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A simple message to Clean Energy Jobs Bill supporters: This is not a comprehensive climate solution

By John Talberth, Daphne Wysham, and Nick Caleb

Climate change is one of the most daunting challenges humanity has ever faced and requires a commensurate policy response. A robust climate agenda would consist of a number of key interventions to holistically address the issue, including:

  • Ramping down all major sources of greenhouse gas emissions as rapidly as possible;
  • Making climate smart production the law not the exception;
  • Catalyzing wholesale changes in consumer behavior and public purchasing to scale up demand for goods and services with minimal carbon footprints;
  • Halting construction of new fossil fuel infrastructure;
  • Making a just transition to a 100% renewable energy and energy efficiency platform;
  • Divesting from the fossil fuel industry and redirecting those funds into sustainable alternatives;
  • Ensuring that communities most impacted by the consequences of climate change and risks associated with fossil fuel infrastructure and pollution are prioritized in adaptation plans and projects;
  • Halting the expansion of suburban sprawl and freeways and ensuring that we move as quickly as possible to public transit for all, and;
  • Rebuilding the resiliency of natural landscapes made vulnerable to climate change by bringing an end to industrial-scale forestry and agriculture practices and ensuring our land use practices enhance the drawdown—not the continued release – of carbon from the atmosphere.

Oregon’s Clean Energy Jobs (CEJ) bill barely scratches the surface of these problems. As such, it should not be hyped up as a comprehensive climate solution for the entire state economy, but explained for what it is – a limited experiment in creating some green jobs and generating public revenues through a market-based greenhouse gas reduction mechanism that will be applied to about 100 facilities and affect just a fraction of the carbon emissions attributable to production, consumption and trade activities in the state.

Most activities that pollute or undermine climate resiliency will be exempted.

What’s off the table as CEJ heads for the 2018 legislature? Any of the consumption-related emissions associated with purchases of goods and services by businesses, government agencies or consumers, for starters. The Department of Environmental Quality has been keeping track of consumption-related emissions for quite a while now, and they currently average over 75 million metric tons of carbon dioxide equivalent per year (75 mmt CO2-e/yr), substantially more than what is counted in the state’s official emissions inventory (62 mmt CO2-e/yr). Climate smart procurement standards for government agencies and businesses receiving public support would be one simple mechanism to begin to address this.

Concentrated animal feedlot operations and their methane emissions are off the table.

All land use activities are exempt. Despite being the number one source of greenhouse gas emissions in the state, the CEJ legislation exempts Big Timber and its industrial scale clearcutting practices. Not only are these practices carbon intensive but they also undermine climate resiliency by maintaining millions of acres in a degraded condition that is more susceptible to fire, insects, disease, flashfloods, landslides, water shortages and warm waters that kill salmon. Simple amendments to fold the timber industry into CEJ have been proposed, but not yet embraced.

Concentrated animal feedlot operations (CAFOs) and massive cattle herds are off the hook as well despite methane emissions that are over 86 times more potent for trapping heat than carbon dioxide. So too are chemical intensive agriculture operations, or developers who clear valuable carbon sequestration lands for automobile dependent sprawl. Globally, these land uses account for a quarter of all emissions. With so much of our state’s land base devoted to forestry and agriculture and with Oregon bursting out of its seams with new growth these exemptions mean a huge wasted opportunity for global leadership.

The proposal adopts the most limited scope of emissions to regulate.

Even on its own terms CEJ gets a “C” or less for completeness and rigor. There are many approaches in the proposed bills that reflect the low bar rather than standards set by science and best practice. Take the scope of emissions regulated at the few facilities that will be chosen to participate. Life cycle analysis (LCA) is the gold standard in scientific circles since it quantifies all the emissions attributable to an economic activity regardless of where they occur. Washington State’s Department of Ecology uses this approach in its environmental assessments conducted under its State Environmental Policy Act, and it has been embraced by thousands of corporate sustainability leaders worldwide.

At the other end of the spectrum is the ‘in-boundary’ scope that seeks to regulate only the emissions

Most emissions from the proposed Jordan Cove facility are off the table.

that occur within state boundaries. So a project like the proposed Jordan Cove liquefied natural gas (LNG) export facility – if constructed – would be off the hook for all the fugitive methane emissions stemming from fracked gas upstream and all the combustion related emissions in downstream markets in Asia. By opting for the in-state approach, CEJ will replicate a failure of greenhouse gas accounting at the national level and help mask emissions associated with fossil fuel exports – which have increased over 1000% since 2009 and now top 620 mmt CO2-e/yr. If Jordan Cove is constructed, Oregon will be contributing another 37 million metric tons a year to these off the books emissions. Oregon should do better and abandon the in-boundary method in favor of LCA whenever practicable not only for purposes of the CEJ but to be comprehensive in its annual greenhouse gas reports.

