10/29/2021 Update

The public comment period for the DEQ Climate Protection Program draft rules closed on October 25th at 4:00 pm

The SOCAN testimony submitted during the comment period can be found here: SOCAN Comments to the Environmental Quality Commission on the Draft Climate Protection Program rules, SOCAN Comments on DEQ CPP Rules and SOCAN CPP Follow-up Comments.

We now await the final proposed rules that DEQ will produce consequent to the comment period. These will then be reviewed by the governing body of DEQ – the Environmental Quality Commission (EQC) either in late November or December.  Watch this space for comment opportunities.


SOCAN Comments on the proposed Clean Truck Rules (emulating that in California) that requires electric truck marketing: SOCAN Comments on the Clean Truck Rule

10/08/2021 Table Updates

Natural and Working Lands (NWL): Lauren Anderson, Oregon Wild; Grace Brahler, Beyond Toxics; Megan Kemple, OrCAN

  • Both Ag/water and Forests sub-tables 
    • The OGWC’s Final Natural and Working Lands Proposal was released! The Proposal sets goals for additional carbon sequestration on Oregon’s natural and working lands, including forests, agricultural lands, and wetlands: 5 million metric tons of CO2 equivalent by 2030 and up to 9.5 million metric tons by 2050.  It also recommends strategies the State should pursue to achieve the goals.  Highlights for agriculture, water and forests: “ The Commission recommends the State:
      • Support the implementation of climate-smart forest management and evaluate scenarios including lengthening harvest rotations on state and private forest lands and increasing protections for mature and old-growth forests on state and federal lands as well as areas with high carbon storage potential;
      • Invest in Oregon’s crop and rangelands through the establishment of a comprehensive climate-smart agricultural program that includes incentivizing soil health practice adoption and other climate-smart practices; and
      • Increase protection and restoration of Oregon’s carbon-rich tidally influenced coastal ecosystems.
    • Read the full proposal here. More information is available on the Oregon Global Warming Commission’s Natural and Working Lands Page.
    • We shared this news with the NWL Grassroots Listserv following the release along with action alert templates to reach out to Governor Brown and state legislators urging them to fund and implement OGWC’s recommendations.
      • “The Oregon Climate Action Plan Coalition is urging the Governor’s office and the Legislature to take action to address the climate crisis by funding and implementing the recommendations to meet the goals in the Proposal.  Please contact the Governor and your legislators to urge their action. Here are instructions and a template for your messages.”
    • Co-leads also distributed this Press Release to media contacts and have gotten some interest from the media.
    • Co-leads will be meeting with Chair MacDonald to inquire about implementation plans and funding needs related to the proposal. We anticipate the Legislature will receive an informational session on the proposal during legislative days in November.
  • Ag/water subtable:
    • The ag/water subtable supports all of the agriculture-related recommendations in the proposal.
    • Lots of work to promote the OGWC’s NWL Proposal to the media and OCAP partners/stakeholders.
    • The Capital Press is interested in doing a story and interviewed Megan about opportunities for agriculture in the proposal.
  • Forest subtable:
    • The Board of Forestry held a pre-decision workshop on ODF’s Climate Change and Carbon Plan 9/8. The Forest Policy Subtable circulated a sign-on letter and submitted it as written testimony; some subtable members presented live testimony. The Board will vote on this plan at the 11/3 virtual meeting.
    • The Forests Grassroots group presented a “deep dive” into Oregon state forest policy work to the PNW Forest Climate Alliance, including OGWC’s NWL Proposal and ODF’s CCCP. The goal was to strategize next steps/action items with forest climate activists. We shared info about the Board of Forestry meeting and talking points for the CCCP public comment opportunity following the deep dive.
    • We are preparing a sign-on letter to send to the Governor urging her to work with the Legislature and relevant agencies to implement the NWL Proposal’s recommendations plus blogs and action alerts focused on legislative priorities for the short session.

Cap and Reduce: Nora Apter, OEC; Don Sampson, ATNI

  • Huge thanks to everyone who turned out during the (initial) 60-day CPP public hearing.
    • 2 public hearings where we showed up; first in front of the DEQ staff; we represented 3×1 against opposition; really important one in front of the EQC a whopping 6:1 turning out to say we need to strengthen and adopt this program right away
    • Over 5,000 pieces of written testimony submitted, the vast majority were in support of strengthening the program; 15 writing workshop events held by OCAP coalition members
  • Last week DEQ announced a 21-day extension of the public comment period (deadline is now October 25th), in response to a formal request from Oregon Business & Industry.
  • We fully expect industry to use the extended comment period to try to further weaken the rules, and we need to push back: 
    • If you have not already, please sign on the joint comments and redlines! You can sign on using the form by COB Monday, 10/11.
    • More comment writing workshops upcoming to generate additional comments during the comment period– thanks to everyone who is hosting and organizing! Let’s go out strong!

Transportation: Vee Paykar, Climate Solutions; Sara Wright, OEC; Aimee Okotie-Oyekan, NAACP Eugene Springfield

