Should organizations be able to count their carbon pollution reductions toward multiple programs or rules?

Should organizations that are required to reduce their carbon pollution under the Clean Air Rule be able to count their reductions toward multiple programs or rules that require carbon pollution reductions?

The issue

Ecology’s clean air rule proposes that some organizations in Washington would be required to reduce their carbon pollution over time. Other existing or proposed rules might also require carbon pollution reductions. Many people have asked if organizations will be able to count carbon pollution reductions for multiple rules.

For example: The U.S. Environmental Protection Agency recently set carbon pollution limits for the nation’s existing power plants through a rule called the Clean Power Plan. The EPA’s rule establishes state-specific goals to reduce carbon pollution from existing power plants. Many power plants in Washington would be covered by the Clean Air Rule in addition to the Clean Power Plan.

We appreciate your comments and questions. These communications are part of the public record but are not considered formal comments. The formal comment period will begin after we file the CR-102 form. We expect this to happen in December 2015.

4 thoughts on “Should organizations be able to count their carbon pollution reductions toward multiple programs or rules?

  1. If an entity is subject to multiple carbon emission reduction requirements then I believe the most limiting or stringent reduction should apply. For example, if it was a federal regulation that reduction should apply, which would also satisfy the state regulation. If it resulted in a state regulation extra reduction credit, then I do not believe that credit should be allowed to be banked for the future or sold, unless that was also permitted under the federal regulation.

  2. 1. Protect the environment. 2. Keep it simple. 3. Make it happen.

    I believe that the environmental protection will be enhanced as the inducement to reduce emissions or air pollutants (criteria, toxic, greenhouse, whatever) is increased. The ability to get “credits” for more than one program for the same reduction may help somebody to decide to do whatever it takes for them to reduce ghg emissions. I can almost see an environmental manager presenting the case to management, arguing that they’ll get credits, here, here, and with the Department of Ecology! Win-win-win!
    It’s simpler. No need to check if they’ve already claimed credits somewhere else.
    Maybe it’ll happen quicker.



  3. There should be only one program that complies with all other carbon pollution reduction programs. The new proposed state regulation should incorporate all other rules from federal or regional agencies.

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