What would we do if we cared?

The policy recommendations section from the 2017 Oregon Global Warming Commission Biennial Report to the Legislature:

Fixing State Climate Policymaking

Key Takeaways and Recommendations for the Oregon Legislature

The State’s climate policymaking machinery is not measuring up to the task of achieving GHG reduction goals and preparing the state for the effects of climate change. This failure is especially noteworthy for tasks not being informed by rigorous cost/benefit analysis, guided by agency assignments and benchmarks, and tracked for performance.

The Commission recommends that the Legislature direct agencies to collaborate with the Commission to set assignments (from the Commission’s Roadmap) and benchmarks, and to report annually to the Commission on progress or lack of progress, and reasons why.

The Commission further recommends that the Legislature provide the Commission with modest but sufficient resources – staff and budget – to enable it to discharge its responsibilities in a timely and efficient way, including its analysis, communications and tracking functions.

Statement of the Problem

Oregon ought to be a national leader in advancing sound climate policy, and in many respects it is – in energy efficiency, renewables deployment, and urban transportation. These interim successes make the failures and blank spots more galling and less forgivable.

While individual agencies have taken up both emissions reduction and adaptation issues episodically, the State has no overall climate change adaptation/preparation strategy, action plan or investment criteria.

In 2016 Oregon made decided progress in addressing electric utility greenhouse gas (GHG) emissions, [FN27] but continued diligence is required to ensure our utilities are not replacing their reliance on one fossil fuel – coal – with overreliance on another – gas – to a degree that would ensure failure to meet Oregon’s GHG goals. However, in the near- and mid-term, utilities face a need for resources that provide firm, on-peak energy. The challenge for utilities in pursuit of the state’s low-carbon future is the current limited availability of non-emitting or low-carbon resources and technologies such as energy storage to meet this need in a least cost and least risk manner.

[FN27 SB 1547, passed in the short 2016 session, commits PGE and [Pacificorps] to eliminating coal-generated electricity from Oregon’s mix by not later than 2035 (and mostly by 2030), and increases the State Renewable Portfolio Standard for these utilities in steps to 50% by 2040.]

Oregon has limited State funding for the critical elements of transportation greenhouse gas reduction: electric vehicles incentives and transit/bike/pedestrian infrastructure, equipment and operations.[FN28]

[FN28 Per ORS 366.514, 1% of annual gas tax revenues are dedicated to bike and pedestrian infrastructure.]

Oregon has insufficient understanding of the carbon contributions – credits and debits – of our forests29 and agricultural lands and activities.

[FN29: In 2016 the OGWC undertook to develop a basis for carbon accounting in Oregon’s forests, and that work proceeds, but slowly, reflecting again the absence of resources to proceed with more dispatch.]

Oregon doesn’t keep systematic track of, or seek to manage, consumption-associated emissions (e.g., waste management).

Oregon has no integrated state GHG policy on non-carbon/methane GHG’s (e.g., CFC’s, Ozone, N2O).

Oregon does not have a comprehensive current strategy for adapting to and preparing for the accumulating and already visible effects of climate change. Individual agencies and some communities have acted in this critical area, but their actions are isolated and often seriously dated.[FN30]

[FN30: In 2010 Oregon State agencies undertook a planning exercise that resulted in a published Framework for Climate Adaptation. There has been no further cross-agency work since; neither has there been any lookback review of whether any of the recommendations were acted upon, and with what outcomes.]

Oregon doesn’t have a cost- and consequences-driven agenda of the most effective GHG abatement measures apart from an extremely modest [FN31] and dated analysis. When legislators ask if we’re doing what’s cost-effective first, we answer formulaically that energy efficiency is our priority (but even that’s misleading since it’s true primarily for electric and gas utilities, and not for other critical sectors such as transportation).

[FN31: Oregon spent $50K of federal recession grant money on a “McKinsey” curve analysis [cost to reduce pollution] that left much to be desired when it was current, a condition it left behind years ago.]

The Oregon Global Warming Commission was established by the 2007 Legislature and empaneled by Governor Kulongoski in 2008. The Legislature gave the Commission broad statutory responsibilities [FN32] but no authority and no operating budget. While the statute directed all State agencies to “support” the work of the Commission, that support is always subject to existing agency priorities for staff and budget. As a practical matter, the OGWC has had to rely on its own sparse resources, principally volunteer experts and funding raised from foundations.

[FN32: 32 “The Oregon Global Warming Commission shall recommend ways to coordinate state and local efforts to reduce greenhouse gas emissions in Oregon consistent with the greenhouse gas emissions reduction goals established by section 2 of this 2007 Act and shall recommend efforts to help Oregon prepare for the effects of global warming. In furtherance of the greenhouse gas emissions reduction goals established by section 2 of this 2007 Act, the Oregon Global Warming Commission may recommend statutory and administrative changes, policy measures and other recommendations to be carried out by state and local governments, businesses, nonprofit organizations or residents. In developing its recommendations, the commission shall consider economic, environmental, health and social costs, and the risks and benefits of alternative strategies, including least-cost options. The commission shall solicit and consider public comment relating to statutory, administrative or policy recommendations.”]

