Under Washington's cap-and-invest program, covered entities must surrender carbon allowances to cover their greenhouse gas emissions for each compliance period. These entities can surrender carbon offsets instead of allowances to meet a limited portion of their compliance obligations. Washington's Department of Ecology (the Department) establishes the protocols that projects must follow to generate carbon offsets eligible for use in its cap-and-invest program. In response to the Department's request for public comment on its proposed revisions to its U.S. Forest Protocol, Policy Integrity offered the following recommendations:
- The Department should not shorten its minimum commitment period of 100 years for both emissions reductions and removals.
- The Department should ensure that its revisions to the method for calculating buffer pool contributions would not reduce the buffer pool's overall size.
- The Department should not allow project developers to buy insurance instead of making buffer pool contributions.
- To the extent that it has not done so already, the Department should use relevant peer-reviewed literature to inform improvements to the Protocol.