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Since proposing the draft Clean Air Rule, we've been actively seeking feedback that would help inform and shape the draft.
We are getting helpful and constructive ideas on how best to move the rule forward. We've considered many potential changes and refinements to the rule.
Let your voice be heard
We'll be scheduling hearings in the coming weeks.
Sounding Board Sessions — what we heard
We held two daytime sounding board sessions and two evening public meetings—one each in Seattle on
October 8, 2015 and one each in Spokane on October 13, 2015.
Our daytime Sounding Board Sessions were well attended and generated energetic discussions. We heard lots of thoughts,
concerns, and ideas about designing an effective Clean Air Rule. The evening meetings were smaller and we had more
discussions on topics of concern.
Click on a topic area to see a sample of what we captured from these
How will this work with the Clean Power Plan? The Clean Air Rule and the Clean Power Plan should harmonize. Need a
workgroup that focuses on both programs, as well as an electricity workshop and/or advisory committee. There is a strong overlap and
there could be serious problems if they do not harmonize.
Increase transparency throughout the rulemaking process.
How will you address leakage, the potential movement of businesses and emissions out of Washington? Will there be accommodations
for energy-intensive, trade-exposed industries?
Consider weather variability and annual rainfall variability. These can have huge impacts especially for the power sector
More meetings are needed. Meet with sectors to discuss the specifics about the rule and to discuss how it impacts their facilities
and their energy intensity. Facilities want to know how this rule works with other requirements.
Post comments online as soon as Ecology receives them.
Circumvention. How will you safeguard against companies gaming the system? What about companies that design their project so
their emissions are just under the threshold?
Encourage early reductions. Provide incentive, banking, and trading.
Concern that the scope and the threshold and sectors covered is too narrow.
Mobile sources, especially transportation, should be included. How is Ecology addressing transportation emissions
given they are a large portion of the emissions in WA? Transportation and marine fuels should be included.
Exported and imported fuels should be included. How will Ecology avoid driving businesses and emissions out of state?
Exempting imported fuels will put a cap on WA fuels, reduce production of fuel in WA, reduce WA jobs, increase fuels being
exported, and allow imported fuels to increase.
All fuels should be included. Get all the emissions, don't have leakage, get all of petroleum, don't encourage importing
petroleum (could be obtained at a different level then refineries, get it at the first entry into the state). The rule should
safeguard against leakage.
Ecology should include incentives that drive toward the existing low hanging fruit.
Don't forgo the opportunity to capture carbon. Don't prohibit it. Be open to it meeting criteria in the future.
Concerns with legitimacy of the credits. If you include offsets, there are many projects that you mentioned that
can be counted less accurately and there is more uncertainty than projects related to forestry. Capturing leakage
is extremely less understood and more problematic.
Consider a lower threshold for new entrants. How do you avoid circumvention? How do you treat aggregation
amongst multiple facilities under one company?
Can new entrants be capped from the get go? Can it be based on their initial design?
Need an incentive to use best available technologies. Must encourage new companies to use new and greatest technology.
New entrants, new source, not an expansion, should look more like a new source in a nonattainment area. They should
have their credits first. They shouldn't be exempt from the cap because they are under the threshold. Disadvantage to existing companies.