In our previous blog post, I talked about the Climate Commitment Act (CCA)—the law that established Washington State’s cap-and-trade program—and discussed where it’s flawed, what it gets right, and where the opportunities are for frontline communities. Here, I want to talk about linkage: a move that will significantly change how the CCA works.
What is “linkage” and where does it stand right now?
Right now, Washington State runs its own carbon market under the CCA. Large polluters are required to hold “allowances”—permits to pollute, basically—that are equal to their emissions, and those allowances are bought and sold within the state system. Linkage would connect Washington’s market to a larger carbon market shared with California and Québec. Companies could buy allowances across jurisdictions, with joint auctions and a shared price.
The state Department of Ecology has released a draft agreement to link Washington’s carbon market to California and Québec’s markets. While the agreement itself focuses on market coordination, it sets the stage for decisions that will shape how the CCA functions in practice and how it impacts frontline communities. The draft agreement lays out how carbon allowances are tracked, how auctions for those allowances are coordinated, and how the three jurisdictions would work together.
A major issue with the cap-and-trade program is that Washington polluters could meet their compliance obligation without reducing pollution at their own facility. Linkage exacerbates the problem by creating a market where polluters can purchase allowances from outside the state—which means that Washingtonians affected by pollution from these facilities will see less cap-and-trade revenue retained within the state to fund the programs we need.
Linkage expands a system that already allows companies to comply with the law without reducing pollution at the source, raising ongoing questions about local air quality, accountability, and whether communities most affected by pollution will see meaningful benefits. Ecology’s draft agreement doesn’t resolve these issues; it largely defers them to future implementation.
Why we’re engaging, and what we’re asking for:
We studied linkage and expressed our opposition to it a few years ago, and the concerns that informed that position remain. For that reason, we are preparing to submit comments on Ecology’s draft agreement because simply opposing linkage will not prevent impact. Unfortunately, linkage is likely moving forward, which means we must address how it is implemented and whether environmental justice concerns are taken seriously in that process.
Our engagement is not an endorsement. It is about reducing harm and shaping outcomes in a system that may move forward regardless of community opposition. Engaging allows us to name risks clearly, push for stronger protections, and advocate for transparency and accountability. It also ensures that these concerns become part of the public record, which matters for how the program is evaluated and enforced over time.
As we prepare our comments to the Department of Ecology, we’re focusing on several key areas:
- stronger protections against local pollution, including approaches that ensure emissions reductions happen in frontline communities;
- clear and enforceable definitions of community benefit, so that investments are meaningful and measurable;
- greater transparency, including accessible public reporting on emissions, allowances, and outcomes; and
- maintenance, rather than weakening, of Washington’s environmental justice standards.
These are not new ideas, but they become more urgent as the carbon market expands. Our goal in engaging at this stage is to reduce harm, strengthen accountability, and ensure that environmental justice concerns are clearly on the record.
We are also continuing to listen: our position is not fixed, and we’re open to it evolving—but not without first hearing from the communities most affected. Frontline community input must be critical in shaping what comes next.
We want to hear from you!
We’re finalizing our public comments on Ecology’s draft linkage agreement and we want your input!
- What concerns do you have about linkage?
- Have you been impacted in any way by the CCA so far?
- What would need to change for this system to better serve your community?
Use our contact form to get in touch! Your feedback will help shape how we engage with linkage so long as it continues to move forward:
Below, we dive deep into the concerns we have with linkage and what it means for frontline communities. You can read on for more information, but if you are ready to send us your thoughts and input, please use the button above.
The problem with linkage:
Our concerns with linkage are not new. They’re grounded in how the CCA already works and how linkage could amplify those dynamics, and they are not resolved by the draft agreement.
As a market-based system, the CCA is designed to reduce emissions overall, and not necessarily in the places where people are most exposed to emissions. Linkage reinforces the disconnect between where pollution happens and where any reductions occur. Frontline communities are exposed not just to greenhouse gases, but to co-pollutants like particulate matter and nitrogen oxides that have direct health impacts. But polluters can comply with the cap-and-trade program without reducing emissions at their own facilities, meaning that communities already experiencing high levels of pollution may see little or no improvement.
In its assessment of the effectiveness of linkage in meeting environmental justice concerns, Ecology points to its own earlier analysis suggesting that it may not have the authority to establish facility-specific emissions limits under existing law. The analysis also notes that reducing greenhouse gas emissions does not always lead to reductions in criteria pollutants, and suggests that this weakens the case for requiring facility-level reductions.
But if the cap-and-trade program cannot ensure reductions in the communities most affected by pollution, that is not a justification for maintaining the status quo. It’s a gap that needs to be addressed. The fact that greenhouse gas reductions do not automatically reduce co-pollutants is not a reason to avoid facility-specific protections; it’s actually the reason such protections are necessary.
Linkage also introduces additional layers of complexity and distance into the cap-and-trade system. As markets are combined across jurisdictions, it becomes harder to track where reductions are happening and more difficult for communities to hold decision-makers accountable.
The draft agreement largely focuses on ensuring the market functions smoothly. It does not add new protections to address any frontline community concerns. It does not include new requirements to reduce emissions at the source. It does not establish protections against localized pollution. And it doesn’t address a core question: What happens to pollution in the communities where it is actually being produced?
This major question is left to implementation, and that’s where most of the real impacts will be determined.
How might linkage play out for frontline communities?
The broader policy landscape is shifting in ways that make state-level programs like the CCA more important. Ongoing uncertainty at the federal level—including the durability of climate investments and regulatory protections—has raised questions about how stable climate policy will be over time. In that context, linkage could help stabilize Washington’s carbon market by connecting it to a larger, more established system. In the absence of federal protections and funding for frontline community priorities, a larger market can mean more predictable allowance prices and a more consistent stream of revenue to fund community investments, clean transportation, and energy programs.
On the other hand, that same flexibility can weaken the already tenuous connection between the cap-and-trade system and local outcomes. Without stronger safeguards, communities will experience little change in local air quality and continued exposure to harmful co-pollutants, and they will have limited visibility into where reductions are actually happening. Linkage may also put downward pressure on Washington’s allowance prices as the market aligns with lower prices in California and Québec, and while that could reduce some cost pressures, it may also reduce the amount of revenue generated through auctions, potentially limiting the funding available for programs and resources that communities already rely on.
These outcomes are not inevitable, but they are possible under the current structure. As we prepare our comments on the Department of Ecology’s draft linkage agreement, we’d love to hear from you: