Chapter 173-446 WAC: Cap-and-Invest Offsets Rulemaking Informal Comment Period

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Comment From: Washington Conservation Action (Katie Fields)

9/27/24 @ 5:28 PM

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Comment From: Carbon Removal Organizations (Myron Lam)

9/27/24 @ 3:08 PM

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Comment From: Friends of Toppenish Creek (Jean Mendoza)

9/27/24 @ 1:27 PM

Dear WA Ecology,
Please see the attached comments from the Friends of Toppenish Creek.
Thank you.
Jean Mendoza
Executive Director, FOTC

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Comment From: WA Forest Protection Associati... (Tom Davis)

9/25/24 @ 6:39 PM

Re: Comment Period on Climate Commitment Act Program, Chapter 173-446 WAC, Offset Protocols

Please accept these comments on behalf of the Washington Forest Protection Association (WFPA) as part of the ongoing Climate Commitment Act ru...↓

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Comment From: Betsy Norton

9/03/24 @ 11:43 AM

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Comment From: CarbonPlan (Grayson Badgley)

8/29/24 @ 10:16 AM

Please find my comments pertaining to the second meeting of the Forest Offset Technical Working Group attached.

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Comment From: David Perk

7/12/24 @ 8:30 PM

As a member of public with low to moderate familiarity with the forest offset protocol I appreciate the emphasis on integrity, clarity and transparency emphasized by multiple technical group members. One of the earliest comments in this regard, regar...↓

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Comment From: DUBS HERSCHLIP

6/25/24 @ 7:13 PM

Proposed:
Revise qualifications for Livestock Projects to include methane reduction by use of approved seaweed (Asparagopsis taxiformis) as cattle feed to reduce methane production by 82%, as an alternative to methane-capture standards for dairy or b...↓

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Comment From: steve thalberg

12/19/23 @ 4:18 PM

Introduction:
1. There should be an incentive for small forest landowners to burn their slash to biochar, rather than to ash. This should be extended to vineyards, and other agricultural endeavors, that have significant woody material to be burned ...↓

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Comment From: Washington Conservation Action (Katie Fields)

12/12/23 @ 5:42 PM

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Comment From: Miles Sand & Gravel Company (Ryan Ransavage)

11/20/23 @ 11:23 AM

We support enacting a progressive policy shift by endorsing the generation of carbon offset credits for concrete with a Global Warming Potential (GWP) below the NRMCA (National Ready Mixed Concrete Association) regional benchmark. This forward-lookin...↓g measure is designed to incentivize the production and utilization of low-carbon concrete, aligning with broader initiatives to curtail the construction industry's carbon footprint. Carbon offset credits, functioning as a market-driven mechanism, furnish businesses with financial incentives to embrace cleaner technologies and practices, thereby facilitating a seamless transition toward sustainability. The focus on a GWP below the NRMCA regional benchmark not only encourages emissions reduction but also acknowledges and rewards companies surpassing established environmental targets.

The integration of concrete into the carbon offset credit program reflects a nuanced understanding of the material's substantial emissions and recognizes its potential for improvement. Concrete production, recognized for its energy-intensive nature, has long been a focal point in discussions about mitigating industrial carbon footprints. This proposal not only supports businesses in adopting environmentally responsible practices within the construction sector but also aligns with a pro-business perspective by acknowledging the economic benefits derived from incentivizing innovation and sustainability in concrete production.

Moreover, the incorporation of Tier 3 Environmental Product Declarations (EPDs) underscores a commitment to transparency and environmental responsibility. Tier 3 EPDs offer a comprehensive account of the environmental impacts of a product, providing businesses and consumers with essential information for informed decision-making. This strategic move not only supports the use of low-carbon concrete but also ensures that businesses can make decisions based on accurate and robust environmental data. As an example of how carbon offset would be measured, the system could quantify emissions reductions through a standardized approach, such as measuring the difference in emissions between conventional concrete and low-GWP concrete, reinforcing the efficacy of the program. Overall, allowing carbon offset credit generation for low-GWP concrete in Washington State's cap-and-trade system, alongside reference to the NRMCA regional benchmark and Tier 3 EPDs, represents a comprehensive and business-friendly strategy to promote sustainability in the construction industry.

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