King County staff have reviewed and strong thumbs up to how this workforce development section represents the current partnerships and opportunities.

Suggest adding some discussion - data from consumption based inventory 2019 or soon to be released King Co inventory can provide sense of scale

Encourage discussion of how these actions/strategy can reduce emissions. King County is about to release updated consumption based emissions inventory, can be a guide for magnitude of emissions from food, with assumptions around food waste, could offer potential emission reduction from reducing food waste and improved food rescue

This seems better suited in next strategy, which is quantified based on acres protected.

Is there data on per acre land conversion, that could be referenced here? What is the basis for supporting that 50 million trees could be realistically planted?

Suggest citing the RCW vs the legislative bill

One-year ahead of the ZEV adoption rates?

Clarify how the emission reductions and actions compare, relate to, or are above and beyond Vision 2050

As formatted these tables continue to convey that if the strategy/actions listed above are taken than this is the emission reduction potential to be achieved. Perhaps if intent is to serve as a quantification tool to guide actions provide average per project data (e.g. for every 100 homes built with zero-emissions space/water heating = X reductions). This could then be general rules of thumb to quantify proposed investments.

Appreciate reframe on emission reduction potential. Continue to be interpreted as an estimate of scale of emission reductions that could be achieved by activities, when no approach, policy tool, or means of doing so is identified. Consider pivot to level of ambition required. The implementation of actions will need to be designed to hit this level of ambition to have meaningful impact.

Add Energy Smart Eastside: link

Staff in Public Health and Building Energy teams encourage adding Built Environment 1.2 here. Often programs to improve indoor air quality combine efforts to electrify and energy eff/weatherization. These are implemented together. Often improving weatherization and air sealing is one of the most effective local govt actions to improve indoor air quality now for residents. Consider making this a list of top 10 or combining both to list in this table.

Climate Solutions thanks you for the opportunity to submit comments on the 2025 Comprehensive Climate Action Plan (CCAP). Climate Solutions is a clean energy nonprofit organization working to accelerate solutions to the climate crisis. The Northwest has emerged as a hub of climate action, and Climate Solutions is at the center of the movement as a catalyst and advocate.

We appreciate the hard work that has gone into developing the CCAP, in particular the thoroughness in identifying actions to combat climate change and adapt to its impacts, and the wide range of sectors considered, including the built environment, transportation, solid waste and waste water, land use and sequestration, refrigerants, and consumption. The list of suggested actions for local governments to take is, indeed, very comprehensive, and we do not see any major gaps in the menu of possible actions.

However, we have concerns that lack of prioritization of the actions within each of their “strategies” would make it difficult for local governments to use this guide effectively. Each strategy does provide helpful metrics including emissions reduction potential and an estimated cost per ton, as well a list of co-benefits and other considerations. But since most strategies contain several possible actions, it may not be clear how a local government using this plan should evaluate an action’s effectiveness relative to the other actions in the same strategy. While we realize that each local government has their own context and specific considerations to decide which actions are appropriate for their community, we do believe that the CCAP should provide stronger guidance on prioritization, given that PSCAA, as an agency that operates across four counties, has a higher-level view of how climate policies across the region may fit together, and local governments may not have the capacity to do this level of analysis themselves. In particular, climate justice should be elevated as a factor in prioritizing actions, since frontline communities are both the most impacted by climate change and those who have historically been left out of climate planning.

We also believe the Draft CCAP has missed an opportunity to identify actions that PSCAA itself can take as an air agency. We understand that PSCAA’s own policies and programs are driven by its Strategic Plan, last updated in 2023, but the climate elements of the 2023 Strategic Plan focused primarily on on-road transportation, and only lightly touched on other sources of carbon pollution. It’s also unclear if the CCAP identifies actions that PSCAA could take, since the symbol for “authority to implement” covers other regional agencies and bodies as well, and the symbols are, again, only applied at the strategy level, not the action.

We thank PSCAA for the work that has gone into this plan, including extensive stakeholder and community engagement. By prioritizing the different actions local governments could take, and by identifying areas where PSCAA itself can have a direct impact, we believe the CCAP could be even stronger, to meet the needs of the climate crisis in the Puget Sound region.

- Deepa Sivarajan, Local Policy Manager at Climate Solutions

Consider using a different icon to represent environmental justice.

Consider making "appliance upgrade" more specific such as "1,000,000 appliances replaced with high-energy efficiency alternative" or "1,000,000 gas furnaces replaced with efficient heat pumps" if that's what was used for the calculation.

I think it would make more sense to refer to this as the 2030 (or 2050) GHG reduction target throughout the plan to avoid confusion with climate adaptation and resilience plans and actions at the state and local level.