A growing number of loopholes and exemptions.

Another weakness comes from loopholes and exemptions for sources the legislation purports to regulate – electricity, industrial processes, and fossil fuels. All facilities that emit less than 25,000 metric tons of carbon dioxide per year are exempted. That’s equivalent to the annual emissions associated with about 5,700 passenger vehicles. The threshold should be much lower. In the Senate version of the bill, the semi-conductor industry is exempted through at least 2025.  Marine and aviation fuels are exempted. And the exemptions and loopholes continue to grow with each new version of the bill. The most recent iteration of the legislation will allow any polluter deemed to be ‘trade exposed’ to receive 90% of their pollution allowances for free with no firm date as to when they will have to start bearing the costs of that pollution.

Failure to halt the expansion of fossil fuel infrastructure.

Another key omission from CEJ is the issue of new fossil fuel infrastructure. The scientific consensus is to leave all undeveloped reserves in the ground, and a ban on new fossil fuel infrastructure is the appropriate policy response along with a commitment to a 100% renewable energy platform. The City of Portland led the way in 2016 and 2017 through its Fossil Fuel Terminal Zoning Amendments and 100% Renewable Energy policy (and Portland called on the State of Oregon to set 100% renewable energy goals). In January, 2018, the Oregon Court of Appeals affirmed the city’s Constitutional authority to prohibit new fossil fuel infrastructure to protect the health and safety of residents. Senator Merkley is a strong proponent for both policies and introduced legislation in Congress in 2017 to this effect. CEJ can easily be amended to scale up Portland’s success and follow Senator Merkley’s leadership on these issues.

Inadequate safeguards to prevent fraudulent offset projects.

And then there is the issue of offsets, which allow polluters to keep polluting and, ostensibly, pay for more cost-effective emissions reductions elsewhere. Offsets are often embraced as win-win solutions for climate and improved agriculture and forestry practices but in reality are replete with perverse incentives and a failure rate so high that the GAO and researchers for the European Union have warned climate policy makers off. Offsets trade emissions reductions that can be achieved with certainty for ones that only have a probability of success – and a low one at that if you read the details of the GAO and EU critiques. In the EU, a 2016 report found that 85% of the offsets purchased were not providing real, measurable and additional emission reductions.

Clearcuts often qualify for carbon offsets despite this practice being the number one source of emissions in Oregon.

Offsets are not only low probability but create the wrong incentives, as noted by a 2012 study commissioned by the National Bureau of Economic Research. You have to be doing harmful practices to get paid not to do them anymore – a textbook illustration of moral hazard. If harmful practices are incentivized, they will proliferate. Adverse selection is another perverse incentive. Polluters who are already planning to reduce emissions have an incentive to mask or delay these plans in order to get paid for doing it. A better system of incentives would be to reward those already practicing climate smart forestry and farming or implementing state of the art emissions reduction techniques to provide incentives for them to expand their holdings and operations.

If offsets are retained, then CEJ should at least adhere to principles of good governance, which would allow citizens free access to information about who is buying them, who is selling them, what the arrangements look like and what the climate impacts are. Citizens ought to be provided opportunities for commenting on these projects and challenging them in court if experts they work with uncover fraud. A citizen’s suit provision would go a long way toward improving accountability in the offsets market.

Lack of safeguards to ensure that climate investments are made wisely.

While CEJ is laudable for generating considerable public revenues (~$700 million a year) for green investments, proceeds are earmarked for three broad buckets without adequate sideboards to ensure that the public is getting the biggest bang for the buck and not having funds used for questionable purposes. For example, 20% of the funds will be earmarked for projects that “promote resiliency to disease and forest fires” – code words for discredited commercial logging projects on public lands under the guise of forest health and wildfire risk reduction.

Scientific studies over decades have shown that in most cases these logging interventions make matters worse. Commercial logging invariably increases carbon emissions and could easily make forests and watersheds less resilient instead of more resilient. The appropriate sideboard in this situation is to amend CEJ to bar use of Climate Investment Fund revenues for commercial logging projects and instead focus on climate smart forest restoration projects. These include road decommissioning, culvert replacement, prescribed fire prevention and weed removal, conserving roadless areas, and non-commercial thinning of dense tree plantations to expedite their conversion back into climate smart and resilient forests.