  • Clean Trucks Update – It’s Truck Month!!
    • Rulemaking is wrapping up!
      • Thanks to folks who were able to submit comments/testify at the Proposed Clean Truck Rules Public Hearing on Oct 16th as well as the EQC Meeting on Oct. 1st!
    • Vote is tentatively scheduled for Nov. 17-18th (at the next EQC mtg)
      • *Note that meeting may get pushed back due to EQC commission seat appointments
    • Social Media campaign is getting finalized so you will be receiving updates on ways to share Clean Truck Rules to continue gathering individual support and interest!
  • Climate-Friendly and Equitable Communities RAC
    • RAC 8 was Sept 15th – Pushback from local governments on prescriptive requirements and timelines for climate friendly area designation. CFEC update at LCDC meeting on September 23rd. (Watch livestream starting at 3:10:10 September 23-24, 2021 LCDC Meeting (Day 1) – Sep 23rd, 2021 (granicus.com))
    • Community Conversations
      • October 25/6:30 – 8:30 PM/Southern Oregon
      • October 26/Noon – 1:30 PM/Bend, Corvallis, Albany
      • October 27/6:30  – 8:30 PM/Salem, Eugene, Keizer, Springfield
      • October 28/11 AM – 12:30 PM.Portland Metro
    • Next Commission meeting and public comment opportunity is Nov 18-19th
  • Clean Fuels Program Expansion is kicking off! DEQ is holding a listening session on October 13.
  • We’re tracking ODOT’s implementation of the tolling program in the Portland Metro region – this will require a series of actions by Metro Council that offer advocacy opportunities. We’ll continue to advocate for an approach to pricing that focuses on climate and equity outcomes (instead of generating revenue to pay for more highway expansion)

Clean Energy: Sherrie Villmark, Community Energy Project; Jeff Bissonnette, Northwest Energy Coaltion.

  • COVID/disconnection
    • UM19 — joint letter with alternatives to disconnection; Sylvia Tanner withMultnomah
  • Transportation Electrification
    • Method that PUC uses for transportation electrification; trying to remove barriers to utility investments in transportation electrification
    • Expecting the PUC to provide some input this month on how they are going to incorporate feedback that stakeholders have been providing
  • Future of Gas
    • Fast and furious process so far; has been mostly in a technical space; hoping that is moving into more of a public engagement space
    • Gas utilities modeled their preferred way of complying with the Climate Protection Program targets and outlined how they will meet them– basically put out a fantasy situation; more RNG and natural gas that you could ever imagine; 20% hydrogen that is upwards limits; huge reliance on new equipment like gas heat pumps
    • Work has been challenging those assumptions and pushing the PUC model a more realistic scenario; trying to get them to model reality that says you don’t have that much RNG, can’t rely on hydrogen, there is going to be electrification– what does that mean for customers and risk and therefore what decisions should we make about the gas utilities going forward?
    • What are the regulatory tools– if they decide there has been a lot of cost and risks on gas utilities expanding and not having a plan for how to meet these targets then they may make changes to existing policies that will hopefully encourage and subsidize options for low income oregonians; shift cost and risk to utilities themselves and not customers
    • Hope for outcome;
    • October 12th meeting is going to be a good one; it’s about regulatory tools so everyone being able to weigh in on what matters to them or what the pUC should prioritize for their recommendations for what the PUC does next; they will keep going with the
    • Climate Solutions planning to organize a briefing for folks to translate it and how to engage;
  • Oregon Community Solar Program
    • The PUC has agreed to move forward with 79 MW of additional capacity
    • A 2% escalator was paired with a 40% LI subscription discount (currently 20%)
    • Program Implementation Manual updates will be proposed next
    • With the Billing Hierarchy issues resolved, outreach is thriving. CEP worked with PGE for a large campaign and has signed up 200 people just in September. A recent report of the new changes will be available HERE within the next couple of weeks.

Public Health: Ira Cuello-Martinez, PCUN; Nora Apter, OEC

  • Heat and Smoke RAC
    • RAC was initially scheduled to end today (Oct. 7), however, it has been pushed back to Oct. 21. The reason for pushing back was to get more worker input and consider the comments submitted by stakeholders.
    • OR OSHA held two worker listening sessions to hear about how the temporary heat and smoke rules are working. We were given a 4-day notice and had difficulty getting workers to participate, but worker representatives were able to share some thoughts. PCUN shared findings from a survey conducted on 66 farmworkers. OSHA is receiving oral/written comments through tomorrow, Oct. 8.
    • Anticipating final proposed rules in November and a subsequent open comment period in December.
    • Rules should be finalized and adopted by the end of February 2022 ahead of the next heat and smoke season.
    • Federal administration expressed plans to launch a coordinated, interagency effort to respond to extreme heat including a national heat standard with strong enforcement. This is promising but would have liked to see more urgency since this can take years to finalize

09/08/2021 OCAP Updates

Natural and Working Lands (NWL): Lauren Anderson, Oregon Wild; Grace Brahler, Beyond Toxics;

  • Ag/water subtable: Megan Kemple, OrCAN
    • The OGWC’s Proposal to the Governor, recommending goals and strategies for carbon sequestration on NWL, is expected to go to the Governor in early September, which is now, don’t have exact dates yet. The Proposal will include the following strategies that the ag/water sub-table supports:
      • recommendations to leverage federal funding opportunities,
      • establish a comprehensive climate-smart agricultural program for Oregon,
      • provide technical assistance and training to producers,
      • and establish a Natural and Working Lands Council.
    • The Ag/water subtable and forests table are working closely together,  preparing to  promote the release of the final Proposal. We want to celebrate the Proposal and encourage the Governor to advance the recommendations, and express any concerns.  In the next week or so, we’re planning:
      • Joint media release from OCAP NWL policy table
      • Blog posts and social media
      • LTE’s
      • We will probably also co-host an Internal info session on the Proposal late in the fall to dissect & reflect on the Proposal and what’s next.
    • OGWC Chair Macdonald is also hoping to provide an update to the legislature in September.


