Strengthening Oregon’s Climate Protection Program

The Oregon Department of Environmental Quality (DEQ) is getting closer to finalizing rules for a new Climate Protection Program. Over the past year, DEQ has made a number of positive changes to strengthen the rules; however, a few key policy design features still hang in the balance. 

The Climate Protection Program aims to address the effects of climate change by capping and cutting greenhouse gas emissions from Oregon’s top polluting sources: transportation fuels, natural gas, and large industrial emitters. A well-designed Climate Protection Program provides Oregon a vital opportunity to demonstrate leadership and make progress in the fight for a healthy climate future. The time for bold action on climate is now.  Weigh in and send a clear message to DEQ.

Our policy recommendations have been unwavering throughout this process: DEQ should maximize emissions reductions, equitable outcomes, and local economic benefits by creating a program that is based in the best available science, requires early emissions reductions, and holds major polluters accountable for their emissions.

Most recently, OEC joined more than 20 organizations–including 10 of our fellow Rulemaking Advisory Committee (RAC) members–in submitting joint comments expressing our concerns and recommendations for strengthening DEQ’s draft CPP rules.  

Here’s what we like about the current rules, and where we will continue pushing for strong protections for Oregonians in the final stage of the rulemaking process. 

What we like:

Matthew Henry | Unsplash

  • A mandatory declining cap on Oregon’s natural gas fuel suppliers (e.g. utilities) and transportation fuel suppliers (e.g. oil companies).
  • Lower emissions thresholds for fuel suppliers, meaning more oil companies will be held accountable for their pollution over the course of the program. 
  • Stronger safeguards to ensure environmental integrity and equitable outcomes under DEQ’s proposed Community Climate Investments (CCI), including necessary limitations to curtail overuse of CCIs and increased oversight to ensure that the CCI program is meeting its stated climate and equity goals. 

Where the program needs to be strengthened: 

Science-based emissions targets

  • The extreme cost of climate inaction has never been clearer: this summer’s climate-fueled extreme heat, widespread drought, and early wildfire season are just the latest examples of how climate change is worsening public health crises and costing Oregon taxpayers billions of dollars in health costs alone.
  • DEQ must follow the science and adopt a more stringent cap trajectory that cuts emissions 50 percent by 2030.

Polluter accountability 

  • Given that there are currently no climate regulations on major industrial polluters in Oregon, it is critical that DEQ’s Climate Protection Program hold these sources accountable. Unfortunately, the way the rules are currently written, emissions from stationary sources could increase under this program. That is unacceptable, and flies in the face of the program’s equity and climate goals.
  • DEQ must hold industrial polluters accountable to mandatory declining emissions reductions. Polluters should also be required to hire qualified third party auditors to identify a game plan to reduce their emissions and related co-pollutants on a timeline that reflects the urgency of the crisis and our state’s overall climate targets.

Equitable and climate-protective community investments

  • DEQ is proposing a novel alternative for polluters to comply with emissions reduction requirements: instead of reducing emissions directly (e.g. by electrifying or transitioning to lower-carbon fuels), polluters will be able to invest in projects that–if effectively designed–will reduce emissions and benefit Oregon communities disproportionately impacted by climate pollution and impacts. However, without greater clarity and direction in the rule language, it is possible that DEQ’s proposed “Community Climate Investment” program could allow pollution to continue unabated in frontline communities and break the overall emissions “cap.”
  • DEQ must provide greater certainty that these projects will achieve real, lasting reductions of emissions and co-pollutants, with at least a 1:1 reduction of emissions per credit. DEQ must also provide clear criteria about the types of projects that are eligible to ensure the greatest community benefit.

What’s next:

With just weeks remaining until the public comment period deadline on October 4th, we are running up against the clock for Oregon to take meaningful climate action. You can make your voice heard in one of three ways:

  1. Send a letter using OEC’s online action portal.
  2. Email comments directly to DEQ at
  3. Testify at one of the upcoming virtual public hearings on Sept. 22nd and Sept. 30th. 

With your help, we can make sure that the Climate Protection Program lives up to its name!

Karsten Wurth | Unsplash

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