Verde’s Position on HB 2020: Oregon’s Cap-and-Trade Program Fails to Address Harms to Frontline Communities

After careful consideration, Verde has determined that we cannot support HB 2020. While we appreciate the hard work legislators and other advocates put into the bill, especially to create elements centered on frontline communities and workers, we have concerns that the HB 2020 does not sufficiently address the potential harms it may cause to or exacerbate for those communities. We do not find that benefits and burdens of Oregon’s future cap-and-trade program are equitably balanced. Click below to read our full statement.

Verde stands ready to continue to provide analysis through an environmental justice lens throughout the future of the cap-and-trade program and we will hold policymakers accountable. Oregon must do right by its frontline communities. The following policy and program recommendations will forward this aim. Current aspects of the climate program that should be maintained or expanded include:

  • A declining cap on emissions.

  • Allocation of 40% of the Climate Investment Fund to impacted communities and 10% to tribes.

  • Few exemptions: marine, aviation, and railroad fuel — and a potential phase in of all of the aforementioned pollution sources—emissions attributable to landfills, cogeneration facilities operated by public universities or the Oregon Health and Sciences University, and fuel importers below a designated threshold.

  • Strong labor and procurement standards, derived through input from labor advocates.

Future modifications to the program should include the following:

  • A cap that achieves ‘net zero’ by 2050 with interim targets that help ensure a strong trajectory.

  • Ensure that governing bodies are vested with meaningful authority to make changes to the program and set policies.

  • A comprehensive study of market supply and demand balance, including the effect of current free allowance schema, as a precursor to rulemaking; continued monitoring and adjustment throughout the program must follow.

  • Excluding aggregation of multiple entities by a single holder.

  • Limitations on banking or carrying forward allowances including progressive cap adjustments that account for or retire a certain number of allowances in private holding to ensure continued and meaningful reductions throughout the program.

  • If Climate Investment Fund dollars are fully spent for tribes and impacted communities, an increase in the allocation along with funding prioritization for the full duration of the program (no sunset).

  • Expansion of the Highway Trust Fund to fund projects through the Transportation Decarbonization Investment Account such as transit, the transition of medium-, heavy- duty and off-road diesel vehicles, solutions to expand transportation options for rural or environmental justice communities, and relief for transportation burden; regular transportation burden analysis may be necessary to help prioritize funding.

  • Eliminate offsets or reduce compliance allotments for offsets while increasing the share of offset projects that must have “direct environmental benefit” in Oregon; in order to support projects that would otherwise qualify as offsets, increase Climate Investment Fund allocations for tribes and natural and working lands and prioritize these projects.

  • Produce a report in advance of rulemaking that details the impact of removing the Energy Facility Siting Council CO2 emissions standards. Consider reinstating the standards or developing an alternative method to address emissions through the siting process. Future climate policy work should include:

  • A 100% renewable portfolio standard (RPS).

  • A climate authority or department grounded in environmental justice and governed by the Environmental Justice Taskforce (re-designated as a Commission) to ensure that Oregon’s climate, energy, and environmental policies lead with strong, community-focused analysis.

Future climate policy work should include:

  • A 100% renewable portfolio standard (RPS).

  • A climate authority or department grounded in environmental justice and governed by the Environmental Justice Taskforce (re-designated as a Commission) to ensure that Oregon’s climate, energy, and environmental policies lead with strong, community-focused analysis.