  • Forest sub-table: Lauren Anderson (OR Wild), Grace Brahler (Beyond Toxics)
    • The forest’s grassroots group is leading a “deep dive” for forest climate advocates next week to brainstorm next steps for the numerous state-level policy decisions we’re tracking (OGWC’s NWL Proposal, ODF’s Climate Change and Carbon Plan and FMP/HCP).
    • Oregon Global Warming Commission’s Natural and Working Lands Proposal
      • Expect final proposal to be released this week or next
      • Will do a joint press release and blogs
      • Will send a letter to Governor asking her to move forward with proposal’s recommendations
      • Will do action alert/ request meeting with state legislature asking that they meet the funding needs of the proposal
    • Oregon Department of Forestry’s Climate Change and Carbon Plan
      • The Board of Forestry is hosting a pre-decisional workshop for the Department’s Climate Change and Carbon Plan at the Board’s meeting next Wednesday, September 8th.
      • Will provide written comments to ODF of finalized CCCP
      • Will offer verbal testimony to Board of Forestry at September 8th meeting
    • Oregon Department of Forestry’s Western Forest Management Plan Goals
      • Forests co-leads participated in a Forest Management Plan stakeholder meeting with ODF staff. We’re circulating a sign-on letter recommending additions and revisions to numerous draft goals, including goals for climate change, carbon, environmental justice, tribal consultation, and old growth protection.
      • Will do an action alert targeting ODF, asking for stronger environmental justice and climate considerations
      • Will do sign on letter
      • Deadline for comments is September 8th
    • Department of Environmental Quality’s Climate Protection Program
      • Working on a letter to DEQ asking that they add a disclaimer to the rule or report language acknowledging that one of Oregon’s largest sources of emissions (the forestry sector) is not covered, and that emissions data is not tracked. This is a significant barrier to addressing GHG emissions and climate change in the state.

NWL table (forests/ag/water):  Some NWL Table members met to discuss the DEQ’s Climate Protection Program and takeaways on the draft rules generally and carbon sequestration’s role in particular.

Transportation: Vee Paykar, Climate Solutions; Sara Wright, OEC; Aimee Okotie-Oyekan, NAACP Eugene Springfield

  • Oregon Transportation Plan update underway, OEC staff on the Policy Coordinating Committee.
  • Keeping an eye on spending of increased federal money – OTC will be making decisions starting pretty soon about how to allocate it. Initial sign-on letter to OTC (due at noon on 9/3) and we’ll keep the group posted for opportunities to argue for better spending choices.
  • DLCD CFEC rulemaking
    • DLCD provided RAC with draft rule language for transportation systems planning, land use requirements in climate friendly areas, and parking reform, and electric vehicle charging for comment: 2021-08-18_CFECRAC7Packet.pdf (oregon.gov)
    • Rules expected to be adopted in spring 2022
    • Will be more “community conversations” and other opps for input this fall.
  • DEQ Clean Truck rulemaking
    • Proposed Rules for Clean Truck Rules Open Now
    • Webinar on 9/15 from Environmental Justice & Public Health perspective
      • Register here and feel free to share with your networks.
    • All written comments due September 24th
    • Public hearing for oral feedback to staff on proposed rules on September 16th
    • Thursday, September 30th is the Final Environmental Quality Commission Meeting before they vote in November. Public comment period likely around 3pm
  • TEINA follow-up work – CS staff on the “Hydrogen Pathway Study” stakeholder group
  • The governor has nominated Marcilynn Burke to the Oregon Transportation Commission.

Clean Energy: Sherrie Villmark, Community Energy Project; Jeff Bissonnette, NWEC

  • Future of Gas – the docket is underway to determine how the PUC holds gas utilities accountable to the DEQ Climate Protection Program rules. While gas companies would not rather not even do that, advocates want a robust process that outlines how to reduce gas substantially to recognize the climate crisis we’re in. While the current docket may not determine the timeline by which gas is removed from the energy system, it can be a foundation to a larger conversation. But we’ll need to keep pushing to ensure that happens.
  • Covid-19 Protections – the disconnection moratorium ended at the beginning of August. Advocates are working to ensure that the possibilities for disconnection are limited and to also ensure that no one is shut off as long as funds remain in the utilities’ Arrearage Management Plans (AMPs). PGE is the first utility to provide notice that its AMPs funds are running out and has requested approval for more funding, which the PUC is expected to grant.

Public Health: Ira Cuello-Martinez, PCUN; Nora Apter, OEC

  • Emergency smoke rule adopted on Aug. 2nd and enforced Aug. 9th
  • Emergency heat rule for labor housing adopted Aug 2nd and enforced Aug. 9th
  • Ongoing engagement with the permanent rulemaking process for heat and smoke
  • Updated comment letter to Oregon OSHA with negative sign-off from initial letter
  • Conversations with federal congressional delegation to get a national heat standard

08/03/2021 Update

On July 22nd DEQ presented an update on the developing Climate Protection Plan to the Environmental Quality Commission, the entity that ultimately approve or disapprove of the proposed program.

The August (9th) meeting of the SOCAN Federal & State Government Project team will be devoted largely to a conversation with DEQ Manager of Greenhouse Gas Programs Office, Colin McConnaha to discuss the reasoning at DEQ for making decisions that we find problematic.  The list of items, already shared with Colin prior to the meeting, is here. This will be a ZOOM meeting.  Anyone interested in attending should contact Alan Journet for the URL.


07/13/2021 Update


EQC SOCAN Climate Protection Plan Concerns A statement of SOCAN concerns about the first draft of rules for the Climate Protection Program.

SOCAN Comments on the seven 2021 Rulemaking Advisory Committee meetings

SOCAN Comments on RAC – 7 (July 14th 2021); An audio recording of the meeting is available here.

SOCAN Comments on RAC – 6 (June 25th 2021)

SOCAN Comments on RAC – 5 (May 29, 2021)

SOCAN Comments on RAC – 4  (April 30, 2021)

SOCAN Comments on RAC – 3 (March 24, 2021)

SOCAN Comments on RAC – 2 (February 21, 2021)

SOCAN Comments on RAC – 1 (January 26, 2021)

SOCAN Comments on 6 2020 DEQ Technical Workshops.

