Alan R.P. Journet Ph.D.
Cofacilitator

Daniel Scotton
Executive Director

Southern Oregon Climate Action Now
August 25th 2025

SOCAN Comments regarding the Department of Energy Draft Oregon Energy Plan

Colleagues

We write on behalf of Southern Oregon Climate Action Now to express general support for the Draft Oregon Energy Policy but also to express reservations in four particular areas.

The Five Pathways reported below make very good sense and summarize valuable energy approaches. However, we note that item 4, Low Carbon Fuels should be Low GHG emissions fuels. This is because not all carbon is equal. For example, the Carbon dioxide equivalent of the C in methane to the C in carbon dioxide is such that each atom of C in methane (CH4) is much more effective as a warming agent than each C in carbon dioxide (CO2). Thus “On a 100-year timescale, methane has 28 times greater global warming potential than carbon dioxide and is 84 times more potent on a 20-year timescale” (EC undated). Meanwhile, The International Energy Agency (IEA 2021) suggested: “The Intergovernmental Panel on Climate Change (IPCC) has indicated a GWP for methane between 84-87 when considering its impact over a 20-year timeframe … and between 28-36 when considering its impact over a 100-year timeframe….” By trying simply to reduce carbon, actions might create a greater climate problem than if the target were to reduce greenhouse gases measured in terms of their carbon dioxide equivalent. It may be assumed as I have often heard when this language is employed, that ‘of course, everyone knows that when we identify low carbon, we mean, low carbon dioxide equivalent emissions fuel.’ We suggest that such an assumption is just naïve and will likely lead to uninformed legislators proposing policies that make matters worse.

1. Energy Efficiency Advance energy efficiency across buildings, industry, and transportation sectors, including by expanding access to and appeal of multimodal transportation options, to deliver the benefits of a more efficient energy system.

2. Electrification Increase electrification of end uses across the economy, including in transportation, buildings, and industry, while incorporating measures to safeguard reliability and support affordability.

3. Clean Electricity Invest in clean electricity infrastructure to maintain reliability and promote load flexibility to reduce system costs.

4. Low-carbon fuels Advance the use of low-carbon fuels in the hardest-to-electrify end uses to achieve GHG emissions reductions while maintaining industry competitiveness and a reliable electricity grid.

5. Resilience Strengthen resilience across all levels of the energy system, including utilities, communities, and customers, enhancing Oregon’s ability to adapt to climate change and mitigate other risks.

While there is much to appreciate, we are concerned about the guaranteed return to utility investors, identification of natural gas and biomass as clean/low carbon fuels and the suggestion that nuclear generation by small modular reactors as a reasonable emerging technology energy option in a clean energy policy.

Utility Investor Guarantee

At the core of this issue is the guaranteed rate of return that utilities are allowed to earn on infrastructure investments. Today, utilities secure roughly a 9% return—far above the true level of risk these investments carry—while passing costs directly to households and businesses. This structure rewards capital expansion over collaboration, and it leaves Oregon’s clean energy efforts vulnerable to utility profit motives rather than public need.

Ratepayers subsidize not only the repayment of utility borrowing but also investor profits, despite utilities facing virtually no risk of failure.
In comparison, a 3% return is considered the baseline for beating the market—making the current 9% guarantee excessive and misaligned with public interest.
The Energy Strategy itself identifies the “utility build-vs.-buy bias,” where utilities prefer to build their own projects rather than support community- or third-party-owned resources.
This bias has already stifled promising local initiatives, such as community solar farms in Southern Oregon, which could deliver both renewable generation and greater regional energy sovereignty.
Recent legislation, including SB 688 (OLIS 2025), has attempted to address these imbalances, but reforms to date remain partial and inadequate.

