SOCAN Testimony to Environmental Quality Commission on Revised Climate Protection Program Rules 

Alan Journet, November 17th 2023

At its November 16-17 meeting the state Environmental Quality Commission approved rules for the administration of the Climate Protection Program (CPP) developed by the state Department of Environmental Quality (DEQ) based on recommendations from a Rulemaking Advisory Committee (RAC) composed almost entirely of energy industry representatives.  The CPP had previously been approved by the EQC and seemed likely to contribute substantially to forging a pathway for the state to reduce our greenhouse gas emissions sufficient to meet our fair reduction given global demands.  Regrettably, the rulemaking proposals represented a weakening of the program previously approved. As is often noted with state and federal program proposals: ‘The devil is in the details’ and the details are always the rules that are developed to allow administration of a program. In this case, the rules weakened the program in several areas, notable the industrial Best Available Emissions Reduction (BAER) rules, and the allowance for gas utilities regarding biomethane and hydrogen.  While the draft rules elicited over 2,000 public comments, the majority of which argued against the weakened rule proposals, the rules that were ultimately approved suggested that DEQ had succumbed to pressure from the fossil fuel industry rather than impose rules that are as rigorous as we need.  The following represent the brief written comments that I developed based on the prior stated allowance of three minutes for oral comments. Unfortunately, on the day this was reduced to one minute because of the number of potential testimonies.  I submitted the following to augment my 1 minute oral allowance:

“Good morning! My name is Alan Journet from rural Jackson County

“I retired in 2010 after teaching Biology for 30 years at Southeast Missouri State University and relocated to Oregon the same year.  It was teaching the Community Ecology section of a General Ecology course, several decades ago now, that stimulated my initial alarm about the threat of global warming.  As I was teaching community ecology, I realized that the climate projections then before us would be sufficient to destroy natural ecosystems (forests, woodland, grasslands, deserts, tundra) across the planet along with the biodiversity they comprise. My ecological understanding indicated that not only would our natural world, our ecological life support system, be destroyed by these changes if they came to pass, but our agriculture, forestry, and fisheries would be equally damaged.  I realized then, and still understand, that droughts, floods, hurricanes, and wildfires, serious as they are, are not the only threats we face. We are also undermining life on the planet as we know it.

“It was then that I vowed to explore climate science to assess its credibility.  Having convinced myself of that credibility, I then dedicated myself to educating folks about the science of global warming, the threat of its climate change consequences, and what we can do to address it.

“Thus, in 2012, I co-founded and still co-facilitate Southern Oregon Climate Action Now, an organization of over 2,000 Southern Oregonians concerned about the climate crisis.  It is in that vein that I testify before you today.

“The United Nations reported on November 14^th that signatories to the UN Framework Convention on Climate Change 2015 Paris Agreement are still not demonstrating the rapid downward trend in emissions that science says is necessary to direct our collective trajectory away from climate disaster.  Then, on November 15^th, the World Meteorological Union reported that the atmospheric carbon dioxide concentration is now 50% higher in the atmosphere than during pre-industrial times while methane continues to increase, and nitrous oxide increased more from 2021-2022 than ever it has done. Finally, the 2023 Nation Climate Assessment concluded that nationally we are experiencing the climate impacts of global warming in every region of our country and throughout our economy.

“Governor Brown’s Executive Order 2020-04 attempted to place Oregon on a reasonable statewide emission trajectory consistent with our collective global need.  In following this order, DEQ developed and the EQC approved a Climate Protection Plan that had a good chance of contributing substantially to achieving this goal.  We are now disappointed to learn that DEQ has proposed rules that substantially undermine that plan.  Advised by a RAC dominated by the very entities that are causing the problem, DEQ seemingly underestimated the plight we are collectively in and seems to have succumbed to fossil fuel corporate pressure to weaken the CPP. 

“If we don’t all wake up and do what we can to address this problem, we are doomed. Those needing to wake up include the public, fossil fuel corporate leaders, state agency personnel, and legislators.  When the DEQ undergoes its CPP review process, I urge them to remedy the giveaways to fossil fuel interests embedded in these rules.