1 – 3 SOCAN Comments on DEQ Tech Workkshops 1 – 3

1- 4 SOCAN Comments on DEQ Tech Workkshops 4 – 6

SOCAN Comments on 3 2020 DEQ Town Halls.

SOCAN Comments to DEQ Town Halls

Videos and information from the Technical Workshops and Townhalls can be found on the DEQ Greenhouse Gas Programs Page

Table Updates from the June ‘All-teams’ meeting.


  • Transportation Electrification Infrastructure Needs Analysis has wrapped up, final report is out, public comment period closed (the report heavily emphasized the fact that we’re way behind on electrification ) and the revised report will be sent to the Governor on June 30th.
  • Clean Air, Healthy Communities Coalition is a newly formed coalition that is focused in the near term on getting DEQ to pass the Advanced Clean Truck/Low-NOX rules. Contact Vee Paykar for more info.
  • Climate Friendly and Equitable Communities rulemaking is about halfway done. Have had community conversations in April/May, next full RAC meeting in July
  • ODOT created a draft Climate Actions plan, OCAP provided informal feedback and feedback through the ODOT survey. Awaiting final version.

Natural & Working Lands:

  • Ag/water subtable:
    • The OGWC is working on drafting their goals and recommendations for strategies to achieve a natural and working lands GHG emissions and carbon sequestration goal. The OGWC’s Report with their recommendations was due to the Governor by June 30th, 2021, but it sounds like they’ve got an extension until sometime in August.
    • Grace and Megan testified at the OGWC meeting on Friday May 7th to let the OGWC know we’d be providing policy recommendations.
    • We finalized and submitted OCAP Ag/water subtable’s shared policy recs for OGWCs NWL goal to the OGWC, ODA and OWEB on May 10th.
    • Megan also shared the OCAP ag/water subtable’s position at an Informational Meeting on the Role of Agriculture in Carbon Sequestration on May 27th in the House Ag and Natural Resources Committee. There was a similar Informational Meeting on Climate-Mitigating Agricultural Practices in the House Energy and Environment Committee on May 26th, with no representation from OCAP.
    • The OGWC recently posted Draft Strategy Recommendations, for discussion at the OGWC meeting on Friday June 4th . We’re pleased that the Draft Strategy Recommendations reflect nearly all of the ag/water subtable’s  shared policy recommendations, but there are several areas where the draft strategies could be strengthened. Co-Leads, Megan and Grace, provided Written Public Comment on the draft strategies and requesting clarity on the process and timeline for providing feedback on future versions.  Megan will provide similar verbal Public Comment at the OGWC meeting on Friday June 4th . She plans to briefly summarize some of the feedback we provided and ask for clarity on the process and timeline for providing feedback on future versions.
    • We’ll need to be ready provide public comment on the draft Report. We plan to prep talking points to make it easy for stakeholders to provide public comment on the draft Report once it comes out.  We are not sure about the process for providing input on drafts, so have requested clarity on timeline and process.  We’re also preparing for the release of the final report which could include a media release, social media, LTEs, and an Internal forum to dissect the report.  We expect the final report in August.  We may also hold a follow-up forum in late summer/early fall to reflect on the Report and what’s next.
  • Forest Subtable:
    • Submitted our Forest Climate Policy Brief to the OGWC to inform the NWL report.
      • Members of the Forest Policy Subtable are planning to testify at the June 4th OGWC meeting. Encourage others to do so as well.
      • Will submit written comments in review of the DRAFT strategy recommendations as well.
      • Overall they turned out better than expected – they mention longer logging rotations and protections for mature and old growth forests.
      • The strategy is focused only on sequestration goals instead of emissions reductions goals – which is a problem.
    • Developing feedback for ODF’s DRAFT Climate Change and Carbon Plan (CCCP)
      • ODF’s webpage for the CCCP is here, informational webinar has been posted on the webpage.
      • Comments on the draft plan can also be submitted through ODF’s portal, all are welcome to do so (the forest policy table is planning to submit comments on the draft plan).
    • ODF’s budget hearing
      • Members of the Forest policy table testified at the Joint Committee On Ways and Means, Subcommittee On Natural Resources hearing on May 19th.
      • Grace’s testimony for ODF’s budget bill

Clean Energy:

  • Community solar: held a workshop Friday morning 6/4 to get public feedback on the future of the program. In general, people asked for a simpler and more accessible program, particularly for low-income subscribers and community-based projects, more certainty and a higher bill credit rate for subscribers, and more easily accessible information about grid capacity from utilities.
    • Workshop recording will eventually be posted here, toward the bottom of the page under “events archive”
    • Staff is now turning feedback into a proposal for Commissioners to vote on at an August public meeting TBA
  • Covid-19: Commissioners decided shutoffs would restart; disconnection notices can now be sent out as early as mid-July. Advocates working on a sign-on letter this week that would give the PUC more specifics as to who should be protected and how, if shutoffs will resume for the general population
    • Please sign the letter once it’s circulated.
    • Participate at June 23 (9:30-12) workshop in support of advocates’ requests. Find more information on workshop and potential letter contents here.
  • Gas Fact-Finding Mission: PUC held first workshop last week to gather feedback on the proposed scope of its gas fact-finding mission. The purpose of the mission is to “analyze the potential natural gas utility bill impacts that may result from limiting GHG emissions of regulated natural gas utilities under the DEQ’s Climate Protection Program, and to suggest appropriate regulatory tools to mitigate potential ratepayer impacts.” See more here; upper right column of the page. The fact-finding mission will specifically focus on how transitioning away from gas might disproportionately affect low-income ratepayers, and what the Commission might to do mitigate that.
    • Advocates working on a sign-on letter to ask PUC to expand the scope of the mission. Stay tuned.

