OEC & Partners Advocate to Strengthen the Climate Protection Program

July 16, 2021

Governor Kate Brown
Office of the Governor
900 Court Street NE, Suite 254
Salem, OR 97301-4047

Director Richard Whitman
Department of Environmental Quality
700 NE Multnomah St. Suite 600
Portland, OR 97232

Cc: Chair George and Members of the Environmental Quality Commission

Governor Brown and Director Whitman,

On behalf of the undersigned groups representing environmental justice, business, culturally-specific and climate advocacy organizations from across Oregon, we write to reiterate our concerns–and suggestions for strengthening–the Department of Environmental Quality (DEQ)’s draft Climate Protection Program (CPP) rule language.

Our organizations submitted the attached letter on June 25, 2021, as part of the written record following the sixth Rulemaking Advisory Committee (RAC) meeting, with the goal of providing constructive feedback and recommendations for revising the draft CPP rule language to maximize equitable outcomes, environmental integrity, and local economic benefits. Since then, the gravity of this rulemaking again came into sharp focus when extreme heat killed more than 110 Oregonians; scientific analysis found that the unprecedented heat wave would have been impossible without fossil fuel-driven climate change. This adds to the growing evidence that urgent action to address the climate crisis and rapidly reduce emissions is even more crucial than had been understood at the signing of EO 20-04.

Specifically, the June 25, 2021 letter urged DEQ to:

  • establish cap and emission reduction targets that are consistent with the best available science;
  • hold industrial polluters accountable for their emissions; and
  • ensure equity and environmental integrity in its proposed alternative compliance “Community Climate Investment” program.

The letter includes more than 20 organizational signers, including 10 RAC members, and is consistent with the comments and suggestions we have repeatedly expressed over the course of the CPP rulemaking process. Particularly given that these perspectives are shared among a diverse representation of RAC and community members, we expect DEQ to take those recommendations seriously and work to incorporate them into the rule language. We are therefore concerned about the lack of substantive changes in the most recent proposed updates to the rules, specifically with regards to the emissions cap and targets, the “Best Available Emissions Reduction” approach for regulating stationary sources, and the Community Climate Investment program.

We therefore urge DEQ staff and leadership to revisit our previous comments and make changes to ensure that these consensus viewpoints are more adequately represented and integrated into the final rule language. We have attached our previous letter, which includes an updated list of additional signers, for reference.

If DEQ chooses not to incorporate changes, we request that agency leadership provide a written explanation of how those program design decisions were reached and an assessment of the resulting equity and emissions reduction trade-offs. We also urge DEQ to commit to transparent decision-making in the next phase of the rulemaking process–the public comment period–to provide assurances that the views of Oregonians are adequately represented and integrated into the final rule language.

Thank you for your time and consideration.

Affiliated Tribes of Northwest Indians * Beyond Toxics & NAACP Eugene/Springfield Climate Solutions * Columbia Riverkeeper * Democratic Party of Oregon * Douglas County Global Warming Coalition * Earthjustice * Environmental Defense Fund Green Energy Institute, Lewis & Clark Law School * Metro Climate Action Team * Native American Youth and Family Center * Natural Resources Defense Council Oregon Business for Climate * Oregon Conservation Network * Oregon Environmental Council Oregon League of Conservation Voters * Rogue Climate * Sierra Club * Sustainable Northwest Union of Concerned Scientists * Verde * Yamhill County * 350Deschutes * 350Salem

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