Science-based GHG Reduction should be a Priority of Oregon’s Community Climate Investment Fund

Oregon’s Executive Order 20-04: Climate Protection Program is nearing its final round of changes and recently completed its public comment period on October 25th. The proposed program will reduce emissions from Oregon suppliers of gasoline, diesel, propane, kerosene and natural gas by 80% by 2050. While the program is similar to a typical cap-and-trade program by allowing regulated entities to trade and bank emission reductions, the program differs in a few ways, including omitting the use of carbon offsets. Instead of allowing carbon offsets, the proposed program will implement a Community Climate Invest Fund focused on environmental justice. As currently proposed, the fund lacks science-based requirements for quantification and verification and risks blunting EO 20-04’s ability to reduce greenhouse gas emissions.

The Community Climate Investment Fund allows for regulated entities to invest in the fund to receive a credit equal to reducing one ton of carbon dioxide equivalents with a limit on the number of credits the entity can use. The collected funds will then be distributed to DEQ-approved, non-profit organizations to invest in projects with a focus on Oregon communities disproportionately impacted by air pollution from the polluting entities. The goal of the fund is to help marginalized communities transition to a renewable economy so that they aren’t caught paying higher prices for electricity use in the future if they are unable to reduce consumption.  Potential project types include home energy efficiency improvements or truck electrification. Under the proposed rules, the investment will be $81/credit.

However, even though the credit allows a polluting entity to emit one ton of carbon dioxide equivalents for a payment of $81, there is guidance on quantifying that the credit equals one ton of emissions reduction from the project. Reducing greenhouse gas emissions is the priority of Executive Order 20-04 and the Oregon legislature’s ORS468A, which the executive order seeks to support. The DEQ should establish stringent, science-based quantification and verification requirements and protocols to ensure that one credit is equivalent to the one ton of carbon dioxide emission reductions. Otherwise, the Community Climate Investment Fund runs the risk of being characterized as elaborate greenwashing.

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