January 22, 2019
On January 22, the first day of the 2019 Legislative Session, Rhett Lawrence (the Oregon Sierra Club's Conservation Director) submitted a letter to Senate President Peter Courtney, Speaker of the House Tina Kotek, Senator Michael Dembrow, Representative Karin Power that details our Chapter's Policy Recommendations on Clean Energy Jobs Legislation.
Dear President Courtney, Speaker Kotek, Senator Dembrow, and Rep. Power,
Global climate change is the biggest environmental, social, and political challenge of our time. Unless we act immediately to curb emissions of heat-trapping pollutants, especially carbon dioxide and methane, we will be unable to mitigate the worst effects of this crisis: rising sea levels; mass plant and animal extinctions; an increasing scarcity of crucial natural resources; a greater frequency of extreme weather events; the spread of toxins, pests, and pathogens; widespread displacement of peoples; and unprecedented social upheaval.
You all know this, of course, and that’s why you have been so diligently working on the Clean Energy Jobs legislation for the last year and longer. As an organization with a long history of working to combat climate disruption, the Sierra Club also has a great interest in finding a comprehensive policy to account for the true costs of climate pollution. And while we recognize that no system is perfect and there are no silver bullet policies to solve the climate crisis, the Sierra Club supports cap-and-invest policies such as those being contemplated in the Clean Energy Jobs bill. Capping and pricing climate pollution can allow us to make necessary investments in energy efficiency and other cost-effective measures while providing real benefits to our state’s economy, people, and environment.
While we do not yet know the details of what the 2019 version of Clean Energy Jobs will look like, we are given to believe that the framework of ideas from the 2018 bills is an approximate starting point. If so, we expect that the legislation will again put a cap and price on climate pollution by making the biggest polluters reinvest in communities to grow the local, clean energy economy. The proceeds from these investments would then go to places struggling economically – rural, low-income, Tribal, and communities of color. And the carbon reduction potential from last year’s legislation was significant, with the likelihood of removing at least 500 million metric tons of pollutants from the atmosphere by 2050.
These would be real gains for our communities and for our planet, and they are worth pursuing. The Oregon Sierra Club believes that we can and should prioritize solutions that benefit all Oregonians, not just a select few. We believe that the Clean Energy Jobs legislation has the potential to do just that and we hope to be working to ensure its passage in the 2019 session. However, as you continue to craft the bill, we do have some recommendations for pieces we believe need to be in it for it to be truly effective and equitable:
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Interim targets: The policy and targets must be consistent with the best climate science and significantly reduce emissions with an economy-wide emissions limit that declines each year. And though the recent report from the International Panel on Climate Change suggests our current state climate goals may be insufficient, the legislation should include targets to reduce GHG emissions by at least 45% by 2035 and at least 80% by 2050, compared to 1990 levels. Given the urgency of the prognosis from the IPCC, a target of ZERO emissions from the covered sectors may well be warranted.
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Decision-making structure: We need one that is transparent, equitable, flexible, and accountable. Program design and implementation must be created and overseen by representatives of geographic and demographic diversity. All advisory and oversight committees should have an over-representation of historically underrepresented communities; the Environmental Justice Task Force, equity groups, and Sovereign Nation representatives must play significant and meaningful roles. Any effective program must have continuous monitoring and oversight to ensure both equity and environmental protections.
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Allowances: Utilities should not be given freely assigned allowances, and there should be no more than 25% free allowances for emissions-intensive, trade-exposed industries (EITEs). Any accommodation for EITEs should support in-state production, be needs-based only, be regularly re-evaluated, and be phased out altogether by 2030.
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Offsets: Offsets should be limited to Oregon-only projects, with a limit of 2%. The program must ensure that offset benefits accrue to Oregon communities, do not contribute to pollution “hotspots” in other states, and are only given for emissions reductions that would not have happened in the absence of the offset program. The program must prohibit the use of offsets for nuclear power, fossil fuel-generated energy projects, forest biomass energy projects, and incineration of medical and municipal waste. We must also ensure rigorous accounting methods to accurately assess the carbon sequestration impacts of offset projects, particularly for measures to increase carbon sequestration in forests, wetlands, rangelands, and agricultural lands.
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Allocation of Proceeds: Proceeds from the sale of allowances must prioritize investments in low-income, Tribal, and rural communities, and especially in communities of color. Resources need to be provided to minimize any adverse impacts of the program on fixed and low-income households. As with offsets, no proceeds should be used for nuclear power, fossil fuel-generated energy projects, forest biomass energy projects, or incineration of medical and municipal waste. Furthermore, all projects should pay a Exploring, Enjoying, and Protecting Oregon Since 1978 3 prevailing wage and comply with responsible contracting standards, fair labor standards, and Tribal Employment Rights Ordinances. In addition to programs supporting the clean energy transition for Oregon’s economy, it is important to devote proceeds to climate adaptation and resilience, especially support for local governments and communities.
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Exemptions: There should be no new explicit exemptions from the program and every polluter should be subject to the cap. Any previously existing exemptions, such as those for aircraft and marine fuels, must be closely scrutinized so as not to undercut the overall goals of the program. Furthermore, any attempt to exempt the proposed Jordan Cove LNG terminal from coverage in the legislation – or to consider it an EITE – must absolutely be denied; if built, it would be far and away the state’s greatest GHG emitter and would singlehandedly wreck our climate goals.
Ultimately, the solution to our climate woes is to transition off dirty fuels to efficient and renewable energy. Capping and pricing pollution and accounting for the true costs of carbon and other greenhouse gases are the most effective and efficient ways to incentivize the market to cut climate pollution while growing Oregon’s economy. The Clean Energy Jobs legislation can get us there if we do it right; we think the above recommendations can help us do so and we ask you to take them into consideration.
Thank you very much for considering our comments and please do not hesitate to contact me if I can be of further assistance to any of you.
Sincerely,
