Cap-and-Invest: EITE Industries report to the Legislature

Submitted By

23 Results

Search Type

Sort:

Sort Results By

Comment From: Clean and Prosperous (Kevin Tempest)

7/28/26 @ 4:13 PM

Attachments:

Download

Comment From: North Cascades Strategies (Jonah Goldman)

7/27/26 @ 12:54 PM

Please see attached letter.

Attachments:

Download

Comment From: Climate Solutions (Altinay Karasapan)

7/24/26 @ 10:31 PM

Attachments:

Download

Comment From: Glass Packaging Institute (Bryan Vickers)

7/24/26 @ 8:39 PM

Attachments:

Download

Comment From: University of Washington's Lif... (Jordan Palmeri)

7/24/26 @ 6:25 PM

Attachments:

Download

Comment From: Food Northwest (Pamela Barrow)

7/24/26 @ 5:42 PM

Attachments:

Download

Comment From: U.S. Oil & Refining Co. (Andrew Troske)

7/24/26 @ 3:45 PM

Attachments:

Download

Comment From: Carbon Leadership Forum (Meghan Lewis)

7/24/26 @ 3:40 PM

Please see our comments attached.

Attachments:

Download

Comment From: WSPA (Jessica Spiegel)

7/24/26 @ 3:34 PM

Attachments:

Download

Comment From: Washington BlueGreen Alliance (Jessica Koski)

7/24/26 @ 3:00 PM

Attachments:

Download

Comment From: The Boeing Company (Katie Moxley)

7/24/26 @ 2:09 PM

Please see attached comments from The Boeing Company.

Attachments:

Download

Comment From: Alliance of Western Energy Con... (Brandon Houskeeper)

7/24/26 @ 1:13 PM

Attachments:

Download

Comment From: NWPPA (Jackie White)

7/24/26 @ 1:06 PM

Attachments:

Download

Comment From: Ash Grove Cement (Russ Simonson)

7/24/26 @ 12:52 PM

Attachments:

Download

Comment From: The Nature Conservancy (David Mendoza)

7/24/26 @ 12:29 PM

Attachments:

Download

Comment From: Nucor Steel Seattle (Tarah Erickson)

7/24/26 @ 12:16 PM

Attachments:

Download

Comment From: Simplot Company (Dedra Williams)

7/24/26 @ 11:43 AM

The attached comments are on behalf of the Simplot Company regarding Cap-and-Invest ELITE Industries Report to the Legislature.

Attachments:

Download

Comment From: Washington Conservation Action (Caitlin Krenn)

7/24/26 @ 11:36 AM

Attachments:

Download

Comment From: bp Products North America Inc. (Jim Verburg)

7/24/26 @ 11:21 AM

Attachments:

Download

Comment From: Kaiser Aluminum Washington (Brent Downey)

7/24/26 @ 9:49 AM

Attachments:

Download

Comment From: Front and Centered, Friends of... (Christina Brown)

7/23/26 @ 12:03 PM

Attachments:

Download

Comment From: Phillips 66 Ferndale Refinery (Craig Bradley)

7/23/26 @ 9:56 AM

Please see attachment.

Attachments:

Download

Comment From: Stephen Smith

7/23/26 @ 7:20 AM

I wish to comment on the January 2026 Report to the Legislature on EITE allowance allocation for 2035–2050 prepared by the Department of Ecology. Specifically, I would like to draw the Legislature's attention to the potential solutions presented in S...↓ection 8, "Decarbonization Pathways and EITEs in Washington."

In the report, Ecology acknowledges that the solutions presented in Table 13, "Examples of Decarbonization Opportunities for EITE Industries in Washington," are "illustrative" and that a "variety of barriers" must be overcome before implementation. Based on my 35 years of experience in glass manufacturing, specifically float glass used in windows, automobiles, and solar panels, the discussion provides a useful overview but lacks the level of technical analysis necessary to support long-term regulatory decisions affecting hard-to-abate industries.

These speculative decarbonization examples should not be heavily relied upon in support of important policy decisions. Suggestions such as improving energy efficiency and increasing the use of recycled glass are already common industry practices and offer limited future potential for additional decarbonization. Other proposed solutions, including electric melting and hydrogen or other green fuels have not yet been demonstrated at commercial scale for float glass manufacturing and currently present significant technical and economic uncertainty.

While point-source carbon capture may be technically possible, Washington State does not currently have a permitted geological sequestration site (Class VI well) for the storage of captured carbon. As a result, Ecology is effectively suggesting that hard-to-decarbonize EITE industries, such as glass manufacturing, invest more than $100 million in carbon capture systems without a viable means of sequestration, while still being required to purchase Ecology allowances for the same captured emissions.

The products manufactured by many of Washington State's EITEs have evolved over centuries of continuous innovation and process optimization. In the case of glass, that evolution spans several thousand years. The CCA's decarbonization requirements and prescribed 2035–2050 carbon reduction schedule does not adequately account for current technological realities.

The Legislature must carefully balance decarbonization objectives with the need to maintain the competitiveness of hard-to-abate EITEs. Failing to do so will increase manufacturing costs in Washington, discourage job creation, and create additional incentives for businesses to relocate outside the state.

No attachments