September 14, 2021 - Week 25 Sine Die
Claudia Keith, Climate Emergency Coordinator, and Climate Emergency portfolio team: Julie Chapman, Shirley Weathers, Cathy Frischmann, Josie Koehne, Kathy Moyd, Robin Tokmakian, and Greg Martin
Climate Emergency Highlights & Priority Legislation (Claudia Keith)
IPCC Aug 2021 report: ‘Code red’ for human driven global heating, “warns UN chief, Climate change is widespread, rapid, and intensifying, and some trends are now irreversible, at least during the present time frame, according to the latest much-anticipated Intergovernmental Panel on Climate Change (IPCC) report, released Monday, (August 9, 2021).”
A major success, all three Climate Priority bills passed and the governor signed: HB 2021, 100% Clean Electricity, on July 27; “Oregon now has the most aggressive timeline in the country for clean energy transition.” Oregon Clean Energy Opportunity Campaign press release. (Find more details in the Clean Energy CE Leg Report.) HB 2842 A Healthy Homes, fiscal reduced to $10M, governor signed July 27, League Testimony. The third priority bill was HB 2475, The Oregon Energy Affordability Act, signed by the governor in May.
Several legislation priorities shared with NR Team died in committee: HB 2488 A, addressing climate justice through land use planning; fiscal $0.8M. SB 286 A, Climate and Environmental Justice; fiscal $3.6M (see NR Leg Report).
CE Budget Priorities: Most of the governor’s EO 20-04 OCAP Coalition budget items, which cover 10+ state agencies, are listed HERE. The League lobbied for Oregon Global Warming Commission funding, but it did not appear in the end-of-session W&Ms budget reconciliation bill. On a positive note, OHA was funded $45M vs. the $30M recommended by the governor for climate-related modernization. ( OHA Pkg 417)
CE sign-on letters and floor letters approved during this session:
SB 16 - Say NO on SB 16
SB 2475 A - Vote Yes on SB 2475, The Oregon Energy Affordability Act
2021 B - Broad Support for the 100% Clean Energy for All bill
The League will continue to collaborate as members or friends with OCN, Renew Oregon, NWEC OCAP and OCEOC to support Climate/Carbon policy.
Oregon Climate/Carbon Policy in the News
Pew Trust: “Oregon Climate Plan Is First in U.S. to Account for ‘Blue Carbon’ Benefits of Coastal Habitats: State strategy can serve as blueprint for others seeking to leverage ecosystems to lessen effects of climate change. Multiple climate change-driven tipping points for coastal systems.” EE News: 100% clean power faces litmus test with new Ore. Law. “Oregon leaps past California and Washington as legislators pass bill to decarbonize power grid by 2040 .” NRDC: The West Coast: Carbon Free by 2045 . . . or Earlier: Oregon Legislature Passes House Bill 2021, 100% Clean Electricity for All By 2040. (Guest Blog by Angus Duncan, previous chair of OGWC, currently PNW Consultant to NRDC). The Atlantic: How the U.S. could slash climate pollution by 2030. Portland denied the Zenith energy expansion certification. Jordan Cove LNG forfeits permits required for an export terminal. ACEEE: In 2020 Oregon tied as 9th in the nation for Energy Efficiency. U.S. Senate: Schumer says Infrastructure bills edge U.S. close to Bidens climate goals.
Mark your calendars
Attend as a League Observer, interested citizen, and/or view recorded agency and commission meetings, including new reports and studies.
ODF Climate Carbon Plan Updates
DEQ Climate GHG Program Updates
Executive Order 20-04 Directing State Agencies and Commissions to Take Actions to Reduce and Regulate Greenhouse Gas Emissions. The Oregon Climate Action Plan (OCAP) coalition was formed in spring 2020 and the League is one of over a hundred organizational members. This coalition was formed after Gov. Brown’s March 2020 Carbon Policy Executive Orders. A formal OCAP Coalition progress report was released March 2021. Find more information at the Renew Oregon site HERE. Find OCAP update interview on NPR HERE.
Find updates across many agencies on the State of Oregon “Action on Climate Change” topics HERE. Find weekly 2021 updates at Oregon Greenhouse Emissions Program web page HERE. DOE weekly blog updates HERE. New Oregon Dept of Energy (ODOE) Report HERE.