Public Health:

Cape & Reduce:

  • At a pivotal point in the Climate Protection Program rulemaking process;
  • DEQ released its first initial draft rules ahead of the fifth RAC meeting; draft rules include language on the purpose and scope of the program; covered entities and thresholds; compliance instruments; and banking/trading.
  • On the positive, we are glad to see DEQ proposing to regulate all natural gas utilities, and proposing to cover stationary sources’ emissions both from combustion of gas and process emissions.
  • As expected, the rules exempt the electricity sector from regulation under the program, which DEQ has long indicated would be the case, given DOJ’s determination of limitations in the agency’s statutory authority.
  • However, there were a few other concerning exemptions included in the draft rules: we have strong concerns that the threshold for transportation fuel suppliers is too high–meaning that emissions from some 90 oil companies and 10% of emissions will be left on the table–and that DEQ is not proposing to regulate industrial emissions under the cap, but rather through a “best available emission reduction” approach.
  • OCAP coalition members, both those who sit on the RAC and those who actively engage in the public comment portion of the meetings, did an excellent job weighing in and pushing back on these and other parts of the draft rule language at the last RAC meeting, and many organizations/cap and reduce table members will also be submitting technical written comments to DEQ by the end of this week.
  • Given the need to hone our focus in the final stages of this rulemaking process, the OCAP Cap and Reduce table convened a strategy meeting in May to identify upcoming program design decision-points where we have the most opportunity to influence DEQ and ensure the end result is additive, maximizes emissions reductions and equitable outcomes, and does not let polluters off the hook. Consensus to focus on the following:
    • NO EXEMPTIONS: No further exemptions for polluters, specifically the industrial sector.
    • ENVIRONMENTAL INTEGRITY + EQUITY: Ensure that DEQ’s proposed alternative compliance methods, Community Climate Investments (CCIs), provide equity benefits + maintain environmental integrity, by not allowing emissions to occur above the cap.

SCIENCE-BASED: Initial emissions cap + the rate of decline must be consistent with science-backed targets (minimum: EO goals). Require emissions reductions from day one + front-load earlier reductions.

04/30/2021 Update

The coalition table teams have continued to meet and engage with those agencies offering stakeholder or public engagement opportunities – which doesn’t include all agencies.

Of particular interest and concern is that the program that DEQ  is developing to cap and reduce emissions from stationary sources (i.e. industry, utility power plants) includes several components that seem likely to thwart the effectiveness of the program and preclude it from reaching even the numerical goal of 80% below 1990 levels by 2050 much less the ‘at least’ component that would allow agencies to go further than that minimum goal and strive to achieve net zero by 2050.  In particular, the inclination exhibited by DEQ to exempt the electricity sector – which includes the six greatest greenhouse gas emitters in the state – namely fossil gas powered generation facilities would, according to 2019 emissions data exempt 10.8 Million Metric Tons (MMT) of emissions annually.  Meanwhile, the inclination to place the threshold for inclusion of fuel suppliers (oil importers) at 300,000 metric tons of emissions annually, would exempt 14% of the emissions from transportation and other fuel, i.e., another 3.4 MMT.  Thus already exceeds the EO target of 11.6 MMT.   While we might see a reduction in fossil gas emissions as the electricity sector transitions to renewable sources, this is not guaranteed since that sector will  likely be exempt from the program and the encouragement across the board to electrify will likely increase our electricity demand and thus our generation need.  It has become increasingly a concern that DEQ is promoting Renewable Natural Gas as a solution and is suggesting that some 15 industries be subjected to the requirement that they adopt Best Available Technology rather than subject them to a reducing cap of emissions.  Since adopting BAT will involve substantial investment, it is not realistic to expect industries to update every years so the BAT requirement will necessarily include a review cycle of several years during which those industries will be exempt from lowering emissions. The array of exemptions that DEQ seems to be developing will place greater burden on other agencies or other entities within the DEQ Climate Protection Plan to reduce emissions to a greater extent.

The greater concern is that none of the agencies charged under the Executive Order seems to be developing a plan that honors the interim target and 2050 goal in that Order.

03/02/2021 Update

The Cap And Reduce Program:

Led by the Department of Environmental Quality, this program will target stationary sources and utilities.  The DEQ Cape & Reduce Plan has been renamed by the Climate Protection Plan

A 34-member Rulemaking Advisory Committee has been appointed by the Environmental Quality Commission on the recommendation of DEQ and is scheduled to meet monthly from January through June to offer advice to DEQ on their developing plan.   This committee contains an excess of industry representatives, a shortage of both climate and conservation/environmental and social – environmental justice/equity representatives, with no representatives from the arena of climate science.

Prior to the first RAC meeting, DEQ held a conference to discuss illustrative scenarios depicting possible directions the program might take.

SOCAN Comments on Illustrative Scenarios

Before each monthly meeting DEQ provides RAC members and posts on its website  a brief on topics to be discussed during the meeting.  These include DEQ ‘leanings’ on issues.  This means the tentative position (though claimed not to be a final position) that DEQ currently holds.  These materials can be found on the DEQ RAC Page, scroll down to, and click on ‘Advisory committee meeting schedule.’

SOCAN Comments on Rulemaking Advisory Committee sessions

SOCAN Comments on RAC 6 (June 25th 2021)

SOCAN Comments on RAC 5 (May 29, 2021)

SOCAN Comments on RAC – 4  (April 30, 2021)

SOCAN Comments on RAC – 3 (March 24, 2021)

SOCAN Comments on RAC – 2 (February 21, 2021)

SOCAN Comments on RAC – 1 (January 26, 2021)

Discussion of the Modeling will occur on April 28, 9 a.m. to 11 a.m. PT; Materials are available via the above link.  To attend and offer comments, go to: https://zoom.us/j/95742486449?pwd=dGJOSjhVcnFwVmZDZVdwemZmZTFFZz09 .