Oregon has an opportunity to correct this imbalance by tying utility rates of return to the 10-year federal treasury bond—a fair benchmark for low-risk investments. This reform would protect ratepayers from inflated costs, ensure utilities receive reasonable compensation, and free up resources for the urgent infrastructure upgrades our energy system requires. Most importantly, it would align utility incentives with Oregon’s climate goals, ensuring the Energy Strategy delivers more than words of encouragement.

The Biomass Boondoggle

SOCAN recognizes the role biofuels are expected to play in Oregon’s Energy Strategy, particularly in the transportation sector—the state’s largest source of greenhouse gas emissions (DEQ undated) and one of the hardest to decarbonize. While biofuels are often presented as a low-carbon substitute for fossil fuels, their climate benefit depends entirely on how they are produced, measured, and integrated into the energy system.

As indicated above, before it is possible to determine carbon neutrality of any product or activity, a full life cycle assessment must be undertaken. In the case of biofuels, this assessment must determine carbon dioxide emissions resulting from the nurturing of the biomass (i.e., emissions from the production, transport, and application of herbicides and fertilizers) to which we must add emissions from fuel combustion by equipment employed in the nurturing or harvest of the biomass and emissions from processing the biomass and transporting it to wherever it is burned to release energy. Full lifecycle assessment suggests that burning woody biomass is not greenhouse gas emissions neutral (e.g., SIG undated). Of course, when forested land is cleared to grow a crop, to these costs must be added the carbon in the cleared forest and the thwarted ongoing capacity of the forest to sequester carbon from the atmosphere (e.g., Liu et al. 2017). This concern is reflected in the comment reported in MIT (2020): “There are many challenges to making biofuels that are truly carbon neutral. That’s because many steps used to create biofuels—fermentation, the energy for processing, transportation, even the fertilizers used to grow plants—may emit CO₂ and other greenhouse gases even before the fuels are burned.” To assign biomass a free pass without such an assessment is a gross error. Regrettably, the Oregon legislature and Governor in 2015 seemed unaware of this need. Thus, Oregon is saddled with a statute that defies both science and sanity. Despite the 2015 legislative action, we would expect the Department of Energy to be better informed and incorporate into state energy policy the caution that biomass is more often not clean than it is.

It is, therefore, unfortunate that biomass is identified in the draft energy plan as a clean fuel. As reported by Simet (2015) in 2015 the Oregon Legislature passed SB 752 (OLIS 2015), and the Governor signed, this bill “that exempts biomass-derived carbon dioxide emissions from regulation under certain air pollution laws….” Then in 2017, the Senate passed SB634 (OLIS 2017) that sought to add woody biomass to this definition, though this bill was in committee at adjournment and thus didn’t pass. However, in contrast to the Oregon legislature’s uninformed decision, in reality, only full lifecycle assessment can reveal whether any fuel is genuinely carbon-free (i.e., climate pollution free) or low carbon (i.e., low in greenhouse gas emissions). It is certainly the case that when vegetation is burned, the carbon dioxide released from its combustion is carbon dioxide trapped from our current atmosphere rather than an atmosphere hundreds of millions of years ago and that photosynthesis will capture the carbon dioxide released, as IEA (2018) argued. Although this suggests we are not adding that historic carbon dioxide to our current atmosphere but simply cycling back the gas from our current atmosphere, such a simplistic perspective fails to recognize reality.

In the case of biomass burning PFPI 2025 noted: “biomass burning power plants emit 150% the CO2 of coal, and 300 – 400% the CO2 of natural gas, per unit energy produced.” This is because wood burning inherently releases more CO₂ than natural gas or coal per unit of energy generated from its combustion. GBPSR (2025) concur with this assessment suggesting: “Burning biofuels increases air pollution and pollution-related disease and creates climate-damaging greenhouse gasses at a time when scientists are telling us urgently to slash these emissions.”

For this reason, SOCAN supports only those biofuels that meet strict criteria for sustainability, efficiency, and life-cycle emissions.