OEA : State of Oregon Office of Economic Analysis
Oregon Economic Analysis (OEA) staff’s recent favorable quarterly revenue forecast did not mention Climate Change risk. The League is concerned that this issue needs broader consideration related to future costs to the state, the effect on future revenue, insurance regulations, related population forecast assumptions, SEC reporting, etc. Find OEA materials presented to the Legislature and narrative report “Oregon Economic Forecast” HERE. Related, at the federal level the League supports the Climate Risk Disclosure Act. Senator Warren and Rep Carten are the Congressional sponsors and introduced the bill April 2021.
Related News: ‘Cities and states on the frontline of climate change aren’t always upfront about risks. Does the municipal bond market care?’. Tracking ESG regulation, “as disasters mount central banks gird against threat of climate change” - (From the Bank of England to the People’s Bank of China, officials of the world’s largest economies are gauging how climate change could rock the financial system). Brookings: ‘Rethinking climate finance to improve infrastructure resilience’. On a positive note, the approved federal Covid-related stimulus funds and recent Infrastructure funding bills moving through Congress will certainly begin to address some of these topics. A Just (economic/social policy) Transition approach to Climate is supported by the League.
Our Children’s Trust
New SCOTUS Supreme Court of the U.S. Precedent was Used in Bid to Amend Kids’ Climate Federal Case. The federal case is still active, Judge Aiken and Coffin recently presided over telephone conferences/hearings. Thomsen Trust: OPINION: 'Climate change threatens Americans' rights to life, liberty and property.’ Recent article in U.S. News & World Report: Tackling ‘Eco-Anxiety’ by Group Action‘: “Lawsuits filed by youth and young adults in the U.S. and Canada reflect growing anxiety over global climate change. In the U.S., Juliana (federal lawsuit) has had a convoluted past since it was filed nearly six years ago. After a series of stays, injunctions, motions and appeals, Juliana plaintiffs are engaged in settlement negotiations with the DOJ Department of Justice, as well as motions to file a second amended complaint, and a pending motion to intervene on behalf of 18 U.S. states led by Alabama as opponents to the original Juliana lawsuit.”
The Montana state climate case was ruled in favor of the kids earlier this month. MIT Press new Book ‘They Knew: The US Federal Government’s Fifty-Year Role in Causing the Climate Crisis by James Gustave Speth was published in August. In July ‘Attorney Generals in New York & Five Other States File Brief in Support of Juliana v. United States While Plaintiffs Oppose Attempt By Republican Coalition to Intervene.’ The League most recently signed on to support the Juliana 21 letter to the Biden DOJ.
Hillsboro Sustainability Plan
Climate Emergency Team Volunteer Opportunities
Our CE portfolio team lacks volunteers in these critical policy areas:
1) Natural and Working lands outside of the Forestry portfolio, 2) Clean Buildings, 3) Public Health Climate adaptation, 4) Regional Infrastructure, 5) State Procurement Practices (Dept. of Admin. Services) , 6) CE Portfolio State Agency and Commission Budgets, and 7) Oregon Treasury: ESG investing/Fossil Fuel divestment. We all collaborate with Natural Resource Action members on many Climate Change mitigation and adaptation policy topics.
SB 392A, Relating to fugitive emissions (Shirley Weathers)
According to the U.S. Energy Information Administration, natural gas leaks into the atmosphere from oil and gas wells, storage tanks, pipelines, and processing plants were the source of about 32% of total U.S. methane emissions and about 4% of total U.S. greenhouse gas emissions in 2015. SB 392 sought to investigate the role of methane leaks associated with natural gas used within the state in Oregon’s overall emissions, as part of the effort to reach climate goals. The bill died in W&Ms due to its $300,000 fiscal impact statement. LWVOR supported.
SCR 17A, Establishing an environmental justice framework of principles for the State of Oregon (Shirley Weathers)
SCR 17 declares the Legislature’s intent that “all persons affected by decisions of state government have a voice” in decisions within agencies’ missions and purview, particularly including "Black, Native American, Indigenous, and People of Color communities and immigrant and low-income communities," as well essential workers, youth and vulnerable people in both rural and urban communities. It acknowledges the collaboration, investments, resource protection and restoration, and regeneration that will be needed if we are to effectively and equitably confront the climate emergency ahead. The bill was determined to have minimal expenditure impact. LWVOR supported the resolution in testimony before both the Senate and House committees on Energy and Environment.
