Submit Comments to the Governor Supporting the Climate Protection Advocates
A broad statewide coalition of climate activists have been monitoring the DEQ process from its inception in May over a year ago. Throughout this process, coalition leadership has been developing sign-on submissions to DEQ relating to the program while individuals have been submitting their own or organizational comments (SOCAN submission are available on the SOCAN OCAP (Oregon Climate Action Plan) page scroll down to the 07/13/2021 Update).
Additionally, a subset of the coalition members has formed an ad hoc group calling itself the Climate Protection Advocates. Feeling the need for a stronger response to the DEQ proposed rules, this subset (led by Diane Hodiak, Executive Director of 350.Deschutes, Stuart Liebowitz, Facilitator of the Douglas County Global Warming Coalition, and Alan Journet, Co-facilitator of SOCAN) developed a set of concerns and submitted these (along with signatories from some 20 regional and statewide organizations) requesting a meeting with Governor Brown to urge her to exert some pressure on DEQ to request strengthening the Climate Protection Program draft rules commensurate with our current urgency. This request for a meeting has been granted and these three representatives will meet with governor on September 13th.
Who are the Climate Protection Advocates?
What is my role in this plan?
It was suggested by one of the signatories that our effort might be strengthened if members of the signatory organizations submitted comments to the Governor on or about that date (13th) to underline the concerns and solutions. We are asking folks to review the list of concerns and solutions (below), identify concerns you share, and send a note to Governor Brown.
What points were identified by the Climate Protection Advocates?
- Since the Executive Order targets at least 80% reductions from a 1990 baseline, the DEQ adjustment to a baseline of the 2017-2019 average should be accompanied by a concomitant adjustment in expected percentage of reductions since the latter emissions were some 11% higher than 1990.
- The program should include stationary sources (industrial polluters) including fossil (natural) gas electricity generation facilities within the mandatory emissions reduction requirements applied to fossil fuel suppliers and gas utilities. This would result in these polluters needing to meet science-based emission reductions targets. This should include encouragement for early emissions reductions and mandate increasingly greater emissions reductions along with a plan to achieve them.
- Per Executive Order 20-04, total GHG emission for all entities subject to these rules should be equal to or less than 32 Million Metric Tons of CO2 Equivalents by January 1, 2035 (i.e. at least 45% below 1990 level). Include electricity-generation sources that are not covered under HB 2021A.
- In order to protect vulnerable communities, industrial polluters should not be allowed to buy Community Compliance Investment credits until they have met their emissions cap or demonstrated a commitment to meeting the cap in the near future.
- DEQ should ensure that projects undertaken with Community Climate Investment funds (CCI credits that polluters can buy are the program’s carbon offset feature allowing polluters who cannot easily reduce their onsite emissions to fund projects elsewhere that can reduce emissions) comply with rules that assure their greenhouse gas emissions impact integrity (i.e. they really do reduce emissions / promote carbon sequestration). Also, such projects should not allow polluters to continue polluting to the detriment of affected communities, particularly vulnerable communities.
- Rather than restricting CCI funds to projects that only reduce emissions, the CCI fund should also support projects that promote carbon sequestration preferably in rural Oregon, and follow the best practices of being real, measurable, additional, permanent, verifiable, and enforceable.
- Fugitive emissions (i.e. greenhouse gas leakage) from pipelines, and transportation fueling should be included under the cap. Methane emissions from these entities should be required to have leak identification and be repaired when located. This would encourage industry cost savings as well as cleaner air. Regulation of Fuel Suppliers should include all carbon intensive fuels, such as propane, diesel, RNG, and Natural Gas. The program should also include full life cycle assessment of emissions as is required in similar air quality programs elsewhere.
Script of the submission by the Climate Protection Advocates to Governor Brown on September 13th
How do I write this?
Please start by identifying why you are concerned about addressing the GHG issue and note that you are from rural Oregon (if that is the case). The reason for stressing this is that we need to make it clear that rural Oregonians want climate action. This is to counter the inevitable opposition argument that climate action is just another liberal Portland / urban Oregon plan to impose burdens on rural Oregonians. Then pick a point or two that resonates with you – you don’t need to address all the points.
If you want more background information or a summary of the CPP, visit the Background page. It might be optimal to write your comments first in a WORD document and then copy and paste to the Governor’s “Share Your Opinion” page. I am not aware that the Governor’s page has a word limit, but if you discover it does, please let me know.
How do I submit my comments?
The target for submission is Governor Brown’s “Share Your Opinion” page by September 17th, where you should select ‘energy’ as the topic.
If you wish to submit via snail mail, the address is: Office of the Governor, 900 Court Street NE, Suite 254, Salem, OR 97301-4047.