Response - Presentation is not clear about 'products of' the facility or industrial process. Gasoline alone does not adequately describe what is and what is not included in the 'outputs'.

Webinar Poll Response - If the purpose is to elimi...↓
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Comment From: Michael Brygger

7/23/20 @ 7:00 AM
Webinar Poll Response - Is it to limit any increase in GHG in WA? or goal to reduce GHG by a certian amout to meet a target by a certain date?

Webinar Poll Response - A lot of rule development is happening behind closed doors, with unknown inputs.
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Comment From: Jacob Lipson

7/23/20 @ 7:00 AM
Webinar Poll Response - Has Ecology contemplated whether a project proponent whose emissions do not exceed the 10K threshold will be able to 'opt in' to following the GAP rule's methodology for purposes of SEPA compliance? Or is the plan to make the ...↓
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Comment From: Matt Hamilton

7/23/20 @ 7:00 AM
My concern is with the indirect emissions. The rule 442 got thrown out of court because that, and it went to the Supreme Court and made it out minus the indirect emissions part of that rule. I could see it happening again with this one—I don’t see, y...↓
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Comment From: Vashon Climate Action Group (Virginia Lohr)

7/22/20 @ 7:00 PM
I’m with Vashon Climate Action Group and I want to say that I strongly support the comments that were made by the woman from Earthjustice. The idea of not setting a set value for methane leakage without allowing new science to change it, I think is e...↓
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Comment From: WA Environmental Council (Rebecca Conden)

7/22/20 @ 7:00 PM
My name's Rebecca Conden—I’m with the Washington Environmental Council of (inaudible). I totally support the points that Amanda made. You know, Ecology is evaluating and recognizing that it's important to understand the full scope of greenhouse gas ...↓
(inaudible)
(inaudible)…the rest of it.
That’s my comment for today, thank you.
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Comment From: Vashon Climate Action Group (Rob Riggs)

7/22/20 @ 7:00 PM
Yes, this is Rob Riggs—I’m a volunteer with Vashon Climate Action Group. I've done a quick analysis here that suggests that the 10,000 ton limit would be that a 50 megawatt peaker plant with a capacity factor of 5% would be required to comply with th...↓
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Comment From: Sierra Club (Stephanie Hillman)

7/22/20 @ 7:00 PM
Super, thank you. Yeah, this is Stephanie Hillman and I’m with the Sierra Club and also co-lead of the Power Past Fracked Gas coalition. Thank you very much for this opportunity to make a comment. You know, our coalition is dealing with a couple of p...↓
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Comment From: Resources for Sustainable Comm... (Eddie Urie)

7/22/20 @ 7:00 PM
Hi, my name is Eddie Urie I'm the climate and energy policy manager at Resources for Sustainable Communities in Whatcom County. First off, am very glad to see this rulemaking. I think it’ll best serve, both environmental advocacy and public health in...↓

I’ll give an example of where we've had problems--with the refinery upgrade in Skagit County a few years ago, the EIS, basically counted plastic that would be manufactured from a petrochemical product as carbon sequestered and that was inappropriate for reasons I don’t have time to explain, but when we're talking about mitigation, this should be separated from the cumulative analysis an incumbent upon industries to invest in measurable reductions in pollution.
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Comment From: Earthjustice (Amanda Goodin)

7/22/20 @ 7:00 PM
Hello everyone. My name is Amanda Goodin and I'm an attorney with Earthjustice. But again, I’d like to thank the Department of Ecology for the chance to participate today. I'd like to comment on several aspects of the rule’s application. First, the f...↓

So first, the focus of this rule is large fossil fuel and industrial projects and that's the right focus. Facilities like LNG and methanol terminals, petrochemical facilities, and energy intensive industrial projects cause tens of millions of tons of greenhouse gas emissions every year. We've seen a number of assessments for massive projects recently that have not disclosed their full carbon footprint. That's a huge problem. For example, we've seen some project proponents attempt to avoid disclosing the massive downstream emissions caused by their products end use. We can't make good decisions based on bad information. We need to understand the full scope of these projects’ carbon footprint before considering new infrastructure investments. This is especially important since large fossil fuel and industrial projects typically have lifespans measured in decades. We have to avoid locking ourselves in unsustainable levels of greenhouse gas emissions. Massive fossil fuel and industrial projects threaten to derail the State’s progress on climate goals. Focusing this rule on the largest and most polluting facilities is what we need to do.