Jordan Cove Energy Project (Shirley Weathers)
The 15 year-long plans of Canadian companies to build a pipeline across southern Oregon and a liquefied natural gas (LNG) export facility in Coos Bay have experienced little besides losses and reversals in recent months. Current owner Pembina still hangs on, despite managing to obtain only a handful of around 50 federal, state, and local permits needed to begin construction. The project has obtained two key federal permits from the Federal Energy Regulatory Commission (FERC), but lost three separate attempts to challenge the denial of essential permits by the State of Oregon. In recent weeks, it lost two more of several local land use permits it once held. Recent court decisions cast doubt on whether the right of eminent domain extends to a pipeline project entirely devoted to foreign export. The well-kept secret of the natural gas industry—that methane, the key component of natural gas, is not “green”—is out. Instead, it is highly prone to leakage during transport and storage and is in important ways a more powerful greenhouse gas than carbon dioxide. The overall fortunes of fossil fuels are falling as the disastrous effects of climate change are evident worldwide. Opponents soldier on while Pembina holds out. We are now awaiting oral arguments before the Court of Appeals of the DC Circuit on October 28, 2021, in a case jointly brought by Oregon, tribes, landowners, and environmental groups challenging the two FERC permit approvals.
The three bills supported by the Oregon Clean Energy Opportunity coalition, consisting of a number of Environmental Justice organizations and affiliated environmental organizations, were League priorities. All three bills were passed by both the House and Senate and have been signed by the governor.
HB 2021 A, “100% Clean Energy,” the major climate change mitigation bill, was negotiated by a large group of stakeholders throughout the session. The bill requires retail electricity providers to reduce greenhouse gas (GHG) emissions associated with electricity sold to Oregon consumers to 80 % below baseline emissions levels by 2030, to 90 % by 2035, and to 100 % by 2040. It permits an electric company, in coordination with a local government, to provide a program of rates or charges to serve retail electricity consumers that covers costs of electricity generated from renewable or nonemitting energy resources. It prohibits issuing a site certificate for a new or expanded facility that produces energy from fossil fuels unless it generates only nonemitting electricity.
At one point, there was an amendment containing the basic bill and a separate amendment establishing a program to provide grants to public entities, consumer-owned utilities, and Indian tribes to plan or build community renewable energy projects, with special emphasis on resilience and environmental justice, and appropriating $50 million to a Community Renewables Investment Fund for purposes of a grant program for those projects. We provided testimony supporting both amendments and were glad to see a new amendment containing both. The negotiations were still not finished, so the combination bill was referred to Revenue, not subject to House Energy and Environment Committee deadlines. We were concerned, but the final bill was an improvement; see our final Testimony in support. The bill was sent to Joint W&Ms and the Fiscal report, approved by the committee, appropriated the full $50 million, but the amount spent during the 2021-23 biennium was limited to $26 million.
HB 2842, “Healthy Homes” is designed to provide home rehabilitation and health risk remediation for low-income Oregonians, with a focus on Environmental Justice Communities. It will improve family health (asthma triggers, lead, radon, smoke, toxins), reduce medical and energy costs, and reduce overall home energy use. See League Testimony in support. The bill was sent to the Joint W&Ms Committee and the Fiscal report approved by the committee appropriated $20 million each in the 2021-23 and 2023-25 biennia.
HB 2475, “Energy Affordability,” authorizes the Public Utility Commission (PUC) to consider differential energy burden and other inequities of affordability in rates and allows public utilities to provide funding for organizations to intervene in PUC regulatory proceedings on behalf of low-income residential customers and residential customers who are members of Environmental Justice communities. The costs are to be collected through rates charged to all retail electricity consumers. See League Testimony in support.
Other Supported Bills That Passed
SB 333, “Renewable Hydrogen,” directs the Oregon Department of Energy (ODOE) to conduct a study of the benefits of, and the barriers to, the production and use of renewable hydrogen (commonly known as “green hydrogen”) in Oregon. This includes an identification of the potential applications in Oregon by 2030 of renewable hydrogen in transportation, industry, electricity generation, energy storage, and other sectors and an assessment of the potential for coupling renewable electricity generation and renewable hydrogen production to increase resiliency or provide flexible loads. See League Testimony in support.
