Alan R.P. Journet Ph.D.
Southern Oregon Climate Action Now
August 31st 2023



Reference Proposed adjustments to the DEQ (EQC approved) Climate Protection Program

Nicole Singh and Elizabeth Elbel

I write as cofacilitator of Southern Oregon Climate Action Now (SOCAN, an organization of over 2,000 rural Southern Oregonians who are concerned about the climate crisis and urge statewide action to address it. The mission of SOCAN is to promote awareness and understanding of the science of global warming and its climate chaos consequences and stimulate individual and collective action to address it. Since rural Oregonians occupy the frontlines in experiencing the impact of the increasing temperatures, decreasing snowpack, drought, wildfires, and extreme weather that the climate crisis imposes, we are strongly committed to statewide action.

It was this mission that led us to engage extensively and consistently as DEQ held preliminary meetings and then orchestrated the Rulemaking Advisory Committee that advised on the development of the Climate Protection Program. Although there were elements of the CPP which we questioned, we felt that it overall provided a program that could make a substantial contribution to achieving greenhouse gas emissions reductions. This, we judged, would place our state at the forefront of responsible emissions reductions consistent with Intergovernmental Panel on Climate Change targets. However, what we always knew was that the key questions would ultimately surround how the program was translated into the rules governing its actualization.

It is, therefore, with great disappointment that we see what has been happening in the development of the actual rules that enable the program.

As the rulemaking process has progressed, we have been offering suggestions as to what we feel is proposed that undermines the CPP.  Regrettably, it appears that these comments have been ignored.  Frankly, from the composition of that RAC, it appears that DEQ established a committee that was preordained to undermine the CPP.  That committee had but two representatives of environmental / climate conscious organizations and no representatives from social equity organizations. This contrasted markedly with the 12 representatives from the corporate energy arena. Clearly, the committee was laden with representatives from the very industries that have contributed to the problem throughout the many decades that Oregon has had voluntary emissions reduction goals and has failed to meet them.  It is because of their decades of inaction that we are as far behind the eight-ball as we currently are. Yet, they were here anointed with an opportunity to further undermine our state’s efforts, and they seemingly are succeeding.  To those who might argue that this interpretation comprises unreasonable polemic, I respond that simultaneously to undermining the CPP, many of these same entities are engaged in a legal effort to reject the entire Climate Protection Program. We can only hope that the public rises, as we do here, to oppose their efforts. If Oregon is to achieve its share of emissions reductions, the Climate Program must be retained and must not be weakened.

I wish to offer comments on three major aspects of this effort to undermine the CPP: the RNG allowance, the BAER program, and the focus on Hydrogen as a solution.

  • The Renewable Natural Gas Boondoggle

The methane utilities have consistently engaged in the rulemaking process for the Climate Protection Program. Unfortunately, although their claim was to collaborate and commit to reducing greenhouse gas emissions from their product’s use, they really have not offered credible good faith efforts to accomplish this. Indeed, they continue to claim that natural gas is ‘the clean fossil fuel’ when they are fully aware of the full life cycle assessments including upstream emissions that give the lie to this claim.  These same entities have, furthermore, joined the cabal of industries attempting to thwart the CPP through the courts. The RNG and Hydrogen scams are cases in point.

In short, full lifecycle assessments of greenhouse gas emissions, considering the far greater global warming potential imposed by methane compared to carbon dioxide, reveal that, in terms of its global warming impact, fracked and conventionally extracted methane gas can easily be as bad as – if not worse than – coal as an energy source. Indeed, a recent peer-reviewed paper by Gordon et al. (2023) offers the following important conclusions:

  • “…gas with a 0.2% leakage rate is on par with coal at all analyzed levels of CMM [Coal Mine Methane] leakage.”
  • “Based on existing studies, coal has a median lifecycle GHG [emissions rate] of 980 kg CO2e per kWh (with an absolute minimum of 675 and maximum of 1689) and gas has a median lifecycle GHG of 501 CO2e/kWh (with a minimum of 290 and maximum of 988).”
  • “…global gas systems that leak over 4.7% of their methane (when considering a 20-year timeframe) or 7.6% (when considering a 100-year timeframe) are on par with life-cycle coal emissions from methane leaking coal mines.”
  • “methane leakage from gas production systems [ranges] from <1% to >66%.