What we need is a solution that is fair, comprehensive, and scientifically rigorous.

Clearly,  Clean Energy Jobs is not a comprehensive climate solution. Though there are climate benefits to be gained from investments in green energy and resilience, the enormous exemptions, exceptions, allowances, and loopholes in current drafts of CEJ, ironically, create the possibility that the energy and effort our state will expend to implement this program could result in no net climate benefits for Oregon’s residents and another failure to meet a new round of climate commitments. And, while we wait for the program to be implemented (beginning in 2021), it seems likely that the legislature will adopt a wait and see approach until enough data has been generated to evaluate the successes and failures of the program. If our legislators and public are left with the impression that CEJ is a comprehensive strategy for tackling our largest carbon emitters– this legislation could delay and impede significant reforms in the forestry and agriculture sectors as well as efforts to prohibit new fossil fuel infrastructure and move aggressively toward a just transition to a 100% renewable energy powered economy.

Unless CEJ is amended significantly and the exemptions, exceptions, allowances, and loopholes enumerated above are addressed, the resulting program will not come anywhere near the type of comprehensive climate strategy we need from our leaders. Oregonians must insist that CEJ be transformed from what looks like the least we can do to something that is fair, comprehensive, scientifically rigorous, and in line with Oregonians’ passion for leading the way on all things green and sustainable.

Additional resources:

Fact sheet: major concerns with CEJ and ways to address them.

Proposed forestry amendments to SB 1070, 2017.

Position paper on no-new fossil fuel infrastructure.


climate legislation big timber

Report: Climate legislation must include Big Timber

climate legislation big timberCarbon sequestration dead zones are expanding. Clearcutting is Oregon’s single largest source of greenhouse gas emissions. Millions of acres of industrial tree plantations present huge public health risks because they are far more susceptible to fires, floods, unhealthy water temperatures and droughts than the natural forests they’ve replaced. But there are numerous options Governor Brown and legislators in Salem have to fix the problem and catalyze climate smart practices that can employ thousands of workers in the woods and enroll Oregon’s forests in the fight against global warming.

These are some of the key conclusions from a new Center for Sustainable Economy report conveyed to Governor Brown and legislators this week as they continue to deliberate options for moving ahead on climate change legislation in the 2018 session, which begins in early February.

The report –  entitled “Oregon Forest Carbon Policy: Scientific and technical brief to guide legislative intervention” – is a synthesis of scientific and technical information about the effects of industrial forest practices on climate change and climate resiliency and a discussion of legislative options for moving forward. It builds on a 2015 report published with Geos Institute that helped lead to a reconvening of the Commission’s forestry task force to revisit their assumptions – published in their Interim Roadmap to 2020 report – that forestry’s effects on climate were an unqualified benefit. Today’s report paints a drastically different story.

According to Dr. John Talberth, who authored the study for CSE, “Any climate change legislation moving forward would be seriously deficient without taking on Oregon’s largest carbon polluter and the number one threat to our water supplies, fish, and wildlife as climate change unfolds. Fortunately, there are multiple ways forward based on sound science, efficient markets, and fairness.”

The report reviews three legislative options. The first option is to include major carbon polluters in the timber industry as entities regulated under the proposed cap-and-invest bill – SB 1070 – now moving toward reconsideration in 2018. As it now stands, the timber industry is exempted. Proposed amendments to SB 1070 have been drafted and submitted to Representative Helm, Senator Dembrow, and other legislators, and have strong support from the environmental community.

The second is a carbon tax and reward approach that taxes emissions from clearcutting and short rotation timber plantations and uses funds to reward foresters who know how to log and leave a healthy forest behind. Legislation for this was drafted last year, but has yet to be introduced.

The third would require corporate forestland owners to develop and adhere to long term climate resiliency plans that set hard targets for accumulating lost carbon from the land. Carbon densities on industrial forestlands are less than a third of what existed before they converted native old growth forests into plantations. The Oregon Global Warming Commission is on record supporting the general approach of setting carbon density standards and targets.

“Inaction is inexcusable given humanity’s urgent need to draw down atmospheric carbon as fast and efficiently as possible, Talberth continued. “And passing legislation to flip industrial forest practices in Oregon to climate smart alternatives is one thing Governor Brown and legislators can do that has global significance.”