Second, this rule needs to be applied in a way that incorporates the latest science. It's critical that major projects use the most up to date science to estimate every aspect of their emissions. So, for example, the rule should not establish a value from methane leakage that would apply to every project going forward. Instead the rules should establish parameters for how to calculate the methane leakage rate for a project. A science progresses, we frequently learn that emissions are even greater than initially thought. The rule must require the analysis for individual projects to incorporate the latest science. This includes new science that post-dates this rule’s publication. It's also important to ensure that the parameters set by the rule guard against underestimating emissions. Where science is still evolving, the rule should require a margin of error to be sure that we don't lock in decades of emissions that are higher than the analysis revealed.

And third, this rule is especially important in light of the federal government's complete failure to respond to our climate crisis. The federal government is instead taking steps to weaken the environmental assessment of greenhouse gas emissions, and to promote increased reliance on fossil fuels. It is critical that state step up to fill this void. State agencies and local governments need the best information to make the best decisions. That information is not going to come from any federal requirements.

Washington needs to lead by establishing science driven requirements for environmental assessments of greenhouse gas emissions. We need this role to establish clear and comprehensive requirements and we need those requirements soon so that we don't have any more major project proposals, based on half-baked analysis. Thank you again for the chance to participate today.
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Comment From: Western States Petroleum Assoc... (Tiffany Roberts)

7/20/20 @ 1:46 AM
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Comment From: bp (Jim Verburg)

7/17/20 @ 9:50 AM
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Comment From: Representative Sharon Shewmake

7/13/20 @ 6:50 AM
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Comment From: Washington Public Ports Associ... (Gerry O'Keefe)

6/25/20 @ 8:15 AM
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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Comment From: Washington Public Ports Associ... (Gerry O'Keefe)

6/25/20 @ 6:30 AM
The public cannot engage in a dialogue among intersted parties. As I understand it, the agency wont release the names of participants. As a resuilt, the Department of Ecology is the sole filter of public dialogue. This is a big problem.


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Comment From: Association of Washington Citi... (Carl Schroeder)

6/24/20 @ 7:00 PM
Okay. Thank you. So I’m from the Association for Washington Cities. For those who don't know, we’re a nonprofit that, whose members are made up of the cities in the State of Washington. 100% of the cities are members of our organization. Just this mo...↓

So, we do hear concerns periodically that the status quo, you know, can feel arbitrary. So, we support this effort to create clear guidelines. We will also look forward to being engaged proactively in this process and sharing more details on the specifics as they become clear. I think that's what I've got to say today. Thank you for the opportunity to participate.
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Comment From: Earthjustice (Amanda Goodin)

6/24/20 @ 7:00 PM
Thanks so much. Good afternoon, everyone. I'm Amanda Goodin. I'm an attorney with Earthjustice and I'd like to thank the Department of Ecology for the opportunity to participate in the advance development of this rule. Today like to offer thoughts on...↓

First, we need emissions reductions and major new projects need to analyze how they can contribute to these reductions, not just maintain status quo. Second, we need science based standards to calculate these emissions. And third, we need mitigation that achieves real emissions reductions and equitable outcomes.

So, first, the overarching goal here needs to be emission reductions. We need dramatic emissions reductions and we need them soon. State law tells us this, and more importantly science tells us this. We need to be sure that every new project does its part help Washington achieve these emissions reductions. And that means that analyzing mitigation to net zero emissions is just not enough. Every project needs to analyze mitigation that gets to well below zero and incorporates the reductions we need to see over time. In the context of our urgent need for emissions reductions, a project with net zero emissions has a significant adverse environmental impact. The SEPA Rule is meant to guide analysis that will inform decision makers exercising their substantive SEPA authority. And that includes the authority to say no to projects that cause harm that's not fully mitigated. The major fossil fuel and industrial projects we're talking about that will be covered by the GAP Rule--these are projects that, once they're built, are with us for a long time, for decades into the future. And we’re at a critical point, when we need emissions reductions soon. We need them in that same time frame. So we have to get this right. We have to be analyzing reductions in the analysis of these projects, because preserving the status quo--maintaining our current level of emissions--is a significant, unreasonable, environmental impact.

