Comments Needed to save and strengthen the Oregon Climate Protection Program

COMMENT PERIOD EXTENDED UNTIL FRIDAY SEPT 27th 4:00 pm

Alan Journet, SOCAN Co-facilitator, August 17th 2024

If you are short of time, jump to OUR TASK TODAY below.

BACKGROUND by Alan Journet

After years of legislative effort to pass a meaningful comprehensive greenhouse gas emissions reduction bill consistently being thwarted by recalcitrant Republicans who frequently deserted the chambers to break the lunatic high quorum in the legislature (but that’s another story), in 2020, Governor Kate Brown’s office  developed and she signed Executive Order 20-04 directing relevant state agencies to develop programs within their authority to reduce greenhouse gas emissions statewide and promote carbon sequestration within the framework of addressing social injustice.  The state’s Department of Environmental Quality (DEQ) launched a procedure the resulted in their establishing a Climate Protection Program (CPP). This was approved by the State Environmental Quality Commission in December 2021.

Several fossil fuel corporations, along with Oregon Business and Industry and other opponents who were represented on the Rulemaking Advisory Committee that assisted DEQ in the development of the CPP then file suit to block its activation.  Regrettably, their suit was successful, though not on substance but on a merely on a minor technicality.  Rather than appeal that ruling to the state Supreme Court, a process that could have taken several years, DEQ decided to develop a revised CPP, based on the original, a process they felt would be quicker.  Thus, during 2024, a new Rulemaking Advisory Committee was established, and the DEQ staff set about developing a replacement CPP.  This has been released and is open for a Public Comment period that lasts through August 30 at 4:00 pm.

OUR TASK TODAY

Since the revised CPP is open for public comment, our task is to contact the DEQ with a flood of comments stating our support for the revised plan and arguing a few key points that advocate strengthening it. The reason for this need is to counter the flood of comments that will be submitted by those opposing the CPP.

• Email target for written comments: CPP.2024@DEQ.Oregon.Gov
• Deadline: Extended from August 30th to 4:00 pm September 27th.

Key elements of submission:

1. Identify your subject as ‘Restore the Climate Protection Program’
2. Direct your comments to ‘Ms. Nicole Singh and members of the Oregon Department of Environmental Quality Office of Greenhouse Gas Programs.’
3. Start with a couple of sentences explaining why you are concerned about the climate crisis and are contacting DEQ about the CPP.
4. Points to make – please use your own words:
   Please send a letter urging DEQ to:
   -Deliver climate justice by upholding a strong Community Climate Investment program.
   -Maintain a science-based emissions cap that ensures near-term emissions reductions by requiring immediate compliance.
   – Maintain the trajectory and targets embodied in the previous CPP.
   – Hold industrial polluters accountable with mandatory declining emissions reductions.

If you submit comments, please shoot me an email indicating you have submitted.  You could do this by adding me as a Blind copy (bcc) recipient.

If you would like to run a copy of your comments by me before submitting, please do so (alan@socan.eco); I will respond rapidly. However, please don’t feel obliged to do that.  Our main goal is to stimulate many submissions, not make it difficult.

More talking points: https://docs.google.com/document/d/1paHb0UksHOeqOsthGaphov8rMdZJqtdQ8RR3w8mhxHI/edit#bookmark=id.8ywpntgy98vw

DEQ’s CPP Website: https://www.oregon.gov/deq/rulemaking/Pages/CPP2024.aspx

FYI. The SOCAN comments submitted several weeks ago are posted on our blog. This includes a downloadable PDF if you wish. But please don’t think your comments have to be so detailed – a series of brief bullet points will suffice.

WORD of ENCOURAGEMENT:

When the initial CPP was proposed in 2021, the submission of several thousand Oregonians’ comments to strengthen it drowned out the opponents’ please to weaken it and resulted in DEQ producing a stronger program.  We’d like to replicate that outcome.

FOR EXTRA MILERS:

It is possible to augment your comments by attending a Public Hearing on Thursday September 26th starting at 3:20 running to 5:20 pm and offering a paraphrase or summary of your written comments. This is a virtual event – only available via ZOOM: https://deq-oregon-gov.zoom.us/j/84398074366#success.

An RV-Times Guest Column on this effort is available here.