SB 589, “Regional Transmission Organization,” requires the ODOE to prepare a report identifying benefits, opportunities, and challenges posed by the development or expansion of a regional transmission organization in Oregon. See League Testimony in support because the change in requirements for electricity usage due to climate change and the intermittency of the renewable sources like wind and solar make regional advance planning increasingly necessary.
HB 3141, “Public Purpose Charge,” allows additional uses of the public purpose charge collected by the utilities: manufactured housing and switching energy sources from bulk fuels (but not natural gas) to electricity service. See League Testimony in support, after the public hearing of the bill because of its emphasis on energy conservation and because of the collaborative manner in which it was developed. It was too late to be published on OLIS; copies were sent to the members of the House Energy and Environment Committee.
HB 3375, “Floating Offshore Wind,” establishes a goal of planning for development of up to 3 gigawatts of floating offshore wind energy projects within federal waters off the Oregon coast by 2030. The Oregon Offshore Wind Site Feasibility and Cost Study, published by the National Renewable Energy Laboratory in October 2019, evaluated five Oregon coast sites, of which the two southern ones are very promising. Because the continental shelf off the coast is very narrow, anchored wind turbines are not usable; however, floating turbines have already been used in deep water off Scotland and are in development for use off the Maine coast. The bill suggests that excess electricity could be used for generating green hydrogen. League supports: Testimony.
Supported Bills Not Passed
SJM 5, “Bipartisan Climate Change Legislation,” would have urged Congress to pass, and the president to sign, the bipartisan Energy Innovation and Carbon Dividend Act as a means to pursue viable solutions to the threat posed by climate change. LWVOR supported SJM 5 in written and oral Testimony. It passed the Senate with a bipartisan vote but died in House Rules.
HB 2479, “Black Carbon,” would have modified the definition of “global warming” to include certain aerosol air contaminants, including black carbon (soot). Black carbon both adds to melting of snowpack and glaciers, including in the Cascades, when it is deposited on the surface and acts as other greenhouse gases when it is in the atmosphere. See League verbal and written Testimony in support. The bill was not considered in Joint W&Ms Committee.
HB 3278 would have directed the Oregon Department of Agriculture, in partnership with Oregon State University, to study potential for developing commercial seaweed production to produce feed for livestock as a means to reduce methane emissions. Department of Environmental Quality (DEQ) Sector Data shows that “enteric fermentation” causes methane livestock burps containing 2.7 million metric tons of CO2 equivalent in Oregon each year. Recently published research has confirmed that cattle fed a small supplement of a particular type of seaweed belch up to 82% less methane with no noticeable effect on the taste of the beef or milk. See League Testimony in support. The bill was not considered in the Joint W&Ms Committee.
Cap and Reduce/Climate Protection Program
In the Governor’s Executive Order on Climate Action, EO 20-04, DEQ was directed to cap and reduce GHG emissions from large stationary sources, transportation fuels, and all other gaseous and liquid fuels, including natural gas, to at least 45% in 2035 and 80% in 2050 below the 1990 levels.
Starting in summer of 2020, DEQ conducted six workshops and two town halls. League members actively participated throughout, including providing verbal and written Testimony for the town halls. We were already concerned about some of the choices DEQ was leaning toward making. In particular, this statement from the town hall testimony expressed a concern we still have: “We recognize that some flexibility should be provided for early modifications that will take some time to implement. However, the program must ensure that this flexibility not be used as an escape hatch for the regulated entity not making feasible reductions.”
The official Rulemaking started in January 2021, renamed: Climate Protection Program. Renew Oregon, which coordinated environmental activity in support of climate bills in 2019 and 2020 legislative sessions, had set up six “OCAP tables” for the Executive Order, including one for Cap and Reduce. It met before and after each Rulemaking Advisory Committee (RAC) meeting and also provided a Google doc for communication among table participants during the meeting. It was useful in providing questions to be asked by the RAC members.
RAC meetings spent considerable time on modeling done by an outside company. It took several meetings before we saw anything besides summary results. Unfortunately, details confirmed our expectations. It would not be possible to make useful predictions 30 years into the future.
DEQ started producing draft rules for the fifth RAC meeting. The table members were extremely disappointed with the lack of detail and with many of the choices being made. That continued with the next two meetings. The League started providing official comments starting with the fifth meeting. The letter for the seventh meeting expresses our overall concerns; we recommend you look at it. It was sent to the Environmental Quality Commission (EQC), which would have to adopt the rules, and was used as a reference for a League member’s written comments to the Oregon Global Warming Commission.