Since King and Kitsap have included C-PACER, Pierce County's C-PACER program should also be included here.

This sentence about Snohomish County's built environment emissions is confusing. From the graph it doesn't look like built environment emissions declined. Are you saying that built environment emissions for SnoCo in 2019 and 2022 were lower than 2015?

Move this to under the graph

Include lines on the pie chart separating these sub-category sections.

What do you mean by "model" year 2022?

This shade of gray doesn't match the shade of gray on the map.

Eastside Cities' Energy Smart Eastside program (similar to Energize)

Weatherization, lighting, controls, and commissioning can be valuable for existing buildings as well

Improving building controls might fit into 1.2 and can be no/low cost. More broadly, equipment commissioning (making sure systems are running as manufacturer intended) is also good O&M

For this chart and above, is it detailed somewhere in this document what existing policies translates to in terms of expected accomplishments by 2030 and 2050? i.e., # of homes weatherized or appliances upgraded due to established policy and market response?

Major focus areas are not all represented in this GHG-focused list. Please include all 24 focus areas across the 2025 SCAP. See below.

A total of 25 focus areas appear throughout the Strategic Climate Action Plan. Each focus area describes a critical area of the Reducing GHG Emissions, Sustainable and Resilient Frontline Communities (SRFC), and Climate Preparedness sections.

GHG Reduction Focus Areas
-Countywide GHG Policy and Leadership
-Transit and Transportation
-Building Energy and Green Building
-Circular Economy
-Forest and Agriculture
-Enterprise Leadership and Accountability
-Sustainable County Infrastructure
-Zero-Emission County Fleets

SRFC Focus Areas
-Community Leadership and Community-Driven Policymaking
-Building Capacity with Frontline Communities and Youth
-Climate and Economic Opportunity
-Community Health and Emergency Preparedness
-Food Systems and Food Security
-Housing Security and Anti-Displacement
-Energy and Justice and Utilities Affordability
-Transportation Access and Equity

Climate Preparedness Focus Areas
-Sea Level Preparedness
-River Flood Management
-Extreme Precipitation and Drought Mitigation
-Extreme Heat Adaptation
-Forest Resilience and Urban Tree Canopy Expansion
-Wildfire Risk Reduction
-Salmon Recovery and Habitat Connectivity
-Climate-Ready Capital Projects
-Regional Capacity Across Climate Hazards

A number of entities across King County run clean building accelerator or incentive programs: Bellevue, Issaquah, Seattle/SCL, PSE...

Bellevue and Eastside cities' Energy Smart Eastside program is another good example, similar to the Energize program.

If not somewhere else, it may be helpful for decision makers to understand what causes the emissions within a sector in a practical sense. For built environment, for example, this is fossil fuels used for space/water heating, in particular, and possibly embodied carbon in a building's materials.

Recycling Reform Act (2025)?

HB1589 (2024) regarding the utility transition?

Might be informative to add that CCA revenues fund state/local investments in key GHG emissions sectors

Perhaps as an appendix item, a table of zip codes/Census areas by City/County would be useful for readers and practitioners trying to make use of lessons from the document

It would be beneficial to have an elaboration on how this would increase food security.

Can you link out to the King County program here? link

Can you link out to the King County program webpage here? link

Including the word "offset" here makes it sound like we are planting 1 tree for every tree cut down or using trees as a carbon sequestration offset for continued emissions in another sector. I recommend removing the word "offset" and just increasing tree planting generally.

Where is figure 1? I'm not seeing a Figure 1 in this chapter.

Consider adding examples of "off-road equipment." Are these stationary diesel generators or landscaping equipment?

Define Overburdened Communities. This term is used earlier in the introduction but is not defined. Here it's capitalized which really makes it seem like it should be a defined term.

If more trees are desired in urban areas for the benefits described above, more funding needs to be made available for the maintenance of those trees, preventing sidewalk/roadway damage by roots, and repairing sidewalks and roadways when they are damaged by trees. In Snohomish County, we've found that the impacts of street trees are important for public health, but that funding is desperately needed to ensure that right-of-ways are safe for pedestrians and bikers to travel.

I would say that cost is a factor, but also the logistics of getting equipment in and out of a site can necessitate cutting more trees than might be ideal. This also depends on one's definition of clear-cutting. In my forestry program, I was trained to recognize cuts of 40 acres or more as clear cuts. A lot of cutting in the PNW are not true clear cuts, but patch cuts. I can't speak to the harms to carbon sequestration in areas harvested with patch cuts, but I hope this provides some insight into how foresters are trained.

Can you be more specific? Does this refer to purchasing land, conservation futures, or other programs?

Could this be generalized to include all regional residents?

We need to have a distinct category for data centers in here whenever the next projections are made