Food security: Protections must ensure that biofuel production does not divert farmland away from food or trigger deforestation and habitat loss. Waste-based feedstocks—such as garbage, wastewater, manure, and food waste—offer promise, but safeguards must be in place before large-scale adoption.
Energy return on investment: The state has not sufficiently addressed the balance of energy required to produce biofuels versus the energy they deliver. Analysis from Oregon’s SB 334 report suggests the need for rigorous feasibility studies to ensure production yields positive net energy.
Lifecycle greenhouse gas assessment: Programs like the Clean Fuels Program and Climate Protection Program already recognize the need for well-to-gate lifecycle analysis. SOCAN insists that all biofuels must demonstrate clear reductions in carbon intensity compared to fossil fuels.
Air quality co-benefits: Research shows that substituting diesel with natural gas in heavy-duty engines can dramatically reduce pollutants such as CO, NOx, and particulate matter, indicating that biofuels, when properly sourced and applied, can yield measurable health benefits.

Oregon should move forward with biofuels only under strict, enforceable standards that protect food supplies, ensure positive net energy, and prove measurable life-cycle emission reductions. Without these conditions, biofuels risk becoming a costly detour rather than a genuine climate solution. With them, Oregon can responsibly integrate waste-based biofuels into its energy mix while advancing both environmental protection and community health.

We urge the Department of Energy to avoid succumbing to and legitimizing the false claim that biofuel is a clean energy source unless this is demonstrated for each project claiming such.

The Natural Gas Fraud

The myth that natural gas is a ‘clean fuel’ has been promoted by gas utilities for years (e.g., McCabe 2022) to defend their ongoing business model of expanding natural gas usage even though it has been demonstrated time and again to be a false claim. Although the combustion of natural gas produces far less (maybe 50%) of the carbon dioxide emitted than when coal is burned to produce the same amount of energy (eia 2024), this fails to account for the methane emissions that leak upstream as the gas is extracted, processed, and transmitted through pipelines and their compression stations. Indeed, in a recent summary of methane emissions from natural gas usage (MIT 2023), this value was reported to be as high as 9% in some cases. This source noted that while methane comprises some 70% of raw natural gas, by the time it is processed, the methane content rises to some 95%. As noted above, assessments of the carbon dioxide equivalent, or Global Warming Potential of methane suggest that it is much worse than carbon dioxide. Indeed, as reported by the Intergovernmental Panel on Climate Change on their Assessment Report 6 (IPCC 2021) on a 100-year basis, methane is some 29.8 times worse than carbon dioxide, while on a 20-year basis it’s 82.5 times worse (values tabled in Sproule 2021).

Many years ago, Howarth (2014) discussed research from his Cornell Lab (e.g., Howarth et al. 2011) that revealed “For conventional natural gas, we estimated a range of methane emissions from 1.7% to 6% (mean = 3.8%), and for shale gas a range of 3.6% to 7.9% (mean = 5.8%)” Howarth (2014) also reported that the break-even point for the natural gas fugitive emissions is 2.8% (range 2.4-3.2%) meaning emissions above this value make the gas worse than coal. This implies that shale fracked gas is always worse than coal, and a substantial proportion of conventionally extracted natural gas is also worse than coal. More recently, Ciesielski (2024) reiterated the Howarth findings while, in a more recent analysis, Gordon and Hughes (2023) reported “Methane leakage as low as 0.2 percent puts gas’s climate impact on par with coal.” Gordon et al. (2023) reported similar conclusions.

The point is that designating natural gas as a low-carbon or clean fuel is a travesty of the current science.