These limitations notwithstanding, the Commission has provided significant value added to the State in numerous ways in its first eight years or so, often by acting as a stakeholder in prompting and shaping State agency work. At the end of this section we have provided a short list of the more important contributions made by the Commission.

Remedy: Agency Accountability for Climate Action

This state of affairs has many causes which need not be belabored here. The remedy could be some combination of comprehensive enforceable emissions standards, and/or a cap-and-trade mechanism or carbon tax. In addition, but especially in the absence of any of these, there should be assignments to State agencies of principal responsibility for implementing aspects of the OGWC Roadmap, together with intermediate progress benchmarks and a reporting process that includes reasons for making or missing benchmarks. Reporting is not the same as directing; there need be no displacement of existing board and commission authority, still less of legislative oversight, which would be better informed with the fruit of the reporting.

This would, however, require a collecting-and-evaluation function that could be housed within a staffed OGWC that is authorized to negotiate benchmarks with agencies and require annual progress reporting. Initially working from the Commission’s 2010 “Roadmap to 2020” (and revising as necessary), and with legislatively-adopted State emissions reduction goals [FN33] and adaptation/preparation needs, the Commission would:

  1. consult with the State agencies in assigning primary responsibility for specific Roadmap [FN34] recommendations (and climate change adaptation/preparation recommendations, when completed); jointly with agencies, develop benchmarks where appropriate, and assign;
  2. receive annual or biennial reports from the responsible agencies on progress on recommendations, or failure to make progress, and reasons for each;
  3. evaluate these reports against goals and needs, and integrate commission findings into its Biennial Report to the Legislature in advance of each long

[FN33: The 2007 Legislature adopted three emissions reduction goals: begin lowering emissions not later than 2010; be 10% below 1990 levels by 2020; and be at least 75% below 1990 levels by 2050. The OGWC subsequently recommended an interim goal: approximately 40% below 1990 levels by 2035.]

[FN34: “Interim Roadmap to 2020” Recommendations adopted by the OGWC October 28, 2010 and submitted to the Legislature as the Commission’s 2011 Biennial Report.]

The Commission could request (but not require) similar reports from other parties (e.g., cities; Metropolitan Planning Organizations), following where recommendations lead.

The Commission would have no authority to direct State agencies, intervene between the agency and its governing board or commission, or compel any action. The authority would only be to assign responsibilities and receive annual progress reports. Since agency reasons for failure to make progress are often lack of resources or authority, this process is as likely to provide support for an agency as to be critical of its progress while informing the Legislature of needs for implementation resources and tools.

Remedy: An OGWC Operating Budget and Resources

The Commission’s ability to evaluate the work of the agencies, and to consolidate the information into a form usable by the Legislature and Governor, is close to zero today. The Commission’s ability to pursue a substantive agenda – for example, the Forestry Carbon Accounting project now underway – is challenging, requiring almost entire reliance on the availability of volunteered expertise and without funding to support even minimal professional analysis. In particular, the Commission’s inability to apply systematic cost/benefit analysis to the range of emissions reduction strategies and adaptation planning choices available to the state is costly and crippling.

The Commission is (ably) supported by ODOE at a 1/3 FTE level when there is not a pre-empting demand for that person’s time and expertise. [FN35 The Commission has no independent funding to contract for technical expertise, and no budget for communications [FN36] or citizen involvement.

The 2017 Legislature could elect to provide a small budget for minimal staff support (an Executive Director and a staff support position) and for a level of technical analytic support sufficient to review agency reports and perform independent analysis (e.g., of the economic feasibility and cost-efficiency of alternative approaches to GHG abatement).

[FN35 For example, for much of 2016 OGWC’s staff support was seconded to ODEQ to assist in producing a “carbon market mechanism” report required of ODEQ by the Legislature. The task was aligned with the work of the OGWC, but necessarily required deferral of elements of the OGWC’s own chosen agenda.]

[FN36: The OGWC web site was designed and constructed with private foundation funding solicited by the Commission. It has no funds to maintain even site security, and still less to use the site to actively engage Oregonians in State climate policymaking or planning, or provide access to means for Oregonians to reduce their carbon footprint or prepare for the effects of climate change.]

Summing Up
  • Oregon’s GHG emissions are not under control, and both GHG abatement and preparation for impending climate change need systematic, not random and opportunistic, attention.
  • Not all, or even the largest part, of Oregon’s GHG emissions are from utilities. The largest, and fastest growing such emissions are from transportation. Other sources (forests; agriculture) are unattended. A separate, cross-cutting function begs to be performed.
  • The Legislature and Governor need systematic, carefully evaluated reporting from State agencies and the Commission on where progress is being made (and why), and where it is not (and needs attention from policymakers). They need to be provided this information in context, so they can distinguish between the immediate and the important, understand what their policy choices, and be informed of the associated costs and consequences as they consider different.

The Oregon Global Warming Commission needs at least the modest level of budget and staff support that would enable it to discharge the very broad range of responsibilities it has been assigned by the Oregon Legislature.