The lead agency is the  Department of Transportation (guided by the Oregon Transportation Commission).  The table is addressing Electrification through the ODOT Transportation Electrification Infrastructure Needs Analysis (TEINA), the Oregon Clean Fuels Program (also known as the Low Carbon Fuel Standard) administered by DEQ, a climate friendly and equitable communities plan within the Department of Land Conservation and Development, and contributed testimony on the ODOT State Transportation Improvement Plan (2024-2027 cycle) which increased the allocation to non-highway projects.

Clean Buildings & Appliances:

Building Codes updates are underway but the Building Codes Division thinks it is making far more progress towards the EO goals than is the case.  The hope that they would include a Solar Ready requirement and greater electric  vehicle charging capacity were thwarted.  REACH codes for buildings represent a level of more rigorous possible improvement that are not included with state codes but which counties and cities can incorporate in their codes.  Some of the efforts of this component of gthe EO seem to have been included in proposed 2021 legislation, which might move this sector forward faster than it is moving currently.

Clean Energy:

The Oregon Public Utilities Commission has finalized its plans for implementing the Executive Order, available on the PUC website.  This table is tracking PUC efforts via a spreadsheet

PUC Fossil Gas Factfinding Session – SOCAN Comments SOCAN response to a fact-finding webinar session exploring public and stakeholder perceptions of the role of Fossil (Natural) Gas in climate action.

Natural & Working Lands:

Agriculture/Water sub-table: Working with Oregon Global Warming Commission to establish ways to promote carbon sequestration.  This includes a survey seeking input on this issue.

Forestry sub-table:  Have developed a guiding document and policy agenda. Also sharing the survey mentioned immediately above, have offered testimony to the Oregon Global Warming Commission, and the Oregon Board of Forestry, but the latter seems relatively unresponsive on this issue.  Has developed position papers on biomass and climate smart forestry.


Advised on the first annual Oregon Health Authority: Climate and Health report released in late 2020. OHA and the Oregon Occupational Health and Safety  Adminsitration are collaborating on developing a response to gthe EO regarding workplace safety especially for outdoor workers in relation to wildfire.

Agency Report Card:

The coalition leadership has developed the first annual report card on agency efforts to meeting the charge in the Executive Order.  This will be released on the Anniversary of the signing (March 10). My (AJ) sense is that this report card will be overly generous.

Legislative Proposals:

Although there is no effort to propose comprehensive greenhouse gas emissions legislation in the cap, trade, and invest mold of previous years’ efforts, several proposals have been introduced that augment the Executive Order by targeting components of agency responsibilities.  See SOCAN’s 2021 Oregon  legislative priorities for further information.


09/28/2020 Updates

The OCAP coalition members have been working diligently to engage with the agencies on developing proposals to actualize the Governor’s Executive Order 20-04.  The most active Table has been the Cap and Reduce Table contributing to the state DEQ technical workshops on a series of critical issues relating to the agency’s scoping on its cap and reduce proposal.  The 6 technical workshops were held between between late August and mid-September.  Information on these workshops can be found here which provides links to the sessions and comments submitted.  As can be seen, each workshop covered a different topic: Program Scope, Program Stringency, Alternative Compliance Options, Distribution of Compliance Instruments, Coat Containment, and Impacted Communities.  It is evidence from this, as it is from reading the DEQ Issue Briefs associated with the sessions, that DEQ personnel are thinking in terms of a plan that is based on Compliance Instruments (termed Allowances in the legislative proposals of 2019 – HB2020 and 2020 – SB1530).

The Compliance Instrument (Allowance) Basis for the Climate Protection Plan

Given the involvement of DEQ in those legislative efforts, it is not surprising that this would be the default approach they adopt.  However, as can be seen in the comments AJ submitted in response to these sessions, this approach has a substantial weakness.  The legislative proposals involved Allowance auctions, with funds raised being assigned to the Investment component of the Cap, Trade, and Invest bills.  Under these circumstances, the price imposed on emissions can be targeted upstream (where fossil fuels, for example, enter the energy economy) and passed down to end users.  That cost serves as an incentive to end-users to adjust their behavior to use renewable energy sources thus avoiding the emissions cost.  Unfortunately, since the Cap and Reduce program cannot generate funds, the Compliance Instruments cannot be sold or auctioned to entities.  Thus, there is no cost to be passed down, and end-users have no incentive to reduce their emissions.  This, therefore, seems to require that end-users are targeted and annually awarded a reducing number of instruments. This would impose on them an incentive to avoid emissions by switching to renewable energy sources.  The benefit to the upstream target is that it involves relatively few entities and is thus administratively easier to manage. In addition, the threshold for inclusion of entities within the program can be relatively large (conventionally 25,000 metric tons of carbon dioxide equivalent emissions) assuming that the fossil fuel importers are charged for the emissions resulting from the end-use combustion of the fuel.

However, if the program targets end-users, the threshold for inclusion will necessarily be much lower, possibly in the region of 100s of tons of CO2e emissions.  This will likely then result in both small businesses and individual households being included.  This raises two problems: (1) these entities will then need a mechanism for calculating their emissions and demonstrating reductions over time, and (2) the administrative complexity will increase exponentially.

SOCAN Comments on 6 Technical Workshops.

1 – 3 SOCAN Comments on DEQ Tech W’kshops 1 – 3

1- 4 SOCAN Comments on DEQ Tech W’kshops 4 – 6

SOCAN Comments on 3 Town Halls.