How Industrial Forest Practices are Subverting Oregon’s Climate Agenda

ccabClearcutting and use of forest chemicals and fertilizers on industrial forestlands could represent Oregon’s second largest source of global warming pollution and are subverting the State’s climate agenda by making landscapes more susceptible to wildfires, landslides, floods and warm waters that kill salmon. And despite legal requirements to do so, the Oregon Global Warming Commission has failed to track and evaluate the greenhouse gas emissions (GHG) from forest practices or follow through on commitments to develop and promote alternative management techniques that can transform these lands from a net source to a net sink for atmospheric carbon. The key culprit: a flawed international greenhouse gas accounting protocol that lumps all forest owners into one aggregate “forest sector” and allows the timber industry to take credit for carbon sequestered on forests protected by non-profits, small landowners, and public agencies.

These are the key conclusions of a new report released today by Center for Sustainable Economy and Geos Institute. The report – Clearcutting our Carbon Accounts – is an analysis of greenhouse gas (GHG) emissions estimated from State and private lands in western Oregon between 2000 and 2014. The report considered emissions associated with timber harvest, which removes carbon stored in forests for decades, clearcutting beyond the rate of forest regrowth and forest chemicals like Atrazine, 2,4 D, and Glyphosate. Oregon has 1.08 million acres less forest cover than it did in 2000 due to controversial clearcut forestry practices that not only degrade water quality, fish and wildlife habitat but also impede attainment of Oregon’s ambitious greenhouse gas reduction targets.

After taking into account carbon stored in longer lived wood products and carbon absorbed by residual forest cover, these emissions were estimated to be 9.75 to 19.35 million metric tons carbon dioxide equivalent (MMT CO2-e) per year. This represents between 16% and 32% of the 60.8 million MMT CO2-e “in-boundary” emissions estimated for the State by the latest (2012) GHG inventory. The timber industry’s operations on its lands in western Oregon are likely one of the State’s largest sources of GHG emissions – second only to transportation. According to Dr. John Talberth, President and Senior Economist at Center for Sustainable Economy, “Oregon’s climate agenda is taking a big hit from industrial forest practices. Yet decision makers continue to look the other way and buy the industry’s rhetoric that since they grow trees, the State should ignore their greenhouse gas emissions and look elsewhere to meet pollution goals for 2020 and beyond. The reality is that reducing the overall rate of timber harvest and promoting alternatives to clearcutting and chemicals are some of the most effective strategies for meeting Oregon’s emissions targets and will help rebuild our forests’ resiliency to fire, floods, and disease.”

In 2007, the Legislature adopted targets for reducing Oregon’s greenhouse gas emissions and charged the Oregon Global Warming Commission with developing strategies to achieve them. Yet the Commission, to date, only tracks emissions associated transportation, electricity use, natural gas use, agriculture, businesses and homes and ignores what happens on timber industry lands altogether. This is despite clear legislative requirements to track and evaluate emissions from all important sectors as well as “carbon sequestration potential of Oregon’s forests” and “alternative methods of forest management that can increase carbon sequestration and reduce the loss of carbon sequestration to wildfire.” Moreover, the Commission’s Roadmap to 2020 merely assumes that “Oregon’s forests are a carbon sink, capturing more carbon than they release. As such, Oregon’s forests and its forest sector have and will continue to contribute to the goal of achieving reductions in greenhouse gas emissions by remaining a robust and sustainable sector in Oregon.”

The CSE-Geos report tells a dramatically different story. According to Dr. Dominick DellaSala of Geos Institute, “Oregon’s clearcut forestry practices are polluting the climate with the equivalent emissions of over 2 million vehicles or 7 coal-fired power plants making forestry one of the biggest polluters in the State at a time when Oregon is seeking to drastically cut its global warming emissions. It’s time for forestry to be proactive like numerous other businesses in the State in being responsible for a safe climate and ecologically healthy future.”

The report was submitted to the Oregon Global Warming Commission, Governor Kate Brown, the Board of Forestry and key legislators. In a letter transmitting the report to the Commission, CSE and Geos have requested a meeting to review the report’s findings and begin the process of enrolling the timber industry in Oregon’s climate agenda.

Please click here for a copy of our report, “Clearcutting our Carbon Accounts.”

Please click here for a copy of the transmittal letter to the Oregon Global Warming Commission.

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