Public hearings on the proposed rules will be held remotely on Sept. 22, 2021, from 4-7 p.m. PDT and Sept. 30, 2021, from 4-7 p.m. PDT (hosted by the EQC).
Cleaner Air Oregon Air Toxics Alignment Rulemaking
One concern in our letter for the Climate Protection Program is that some sources of greenhouse gases are also covered by other emissions programs, because those sources are also the source of air toxics. The League was glad to see that some of these overlaps were being ameliorated by alignment of the list of air toxics for the Cleaner Air Oregon and the existing Air Toxics program. We also appreciated the expanded Science Advisory Committee scope, to advise the DEQ and Oregon Health Authority on the harmful effects of air toxics. The League was the only speaker at the public hearing. Approved verbal text was incorporated in a letter, including a reference to recent research on the harmful effects of air toxics on small children.
by Josie Koehne
The Governor issued Executive Order 20-04 requiring the 14 natural resource agencies and two other agencies within the executive branch to submit plans to reduce greenhouse gas emissions by June 30, 2021. The Oregon Department of Forestry released the draft Climate Change and Carbon Plan (CCCP) on May 21. LWVOR commented in support, disappointed that no plans for immediate action to increase carbon sequestration were included to address the emergency at hand, since implementation and metrics are assigned to a panel and a new committee that will need legislative funding, adding further delay. All comments on the draft were reviewed and summarized by an independent consultant, Oregon Consensus, in July. The final draft was recently revised on August 23 with this input in mind. A workshop on the revised draft will be presented on September 8, with opportunity to provide further oral comments. The final will be presented for approval to the Board of Forestry in December, 2021.
The LWVOR has been participating and providing input to the Natural and Working Lands Table (includes forestry and agriculture) of the Oregon Climate Action Plan (OCAP) Rulemaking Team, a volunteer coalition of conservation organizations that has supplied comments and feedback on all climate-related deliberations to legislators, the Oregon Global Warming Commission (OGWC), the Oregon Department of Forestry and Board of Forestry throughout the session. The OGWC requested stakeholder input on two surveys about what would motivate forestland owners to adopt conservation practices.
The Global Warming Commission presented their draft Natural and Working Lands Proposal on July 28 in response to the Governor’s Executive Order 20-04 that directed the OGWC to develop recommendations about state goals for carbon sequestration and storage on Oregon’s natural and working landscapes. Public comments were heard and letters were accepted through August 4. See League comments. OGWC Chair Catherine MacDonald then revised and much improved the final draft, which was reviewed and approved in an online public OGWC meeting we attended on August 4.
The only bill on climate and Forestry this session was in the House Committee on Economic Recovery and Prosperity, Public Hearing on HB 2916 on March 9, but it did not pass by the end of session. The bill establishes three separate Blue-Green Economy Task Forces in the areas of timber, agriculture, and marine resources, and requires each task force to consult with the OGWC to develop a plan that accelerates greenhouse gas reduction and removal, while identifying economic development opportunities in rural communities impacted by the industries related to the task force. Rep. Anna Williams (D, HD 52, Hood River), chief sponsor, said the bill needed an amendment,never drafted by session end. In the public hearing on the 9th, Anna Williams said she supported existing industries that were doing marine, timber and agriculture projects being brought into the conversation for the group working on this bill. She suggested reworking the bill with an amendment to include these stakeholders. A representative of the nursery industry was in favor and glad a revised conservation bill would include their input. 13 nurseries had gotten together to assess their carbon emissions and were already working to reduce their gas energy use, so their efforts should be acknowledged and appreciated. The AG sectors have not been included in the conversation to increase climate resiliency. Rep. Levy, Rep. Cate and Rep. Whallan said timber owners are usually not at the table to provide input on these climate bills, and also complained that federal forestland is not managed well for forest fires to prevent spillover onto private forestland. Rep. Clem by phone pointed out that there will soon be federal or international carbon offset market legislation, and that Oregon should get in on shaping the rules and criteria for the global offset market to the benefit of our Oregon industries since state markets are too limiting. Rep. Clem said Oregon should get credit in the carbon market system for our forest sequestration, hydro power, vehicle miles traveled program and our land use planning laws.