SOCAN Comments to DEQ Town Halls

Videos and information from the Technical Workshops and Townhalls can be found on the DEQ Greenhouse Gas Programs Page

08/21/2020 Updates

In response to Governor Kate Brown’s EO 20-04 establishing the Oregon Climate Action Plan (OCAP), the statewide coalition, led by Renew Oregon, Oregon Environmental Council, and Climate Solutions is coordinating the statewide climate activist response and engagement in agency actions and rule-making.

They have established 7 ‘tables’ (teams):

Cap & Reduce
Construction / Building Codes / appliance efficiency
Clean Energy and the Public Utilities Commission
Natural & Working Lands
Public Health
Environmental Justice/ Impacted Communities

Each of these tables is facilitated by a content co-leader and a social justice co-leader. Within each, there seems to be a ‘policy group’ and a ‘grassroots group.’  The former is the smaller team that focuses on interactions with the relevant agencies while the latter serves to communicate with statewide organizations interested in this process.

So far, the Cap and Reduce table has begun engaging with the Department of Environmental Quality on this issue.  DEQ is holding a series of 9 four-and-a-half-hour public ZOOM hearings each addressing one aspect of the issue.  These are preceded by coalition discussions of issues to raise.

Within the Natural and Working Lands arena, there is a policy team us scheduled to hold its first meeting on Monday August 24th, with a grassroots meeting on August 25th.  Interestingly, a parallel ensemble of organization representatives operating under the banner” Pacific Northwest Forest Climate Alliance’ has been discussing forestry and climate issues and is seeking involvement in / engagement with the coalition process.

Meanwhile, similar activities are occurring with the other tables.

08/06/2020 Updates

Under the leadership of Renew Oregon and a Steering Committee of climate activists, engagement with the agencies in the rule-making as charged to agencies by Governor Brown’s Executive Order 20-04 is occurring.  As discussed last month, the response is organized in a series of ‘Tables’ (teams) as listed below.

Cap & Reduce
Construction, Buildings & Appliance Efficiency
Clean Energy & the Public Utilities Commission (PUC)
Natural and Working Lands
Public Health
Environmental Justice and Impacted Communities.

Each Table (team) except the Environmental Justice Table has two co-leaders, one from the climate activist arena and one from the social justice arena.  This is designed to ensure that social justice is retained as a top priority in the recommendations of all policy groups. SOCAN representatives are engaged in ‘Cape & Reduce;’ ‘Transportation;’  ‘Construction, Buildings, Appliance Efficiency;’  ‘Clean Energy / PUC;’ ‘Natural and Working Lands;’ ‘ Public Health;’ ‘Environmental Justice and Impacted Communities.’  Most of these table teams have started interacting with one another and the relevant agencies, but it’s not too late to join the action if you are interested – email Alan.

07/05/2020 Updates

Most agencies charged by the Governor’s March 10 2020 Executive Order 20-04 with submitting a report by May 15th on the progress they have made, what they plan to do, and how public and stakeholder input will be sought, indeed have submitted reports. These reports are extremely variable, some display clear recognition of the issue and an enthusiastic willingness to take steps to meet the Governor’s goals. Others, meanwhile are very disappointing either in their claim that they are already doing everything required of them or arguing that they are not convinced they have statutory authority to do what the Governor charged them to do and suggesting they need Department of Justice advice.  Reports

Renew Oregon, which had taken the statewide lead on promoting legislation is now taking the lead on facilitating response to these reports and engagement in the rule-making that will occur over the next year or so.  They are establishing a series of what they call ‘Tables’ but we can think of as ‘Teams’ to collaborate in seven areas:

The plan is to have each team led by two individuals, one with expertise in the specific issue, and another representing the social justice arena.  It is felt that this will ensure the social justice element is not overlooked in any team. SOCAN activist are interested in several areas, notably Natural and Working Lands, but also Cap & Reduce, Public Health, and Food Waste. However, it is evident from the list that food waste is not on any Table. Maybe our local Emerging Futures folks would be interested in taking a lead in that area.

Most recently, SOCAN has collaborated with Hogan Sherrow from ROCPAC and Joseph Vaile from KS Wild in developing a response to the rather disappointing Oregon Department to Forestry report. Along with the same two local activists, we (Alan Journet) recently attended a ZOOM meeting of the Pacific Northwest Forest Climate Alliance which seems to be taking the lead in addressing forestry issues.

Individuals interested in engaging in any of the areas depicted either by the agency reports or the Tables listed above, contact Alan who will link you into the teams.  To counter the constant campaign that climate action is just a Portland or Urban Oregon effort to impose their will on the rest of the state, and demonstrate rural Oregonians are as concerned as urban Oregonians, it is critical that we are involved in this process.

06/7/2020 – Updates

Directing State Agencies to Take Actions to Reduce and Regulate Greenhouse Gas Emissions

The Governor’s Executive Order (EO 20-04) was signed on March 10.
Executive Order 20-04 | SOCAN Summary.   The SOCAN May 2020 monthly meeting was devoted to a discussion of the Executive Order.  A video of that program is available on the SOCAN You-tube Channel page.
The Governor charged state agencies with a series of tasks and deadlines. The primary charge was to submit a report by May 15th outlining how the agency plans to move forward to address its charge in the EO (reports submitted as of Jun 5). DEQ was charged with presenting a preliminary report by May 15th identifying how it plans to engage public input. Public comment on this is due June 15th; final report due June 30th.

The final DEQ public webinar on the DEQ proposal to address the Cap & Reduce charge was Monday June 9 from 5:00 – 6:30pm. This is worth attending if you have any interest in understanding what DEQ is doing.

SOCAN has expressed interest in working in (1) The DEQ Cap & Reduce arena ensuring that the plan targets greenhouse gas emissions not just carbon, (2) Reducing Food Waste (Catie Faryl), (3) Natural and Working lands encouraging appropriate efforts in the arena of reducing emissions and promoting carbon capture and sequestration through forestry and agriculture (Alan, Gary Clarida, Ray Seidler), (4) Health (Ken Deveney.)