Note that while the median value (# 2) for global warming emissions from gas usage is half that of coal, the range for gas emissions overlaps that for coal. Item 4, compared to 3, reveals again that methane gas is, at least as bad as coal in terms of emissions. This implies that gas is, in some situations, worse than coal. Since leakage rates increase with age (e.g., Weller et al. 2020), it seems inevitable that emissions will increase as infrastructure ages.

DEQ lacks the authority to assess full life cycle (upstream) emissions, but the transmission of gas through leaky pipelines from neighboring states will inevitably result in methane leakage that is unassessed. Allowing RNG produced in another state, whether piped into Oregon or simply transmitted elsewhere through pipelines, will result in Oregon’s program simply reducing in-boundary emissions by exporting emissions to other states.  The only solution to this is simply to disallow such an option.

While Lee et al. (2021) for example, argue that RNG is substantially better than natural gas in terms of full life cycle emissions, Feinstein and de Place (2021) make the case that it is a flawed remedy  because: it’s availability is insufficient to replace much natural gas, its inclusion raises the cost of the gas, emissions from natural gas already account for nearly a quarter of national greenhouse gas emissions, the limited RNG available should be used for industrial processes that find electrification difficult and not be wasted in general pipelines serving domestic usage, and finally that RNG is being used by the industry as a greenwashing scam. The goal seems to be to allow it to continue and even expand its current destructive business model of marketing climate pollution.  Feinstein and de Place (2021) conclude by arguing: “Although there may be some modest climate benefit for a few niche applications like heavy industry, RNG cannot be a replacement for the way we use natural gas now.” Billimoria and Henchen (2020) and Auguste et al. (2018) likewise argue that the best route to reducing greenhouse emissions does not include promoting natural gas utility efforts to extend their polluting grip on our energy supply.

Matthewson (2023) offers a valuable concern: “…while natural gas is an improvement over coal and other fossils fuels, continued reliance on it—not to mention any further development — at the expense of carbon-free alternatives will impede our ability to meet the Paris Agreement climate goals and avoid the worst impacts of global warming.” Meanwhile, Kemfert et al. (2022) offer the valuable insight that: “We highlight that natural gas is a fossil fuel with a significantly underestimated climate impact that hinders decarbonization through carbon lock-in and stranded assets.”

The gas industry seems to us to be seeking to undermine the Climate Protection Program by compromising the Community Climate Investment fund’s ability to promote socially just activities in Oregon, activities that can offset emissions legitimately. This component of the program exports climate pollution to neighboring states where leaking pipelines emit the methane that is RNG.  It is transparently obvious that the goal here is simply to promote a business model that accentuates the climate crisis.

In our judgment, DEQ should simply disallow this effort and return to its original plan requiring fossil fuel utilities that cannot achieve their reduction goals to invest in the Community Climate Investment fund that benefits Oregonians.  Failing that, efforts by the utilities to replace their product with RNG should be restricted to sources within Oregon. Recall, a critical component of the CPP, and especially the CCI fund is to benefit Oregonians, especially those experiencing a history of social injustice. This effort by the utilities bypasses and compromises that goal.


It was our position during the development of the program, that industry should be under the same reducing cap as the fossil fuel sector. The DEQ position was to favor the Best Available Emission Reduction (BAER) approach which may, or may not, result in emissions reductions, especially if industries expand production. Given that BAER is the focus for the industrial component, we now argue this program should:

  • place all large polluters on a substantial downward trajectory in emissions such that the industrial sector can achieve the statewide reduction goals stipulated in the program,
  • hold large emitters accountable for the climate pollution they produce and insist on the best available technology,
  • not encourage the expansion of existing pollution sources or the development of new sources,
  • require that potential new polluters should demonstrate plans prior to construction that confirm their inclusion of the BAER technology,


It is certainly the case that when hydrogen combusts, the product is water.  This creates the impression that hydrogen is a totally benign energy source. Regrettably, this is only the case in the artificial and unreasonable assessment that only accounts combustion emissions. Although the planet contains a vast amount of hydrogen, it is unfortunately not easy to separate it from the compounds with which it associates. Most methods require substantial heat and thus consume considerable energy.