The suggestion was that the Governor’s task force should be replaced by a work group, with members not just appointed by the governor, but consisting of industry members and environmental/climate members (one rep suggested not more than 22 members), to work together to propose the best plan in each for these three areas. Rep. Williams said she would revise this bill for the future. This was a very important and substantive conversation that the LWVOR thinks holds promise for future success.
Climate/Transportation (Julie Chapman)
The 2021 legislative climate work was supported by climate activists advocacy, BIPOC communities, health and environmental justice voices. The governor and many legislators came to Salem this session with well-designed legislative concepts and, in some cases, bipartisan support, to advance transportation electrification bills to passage.
HB 2165 requires that larger electric utilities develop a plan accepted by the Public Utility Commission to collect an amount from retail electric customers to develop EV charging infrastructure. At least 50% of infrastructure must be installed in underserved communities. The bill continues and expands rebates for standard and low-income programs to purchase new or used zero-emission vehicles (ZEVs). The programs’ funding comes through a tax for the “privilege” of engaging in the business of selling motor vehicles. See League testimony.
HB 2180 amends state building code to require 20% of parking spaces in new commercial and multifamily (more than 5 units) construction provide for electrical service capacity for EV charging devices. Charging devices are not required, but future installation costs will be markedly reduced by installing the conduit and provisions for electrical service capacity. See League testimony.
HB 2290 requires the State Parks and Recreation Department to allow for installation and service of public EV charging stations in the state park system.
HB 3055, the Omnibus Transportation bill, is a 77-page chimera, full of speed bump heights, weight-mile taxation, and disabled person parking permits, into which were inserted two free-standing bills at the end of session. The League objected directly to committee members about charging customers to support and expand natural gas (NG) infrastructure in order to provide hydrogen (which perforates NG pipelines) and renewable NG (inadequate “feedstocks”) as transportation fuels.
HB 2021 (100% clean electricity), HB 3375 (planning for offshore wind energy projects), SB 333 (study of development of renewable hydrogen) and SCR 17 (establishing an environmental justice framework for Oregon) are discussed elsewhere in this report; they all have significance for access to nonemitting transportation.
Unfinished business: policies to increase %ages of ZEV car sales; “cash for clunkers” programs focused on replacement with ZEVs; financial support for transition to zero-emission transit vehicles, school buses, and off-road work equipment (e.g., tractors); bike and pedestrian safety and access; considerations for replacing the gasoline tax to fund highway maintenance; study of health impacts from “indirect source” emissions and particulates from “hotspots” with multiple diesel engines (construction and industrial sites, commercial hubs, etc.); study of fugitive emissions from production, transportation, and storage of NG used in Oregon.
Oregon Department of Transportation and the Oregon Transportation Commission:
ODOT’s Climate Office gathered experts and consumer advocates to produce well-researched and widely vetted recommendations in the Transportation Electrification Infrastructure Needs Analysis (TEINA). The study focuses on light-duty vehicles. In its 174 pages, the report reviews adopted state policies and steps to achieve their goals, focusing on equity and accessibility, safety, role for electrical utilities, and development of educational and technical resources, a skilled workforce and increased support for micromobility (e.g., eBikes, eScooters). Analyzing transportation sectors, the study forecasts requirements for charging ports by geography and community type. The need for public charging will grow exponentially between 2020 and 2035. Factoid: Public charging needs for Direct Current Fast Charge ports in rural areas (1,400 by 2025) exceed those in urban areas (880). Due to the long driving distances in rural areas, this disparity is expected to persist.
ODOT’s Climate Action Plan lays out the theoretical underpinnings for addressing transportation greenhouse gas emissions and impacts of extreme weather on the transportation system, and presents specific strategies and programs to reduce emissions. Appendix A. Climate Action Plan (2021-2026) provides more detail for the work ODOT will do to reduce emissions from transportation, address equity, make the transportation system more responsive and resilient, and align with state and federal investments. Central to both is the development of performance metrics to measure emissions reductions and program performance — a transparent assessment that will be tracked on ODOT’s transportation emissions dashboard.
Unfinished business: Missing from the plans are 3-5 year interval targets for transportation emissions reduction. We recommend ODOT/Oregon Transportation Commission begin to make investments that reflect the climate emergency, using TEINA and their Climate Action Plan.