Department of Environmental Quality, Climate Protection Program 2024 Rulemaking Advisory Committee 1

Comments on behalf of SOCAN submitted by Alan Journet, April 2nd 2024

I comment as a cofacilitator of Southern Oregon Climate Action Now representing hundreds of rural Oregonians who seek state action to address the climate crisis. We were very involved in the process that led to the CPP development and approval by the EQC in 2022.

While we were disappointed by some aspects of the CPP, we were also very disturbed by the efforts of the Fossil Fuel industry and others to defeat the program after serving on the RAC and committing time and again to seeking GHG reductions. We hope that the representatives of those entities from the previous RAC who then fought the CPP in the courts will approach this effort in good faith and with a more positive attitude. Future generations depend on your sincerity.

In particular, we hope that the revised program recognizes the delay and thus the need for a more rapid emissions reduction trajectory. In particular, we would like to see industry emitters included in the emissions reducing cap rather than continuing with the BAER component.

As a science-based grassroots climate organization we also urge that development of the CPP and the rules ultimately established should be science-based. We note this because there are pressures relevant to these discussions that defy scientific reality. I am thinking, for example, about the problem that complete lifecycle analysis is precluded, and that the production and transportation of some fuels that are defined in Oregon as emissions-free actually result in substantial emissions.

In the above context, it was of concern to hear during the session the claim that biofuel use results in no emissions. This is patently false and represents a perfect example of the failure of DEQ to acknowledge the best available science. If DEQ fails to acknowledge the science, it is difficult to imagine that the rules will do so. It was also of concern to hear the rejection of acknowledging full lifecycle analysis by stating the program only addresses emissions in-boundary. Failing to acknowledge upstream emissions means that Oregon is developing a program that lowers in-boundary emissions while potentially raising out-of-state emissions, i.e., exporting our emissions. We also urge that the Community Climate Investment feature should be applied to all entities.  The program should preclude the ability of gas utilities from by-passing and undermining the CCI component by importing biomethane generated out-of-state as a way to evade emissions reduction demands. Since biomethane generation and transmission is not emissions-free allowing biomethane generated out of state is another example of reducing in-boundary emissions by exporting emissions.

We understand that DEQ cannot do what it cannot do, but please recognize these problems and account for them in the rules that are developed. That means developing rules that discourage biofuels as an option and recognize the significance of upstream emissions.

Finally, I’d like to encourage representatives from the fossil fuel industry to try to avoid approaching this critical process with a commitment to defending and maintaining your current business model. Please recognize that, if we are to pass on to future generations a livable planet, much of what is currently being done needs to be adjusted.

0 replies

Leave a Reply

Want to join the discussion?
Feel free to contribute!

Leave a Reply

Your email address will not be published. Required fields are marked *