Using carbon management under the Cap-and-Invest Program

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Comment From: NW Natural (Kellye Dundon)

6/26/26 @ 9:25 PM

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Comment From: Western Power Trading Forum (Clare Breidenich)

6/26/26 @ 7:51 PM

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Comment From: Clean & Prosperous (Zac Pinard)

6/26/26 @ 5:18 PM

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Comment From: Beyond Alliance (Carl Kish)

6/26/26 @ 4:08 PM

The Beyond Alliance respectfully submits the attached comment letter in response to Ecology's request for feedback on Carbon Capture, Removal, Utilization, and Storage in the Cap-and-Invest Program.
Attached are two documents: (1) our comment letter,...↓

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Comment From: Climate Solutions (James Hove)

6/26/26 @ 4:01 PM

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Comment From: Puget Sound Energy (Jessica Zahnow)

6/26/26 @ 3:26 PM

June 26, 2026

Andrew Hayes, Cap-and-Invest Policy Section Manager, Department of Ecology
Marissa Tousley, Cap-and-Invest Industrial Decarbonization Specialist, Department of Ecology
Air Quality Program
P.O. Box 47600
Olympia, WA 98504-7600

Re: Pu...↓

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Comment From: Williams Companies, Inc. (Erin Sullenger)

6/26/26 @ 1:55 PM

Please see attached comments from the Williams Companies, Inc.
Thank you.

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Comment From: Jessica Spiegel

6/26/26 @ 1:41 PM

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Comment From: RMI (Kyle Clark-Sutton)

6/26/26 @ 1:40 PM

Please see the attached file for RMI's comments. Thank you.

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Comment From: International Emissions Tradin... (Adarsh Srinivasan)

6/26/26 @ 1:08 PM

On behalf of our 300+ member companies, IETA appreciates this opportunity to provide feedback to ECY on using carbon management under the Cap-and-Invest Program.

Our full response is attached.

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Comment From: Clean Air Task Force (Darryle Ulama)

6/26/26 @ 12:29 PM

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Comment From: Sabin Center for Climate Chang... (Korey Silverman-Roati)

6/26/26 @ 11:32 AM

Please see the attached file for our comments.

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Comment From: CarbonQuest (Anna Pavlova)

6/26/26 @ 11:24 AM

Please, see attached comments from Spokane Valley-based distributed carbon capture company CarbonQuest. Thank you for initiating the comment period on carbon management.

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Comment From: PacCLEAN.org and others (Mike Robinson)

6/26/26 @ 11:08 AM

Please see the attached letter submitted on behalf of a broad coalition of organizations across the CDR ecosystem. This coalition includes diverse set of interests and stakeholders:
- concerned NGOs like the Indigenous Greenhouse Gas Removal Commiss...↓ion, the Institute for Responsible Carbon Removal, Global Ocean Health, and PacCLEAN.org
- buyers and registries like Stripe, Rainbow Standard, and Absolute Climate
- suppliers and project developers like Ebb Carbon, Climeworks, Heirloom, Basic Dust, and many others
We are all speaking with one voice in making these recommendations to the department.

As explained in the letter, existing Washington state law provides a unique opportunity for Washington to provide important leadership on carbon removal.

RCW 70A.45.100 makes it clear that the legislature's intent is to support carbon removal of all kinds in Washington. We believe that what we are proposing in our letter fits this intent precisely.

We would welcome the opportunity to discuss this with you further at your convenience!

RCW 70A.45.100

(1) Separate and apart from the emissions limits established in RCW 70A.45.020, it is the policy of the state to promote the removal of excess carbon from the atmosphere through voluntary and incentive-based sequestration activities in Washington including, but not limited to, on natural and working lands and by recognizing the potential for sequestration in products and product supply chains. It is the policy of the state to prioritize carbon sequestration in amounts necessary to achieve the carbon neutrality goal established in RCW 70A.45.020, and at a level consistent with pathways to limit global warming to one and one-half degrees.

(2)(a) All agencies of state government including, but not limited to, the department, the department of natural resources, the department of transportation, the department of fish and wildlife, the department of agriculture, the department of commerce, the recreation and conservation office, and the conservation commission, shall seek all practicable opportunities, consistent with existing legal mandates and requirements and statutory objectives, to cost-effectively maximize carbon sequestration and carbon storage in their nonland management agency operations, contracting, and grant-making activities.