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Getting Washingtonians involved

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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 in-depth discussions on topics of concern.

Click on a topic area to see a sample of what we captured from these great meetings.


• Generalfeedback

  • 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.

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• Covered Entitiesfeedback
  • 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.

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• Thresholdfeedback

  • Most participants said the threshold was about right, but some said the threshold should be higher.
  • People want to see the data and the calculations used to determine the threshold, sectors covered, and the 35 entities.
  • Thresholds and compliance targets should be specific to the sector.

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• Baseline Year to Determine Compliance Obligationfeedback

  • Most participants favored the multi-year average.
  • Companies want flexibility in determining the baseline.

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• Shape of the Curvefeedback

  • Don't let the statute limit the Clean Air Rule. The Clean Air Rule should be based on the best available science.
  • Is the compliance curve based on percentages or actual reductions?
  • Have more compliance steps/points and feedback points, not just the 3 years established in statute.
  • Focus on decreasing global total emissions, not just WA emissions.

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• How to Determine Compliance over Time feedback

  • Compliance should happen over a series of steps and have flexibility; avoid the compliance cliff.
  • Could vary for sectors. Will there be an overall compliance goal for the sector or will each sector have a compliance goal?
  • Companies impacted by the weather might not like a multi-year average.
  • Single years are problematic for companies because production schedules vary.

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• How to Comply with the CAPfeedback

  • There should be incentive for credits to be generated near low-income communities, polluted communities, and areas of worker displacement.
  • Facilities should be required to reduce their emissions by a certain amount before using credits. Most reductions should happen within the facility.
  • If facilities made improvements to reduce their emissions in the past, will they be given credits? How far back will Ecology accept?
  • Will there be technical support and incentives to help the 35 entities to adopt the rule and comply with the rule?

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• Credit System Designfeedback

  • Segregate sectors.
  • Look at existing systems, don't reinvent the wheel.
  • The Clean Air Rule credit system must work with the Clean Power Plan and other existing markets.
  • Don't allow double counting.

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• Criteria for Generating Creditsfeedback

  • Make credits and reductions real and permanent.
  • Have very clear criteria. Have a quantitative method for determining credits and reductions.
  • Alternative methods should be public. The method should be duplicable. Methods should be challengeable. This must be transparent.
  • Banking is essential. You should be able to bank credits so companies are rewarded for their reductions.

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• Credit-Generation Projectsfeedback

  • 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.

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• Location of Credit-Generation Projectsfeedback

  • Main reductions should occur within the sector within the state.
  • Washington State is too broad. Reductions should occur at the source, especially in disadvantaged communities. Consider environmental justice. Health impacts at a local community should be considered.
  • Not easy to satisfy requirements within state only. Prefers to have projects that benefit the region, not just the state.
  • If we restrict it to WA, then we lose opportunities for reductions at facilities in other locations.
  • Allowing criteria from emission reduction projects in other states encourages emissions to be reduced in states where emissions reductions aren't a priority.

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• Additionalityfeedback

  • Federal and state requirements should not be accumulative. Additional should not apply to vertical jurisdictions but should apply to horizontal.
  • Allow efforts to comply with the Clean Power Plan count with this rule too. Not double counting. Vertical jurisdiction is ok.
  • How will this rule work with the implementation of the Clean Power Plan? How will this rule work with other programs? Do emission reductions under this rule apply to the Clean Power Plan?

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• New Entrantsfeedback

  • 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.

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