The Hydrogen option might look promising so long as the Hydrogen employed is extracted from water using electrolysis through a process driven only by renewable energy sources (so-called Green Hydrogen). However, even this raises the real question as to whether renewable energy should be used to produce Hydrogen and thus maintain the natural (methane) gas industry. More reasonable might be a plan to commit renewably generated energy directly to end uses.

More troubling is the prospect of employing alternative processes for producing Hydrogen, since such technologies confront other problems. Howarth and Jacobson (2021), for example, report that using Hydrogen generated from methane (so-called blue hydrogen) is actually more greenhouse gas emissions intensive than combusting the methane itself. Furthermore, even if the renewable energy were available to produce green Hydrogen, as Erdener et al. (2023) point out “existing gas-fired power plants or industrial processes, may not be designed to tolerate hydrogen blending beyond a given limit; for many existing gas-fired power plants, this limit is 5% volume.” On a slightly more optimistic note, Esposito (2022) reports a limit of 20%, but notes that even if this Hydrogen is renewably generated, the greenhouse gas emissions reduction amounts to only 6 – 7%. Esposito also adds that this would raise the price of methane by 2 – 4 times.

It seems to us incredibly unfortunate that the recent rulemaking process, dominated as it was by the very offenders whose inaction has led to the desperate situation of non-compliance in which we find ourselves, has so seriously weakened the program approved by the EQC.  We object strenuously to this weaking and encourage DEQ to return to the program that was previously approved.

Respectfully Submitted

Alan Journet

Billimoria S & Henchen M 2020 Regulatory Solutions for Building Decarbonization: Tools for Commissions and other Government agencies. Rocky Mountain Institute.

Auguste L, de Chalendor P, Emery D, Gardiner W, Halleaux D, Holliday C, Katragadda G, Knight Z, Kortenhorst J, Kyle R, Laabs M, Lancaster R, Laskey A, Lont A, Mathur A, Moss A, New P, Parshad N, Regnell A, Singhi M, Steer A, Strn N, Topping N, Trezona R, Tricoire J, Tublana L, Turner A, Wirth T, Zhang L, Zhao C, Zoi C.  2018 Mission Possible: Reaching Net Zero Emissions form harder-to-abate sectors by mid-century. Energy Transitions Commission.

Erdener B, Sergi B, Guerra O, Chueca A, Pamnbour K, Brancucci C, Hodge B. 2023 A review of technical and regulatory limits for hydrogen blending in natural gas pipelines. International Journal of Hydrogen Energy 48 (14) 5595 – 5617.,5%25%20volume%20%5B14%5D.

Esposito D. 2022 Gas Utilities Are Promoting Hydrogen, But It Could Be A Dead End For Consumers And The Climate. Forbes March 29.

Feinstein and de Place E 2021The four fatal flaws of Renewable Natural Gas Sightline Institute

Gordon D, Reuland F, Jacob D, Worden J, Shindell D and Dysn M 2023. Evaluating net life-cycle greenhouse gas emissions intensities from gas and coal at varying methane leakage rates. Environmental Research Letters. Environ. Res. Lett. 18 084008

Howarth R & Jacobson M 2021 How green is blue hydrogen? Energy, Science & Engineering. 9: 1676-1687.

Lee U, Bhatt A, Hawkins T, Tao L, Benavides P, Wang M. 2021 Life cycle analysis of renewable natural gas and lactic acid production from waste feedstock.  Journal of Cleaner Production 311, 127653

Kemfert C, Präger F, Braunger I, Hoffart F, Brauers H 2022. The expansion of natural gas infrastructure puts energy transitions at risk. Nature Energy 7:7.

Weller Z, Hamburg S, van Fischer J 2020 A National Estimate of Methane Leakage from Pipeline Mains in Natural Gas Local Distribution Systems. Environmental Science and Technology 54: 8958-8967.

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