The Nuclear Conundrum

Stimulated substantially by the nuclear power industry itself, but also by the proposals contained in the anti-science Heartland Institute’s Project 25 (Dans and Groves 2023), there has recently been a resurgence of interest in nuclear electricity generation as a rational option in a clean energy economy. Many Oregonians unfamiliar with the issue, including some with climate or other environmental concerns, have been attracted by this is unfortunate development. It was with some surprise that I discovered deep in the draft, (not mentioned before Clean Energy Action 3 on p. 72) reference to small modular nuclear reactors as an emerging technology that, presumably, could be explored by DoE as a component of a clean energy future for Oregon. The bottom line for nuclear power is, as Sovacool (2021) has concluded, the lead time necessary to bring nuclear power plants online compared to that for renewable generation, indicates that, unlike renewables, nuclear generation is unlikely to be capable of addressing the climate crisis in the time necessary. Indeed, Plummer (2025), writing for Forbes Magazine, offered the following economic assessment:

“According to the U.S. Energy Information Administration, the LCOE for advanced nuclear power was estimated at $110/MWh in 2023 and forecasted to remain the same up to 2050, while solar PV estimated to be $55/MWh in 2023 and expected to decline to $25/MWh in 2050. Onshore wind was $40/MWh in 2023 and expected to decline to $35/MWh in 2050 making renewables significantly cheaper in many cases. Similar trends were observed in the report for EU, China and India.”

Small modular nuclear reactors would be employed at the expense of Oregon utility consumers.

Stanford University environmental engineer, Mark Z Jacobson (Jacobson 2019), long a researcher in the energy arena, reported that “New nuclear power plants cost 2.3 to 7.4 times those of onshore wind or utility solar PV per kWh, take 5 to 17 years longer between planning and operation, and produce 9 to 37 times the emissions per kWh as wind.” This author also noted: “…a fixed amount of money spent on a new nuclear plant means much less power generation, a much longer wait for power, and a much greater emission rate than the same money spent on WWS [i.e., Wind, Water or Solar] technologies.” The economics of nuclear generation have not changed since that analysis was published. Jacobson (2019) also countered the myth often propounded by nuclear proponents that nuclear power is a zero-emissions energy source with the assessment that “Overall, emissions from new nuclear are 78 to 178 g-CO2 /kWh, not close to 0.” Again, nothing has changed since then; nuclear power is still the most expensive and delayed method of reducing emissions from electricity generation.

As I have argued and justified elsewhere (Journet 2023), nuclear proponents seem to base their support for nuclear generation on one or more of three false premises:
1) There is insufficient renewable energy available to meet global energy demand,
2) Nuclear generation is free of greenhouse gas (carbon) emissions,
3) Nuclear generation is safe.

The falsification of any one of these three premises should be enough to negate the nuclear option. However, since all three are false, the myth of a nuclear option should be firmly rejected without any waste of taxpayer funds invested in its further exploration; these are funds that could be used to explore worthwhile options

In addition, in relation to Small Modular Nuclear Reactors, proponents again propound myths, that Lyman (2024) evaluated:
1. SMRs are not more economical than large reactors.
2. SMRs are not generally safer or more secure than large light-water reactors.
3. SMRs will not reduce the problem of what to do with radioactive waste.
4. SMRs cannot be counted on to provide reliable and resilient off-the-grid power for facilities, such as data centers, bitcoin mining, hydrogen or petrochemical production.
5. SMRs do not use fuel more efficiently than large reactors.

Finally, previous nuclear proponent Gundersen (2025) concluded:

“With SMRs, you get all the risk and complexity, but at even higher costs per unit of energy, due to the loss of economies of scale. That is why nuclear power has never been financially viable. Every plant built in the U.S. required public subsidies, and every attempt to reduce unit costs by increasing reactor size, designing the plant in factory modules, or eliminating safety features has ended in disaster or disappointment.”

In summary, Oregon’s Department of Energy should not fall for the nonsense propounded by proponents of small modular reactors that these comprise an emerging technology rather than an irrelevant diversion from the path to a genuinely and economically viable clean energy.

Respectfully Submitted

Daniel Scotton, Executive Director
Director@socan.eco

Alan Journet Ph.D. Cofacilitator
alan@socan.eco
541-500-2331
541-301-4107

Southern Oregon Climate Action Now

7113 Griffin Lane
Jacksonville
OR 97530-4182

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