We envision collaborating on the Natural and Working lands issues locally with KS Wild, Our Family Farms (OFF), Rural Oregon Climate Political Action Committee (ROCPAC), and particularly with other statewide rural organizations such as Eugene-based Oregon Climate & Agriculture Network (OrCAN), Portland-based Cultivate Oregon, and possibly with Oregon Wild, the Center for Sustainable Economy, 350 Deschutes and others with forestry interests.

If you are interested in joining these efforts see 5/26/2020 updates (below). Contact Alan Journet for additional information.

5/26/2020 – SOCAN Monthly Meeting: Where are we and where do we go from here?

Sign up to take action on the Oregon Climate Action Plan

Engage in Agency rulemaking

Promote the Executive Order in Conversations

Support the Executive Order in Letters to the Editor & Legislators

Encourage local representative bodies to support action

Join SOCAN activities in support of the Executive Order

04/29/2020 – Current Actions:

Renew Oregon, which led the statewide effort to gain passage of a legislative proposal, is adjusting its focus now to serve as a conduit for ensuring that the Oregon Climate Action Plan comprises rules that genuinely will serve the state’s need to reduce emissions.  This includes advising the agencies as they develop rules to assure that meaningful emissions reductions are achieved.  Anyone interested in guiding the rule-making should contact Alan Journet who will connect folks with Renew Oregon.  SOCAN is particularly interested in engaging to:

  1. Ensure that the program targets greenhouse gases, not just carbon (see The Carbon Mistake).
  2. Promote efforts in our natural and working lands to stimulate their capacity to capture and store carbon.

04/27/2020 – Sign The Pledge of Support:

Oregon residents wishing to support the Governor, endorse the actions in the Executive Order, and commit to assisting their achievement should visit the Renew Oregon website and sign the pledge.

03/10/2020 – OCAP: The Plan

For many years the Statewide coalition of climate organizations, led by Renew Oregon, has been working with legislators to develop and pass a bill that establishes a meaningful trajectory for the reduction of  statewide greenhouse gas emissions.  Most recently, in 2019, the Clean Energy Jobs Bill was HB 2020.  In 2020, the bill was SB1530.   In both these sessions, passage of the respective bill was thwarted by Republicans walking out. In both sessions, they walked out of the Senate Chamber, but in 2020, they also walked out of the House Chamber.  In the 2020 short session, only three bills received a vote while some 40 bills, some bi-partisan,  that had been worked on in committee for several weeks were left in incomplete and unaddressed limbo. A discussion of the twenty or so bills that were ready to go and that these Republican shenanigans killed during the 2020 session can be found in The Oregonian.

Since the Governor had made a commitment to establish a climate action plan in 2020, the Republican effort to undermine democracy left her with one option – to sign into law an Executive Order that established as effective a statewide plan as she has the authority to establish.

On March 10, 2020, Governor Brown signed Executive Order 20-04.

Prior to the Governor’s signing of this order, Oregon Greenhouse Gas emissions reduction efforts were established by HB3543 in 2007.  This identified the state goals as 75% below 1990 emissions level by 2050.  As discussed below, EO 20-04 immediately increased that goal to 80% below 1990 levels by 2050.

A 3-page summary of the Executive Order is available from the Oregon Environmental Council .


Executive Order 20-04 will:

1 . Reduce greenhouse gas emissions to 45% below 1990 level by 2035 and 80% below 1990 levels by 2050.

2.  Cap and reduce emissions from stationary sources according to the trajectory identified above.

3.  Cap and reduce emissions from transportation fuels according to the trajectory above.

4.  Cape and reduce emissions from all other liquid and gaseous fuels, including natural gas, according to the trajectory above.

5. Increase the rigor of the Clean Fuel Standards to reduce greenhouse gas emissions per unit of fuel energy combusted to 20% below 2015 levels by 2030 and 25% below 2015 levels by 2035

6. Promote electrification. Cape emissions from stationary sources (industrial and utility emitters) according to the overall trajectory indicated above.

7. Regulate methane emissions fro landfill operations

8.  Reduce food waste

9.  Promote Building Code provisions that increase the energy efficiency of new construction.

10. Require the Oregon Department of Energy to update energy efficiency requirements of an array of products sold in Oregon

11. Require the Department of Administrative Services to consider greenhouse gas emissions in procurement notably aiming for  zero emissions vehicles.

12. Support Metropolitan Planning that reduced Greenhouse gas emissions

13. Support electrification

14. Direct the Oregon Health Authority to assess the public health impacts of climate change.

15. Direct the Oregon Global Warming Commission to submit a report on methods of promoting carbon sequestration in natural and working lands.

16. Require state agencies to prioritize actions that will help vulnerable populations and impacted communities adapt to climate change; and consult with the Environmental Justice Task Force when evaluating mitigation and adaptation priorities and actions

A slightly longer though still brief but excellent summary of EO 20-04, written by Renew Oregon’s Zach Baker, is available here.

Because the Governor lacks authority to establish a program that raises revenue, several features of  SB1530 were necessarily missing.   While the goals are statewide, tactics to reduce emissions are different for different areas of the economy.  Rather than targeting stationary sources emitting over 25,000 metric tons of greenhouse gases, the order targets all stationary source emitters.   Since there is no auction of allowances, there can be no allocation of free allowances for Emissions Intensive, Trade Exposed (EITE) industries or for utilities to reduce the cost of electricity for low-income Oregonians.  Finally, because there is no auction of allowances, there is no generation of investment funds to invest in rural and coastal Oregon and  target support for the Tribes and vulnerable and impacted communities.  Ironically, because they walked out, Republicans thwarted passage of a bill that addressed most, if not all, of the real concerns they raised.