Chapters 173-441 WAC and 173-446 WAC, Cap-and-Invest Program Updates and Linkage Rulemaking Formal Comment Period
Comment From:
City of Spokane (Robert Duff)
7/20/26 @ 3:30 PM
Thank you for the opportunity to comment on the proposed rule language related to linking the Climate Commitment Act Cap-and-Invest program with other entities (CR-102/(173-446 WAC)). The City of Spokane submits the following comments.
The City of S...↓pokane would like confirmation that this current rule-making will not affect our Waste-to-Energy facility with respect to recent RCW changes enacted with passage of House Bill 2416. Specifically, we would like to confirm that the no-cost allowances provided in statute for the years 2027 through 2030 will not be affected by the proposed compliance period changes. In addition, we would also like clarification on whether there will be any changes to the consignment of no-cost allowances that will affect the City's WTE facility.
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I strongly oppose the proposed expansion and linkage of Washington's Cap-and-Invest Program.
This program continues a troubling trend seen in states such as California, where increasingly aggressive climate p...↓olicies have contributed to some of the highest energy costs in the nation. Consumers, small businesses, truckers, farmers, and working families are paying the price. The cost of these programs is ultimately embedded in fuel prices, transportation costs, utility bills, and the price of virtually every product that reaches store shelves.
The reality is that affordable energy is not a luxury—it is the foundation of economic prosperity. Energy is the lifeblood of a modern economy. When governments deliberately increase the cost of energy, they increase the cost of living. The burden falls most heavily on lower-income households, working families, retirees on fixed incomes, and small businesses that can least afford it.
I am also concerned that climate policy discussions frequently dismiss legitimate scientific debate regarding natural climate variability. Earth's climate has never been static. Long before modern industrialization, climate conditions changed significantly due to natural processes. One of the most well-established examples is the Milankovitch cycles—long-term variations in Earth's orbit, axial tilt, and precession that affect how solar energy is distributed across the planet. These cycles have been recognized as major drivers of historical warming and cooling periods throughout Earth's history.
While reasonable people can debate the relative contribution of natural and human influences on climate, it is difficult to justify imposing massive economic costs on citizens based on the premise that government planners can precisely manage global temperatures through increasingly complex taxation schemes, carbon markets, and regulatory programs.
I am also concerned by the increasing tendency to justify these programs under broad concepts such as "equity," "environmental justice," and "social justice" without adequately examining whether the policies themselves produce equitable outcomes.
If equity is truly the objective, policymakers should carefully evaluate who ultimately bears the cost of these programs. Every increase in fuel prices affects the cost of commuting, food distribution, agriculture, construction, manufacturing, and household goods. These costs do not disappear; they are passed directly to consumers.
The result is often a regressive economic burden. Wealthier households may absorb higher energy costs with relatively little impact on their quality of life. Working families, retirees, truck drivers, farmers, and lower-income households experience these costs immediately and disproportionately.
A policy should not be considered equitable simply because it is labeled as such. It should be judged by its outcomes. When a climate program increases the cost of gasoline, diesel, electricity, and essential goods, policymakers should explain how that outcome advances affordability, opportunity, or fairness for the citizens most affected.
Washington's emissions represent only a small fraction of global emissions, yet Washington residents are expected to bear significant economic costs in pursuit of emissions reductions that are unlikely to have a measurable impact on global climate outcomes. Citizens are asked to pay more every day while receiving little evidence that these sacrifices will materially alter worldwide temperatures.
The proposed linkage with California and Québec raises additional concerns. California's experience should serve as a cautionary tale, not a model. California residents face some of the highest fuel prices, electricity costs, and housing costs in the country. Policymakers should carefully consider whether expanding carbon market regulations is producing the promised benefits or simply creating additional financial burdens for citizens and businesses.
It is also worth remembering that the concept of carbon-credit trading traces its origins to market-based emissions trading concepts that were enthusiastically promoted by financial and energy-trading interests. The public should be skeptical whenever complex regulatory markets create new classes of tradable financial instruments while simultaneously increasing costs for ordinary citizens. Enron invented these schemes. That tells you all you need to know.
At a time when fuel prices remain elevated and inflation continues to strain household budgets, governments should be reducing the tax and regulatory burden on energy rather than expanding it. Policymakers should be exploring ways to reduce fuel taxes and compliance costs to provide relief to consumers instead of adding new layers of expense.
Most importantly, government derives its authority from the consent of the governed. Public policy should reflect the needs and priorities of the people it serves. Many citizens believe these climate programs have expanded far beyond their original purpose and now impose substantial economic costs while delivering uncertain benefits. Those concerns deserve serious consideration.
Fossil fuels remain indispensable to transportation, agriculture, manufacturing, aviation, emergency response, construction, and countless other sectors of modern life. Despite decades of predictions regarding their imminent decline, they continue to power the overwhelming majority of global economic activity. Public policy should acknowledge this reality and focus on making energy more affordable, reliable, and abundant—not artificially more expensive. Fossil Fuels, Fuel American Freedom.
For these reasons, I urge Ecology to reject the proposed expansion of the Cap-and-Invest Program, abandon efforts to link Washington's carbon market with California and Québec, and instead pursue energy policies that prioritize affordability, reliability, economic opportunity, energy security, and consumer choice.
Respectfully,
Bascomb Grecian
Economic Freedom Advocate
Energy Industry Expert
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