Second, we need science based methods to calculate a project’s emissions. Major projects, like the projects covered by the GAP Rule will have major upstream and downstream emissions. And there's lots of information, lots of science out there that tells us how to calculate those emissions. Unfortunately, we’ve seen a lot of analyses recently that do not incorporate the best science. A few examples, we’ve seen recent analysis for recent projects that have included wildly unrealistic estimates for leakage associated with gas extraction. We've seen unrealistic estimates for the global warming potential of methane and unrealistic estimates for leakage from ships. Another area where we've seen a lot of problems is in claims in market displacement. We've seen claims that new projects will displace other fossil fuels that are supported by completely speculative analysis. This is an area that is rife with uncertainty allow a hope and a prayer of reductions elsewhere to justify massive new carbon emissions. We need to be sure that we're using the very best science in these analyses and we need to be sure that as the science evolves, the standards evolve too. Ecology should be consulting with experts, like SEI (?), on this rulemaking to be sure that we're requiring the very best and the most current science in every environmental analysis.

Third, we need mitigation that achieves real emission reductions and equitable outcomes. And we reductions, I’ve already touched on that, not just the status quo. Maintaining the status quo is a significant adverse environmental impact, but we also need to ensure those reductions are real. Mitigation needs to meet rigorous standards. We need to know that the reductions are additional, not reductions that would occur anyway, and we need to be able to quantify and verify them. There's a significant body of research on the best ways to do this and Ecology needs to rely on the best science and the best research, so that proposals for mitigation, in these environmental analyses, incorporate those requirements.

It's also critical that the mitigation analysis incorporate a strong equity lens. Huge projects, like the projects that the GAP Rule would cover can have devastating impacts on nearby communities. Many of these communities are already vulnerable and overburdened. These can include impacts from air pollutants like particulates and toxics that have known health effects. They can include adverse effects to important community resources like fishing areas. We need to require a strong environmental justice analysis of any mitigation proposal. And this rule needs to set strong standards for what that analysis looks like. We know we need to reduce our greenhouse gas emissions and we need to be sure that we're increasing environmental equity at the same time.

Thank you for the chance to participate in the advance development of this rule. We have the chance here to set the gold standard for hoe this analysis should be done and we look forward to working with you to make that happen. 
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Comment From: Association of Washington Busi... (Peter Godlewski)

6/24/20 @ 7:00 PM
AWB also appreciates the opportunity and Ecology inviting a business perspective starting this rulemaking and throughout it. We do look forward to participating in a constructive and positive manner throughout the process and our members are committe...↓

First point is release a working draft before the formal release of CR102. We believe an ongoing dialogue between the stakeholder community and Ecology would provide (work?) immediate feedback as the rulemaking process advances and allow for a more refined product when CR102 is released.

We also think we should align emission factors with existing rules. The final rule should use the same GHG emission factors that are currently used in EPA and other state GHG reporting rules to help streamline the reporting to state and public agencies. (Inaudible)…required the need for clear mitigation guidances for, for compliance and (inaudible) the goals to be achievable and realistic in terms of achieving the state greenhouse gas emission goals. These goals should be, again…mindful of the ability of, of a certain (inaudible)…project to meet those, state to meet those goals. Excuse me.

A consideration of the impact of leakage in the overall impact of the global greenhouse gas emissions outside the borders state, AWB believes that shifting our emissions out of the state is not in the best interest of either the climate or our state. We'd like to see a de minimis level for emissions, below which carbon emissions from projects are not impacted by this rule.

The allowance of the best available control technology as a mitigation pathway for future projects. Uh, responsible growth allowance…encouraging responsible growth…we'd like to see the department evaluate the mitigation of greenhouse gas emissions on a greenhouse gas intensity basis.

And finally, a limit of the geographic scope of secondary emissions. Similar to the offshore boundary definition of the Clean Air Rule…the scope of secondary emissions should be limited to Washington State borders and offshore waters to under state controls, which is three or five miles, as opposed to 200…(inaudible).

Again, we appreciate the opportunity to provide input and look forward to our participating as these webinars move forward. Thank you.
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Comment From: AQP Enterprises, LLC (Alan Newman)

6/24/20 @ 7:00 PM
Yeah, I guess I'm gonna be a little off from everybody else, but I want us to think about where we're going to have jobs for our children and our grandchildren as we want to have them living close to us in this fine state. Towards that end, I encoura...↓
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Comment From: Association of Washington Busi... (Peter Godlewski)

6/15/20 @ 4:45 AM
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Comment From: EITE Group (Jennifer Ziegler)

6/11/20 @ 6:32 AM
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