Public Comments

Public Comments Supporting Climate Action

Oregon Legislature

2021 Session–Clean Electricity Law

MCAT was part of a large group of climate and equity organizations supporting House Bill 2021, and signed on the several joint letters, and also submitted individual testimony urging the Oregon legislature to ensure the transition to 100% clean electricity, with strong labor standards for all clean energy projects, incentives for community-based renewable energy projects, and provisions that prioritize benefits and avoid harms to environmental justice communities aroud the state.

Link to Comments: Testimony and OP-ED Letter

2023 Session–Building Resilience Package

MCAT was part of a large group of climate and equity organizations supporting the Clean and ResilientBuildings package of bills (SBs 868, 869, 870, and 871), signing on the several joint letters, and also submitted individual supporting testimony to the Oregon legislature that the bill package will help provide the incentives and programs needed to speed up the decarbonization o our buildings by supporting rapid deployment of heat pumps and weatherization upgrades, improving buildings codes for new construction, implementing a Building Performance Standard to improve efficiency in large commercial buildings, and making it easier for state and other public buildings to implement energy efficiency programs.

Link to Comments: Senate E&E-Building Resilience Package

Oregon Public Utilities Commission

Northwest Natural IRP and CPP Review

MCAT was part of a group of interested parties, known as the Climate Advocates, that formally intervened in the Oregon Public Utility Commission Docket regarding the Northwest Natural Gas Company’s 2022 Integrated Resource Plan. Under the leadership of the Green Energy Institute at Lewis & Clark LawSchool, the Climate Advocates also included Climate Solutions, Columbia Riverkeeper, Community Energy Project, Electrify Now,Natural Resources DefenseCouncil, and Sierra Club. In addition, MCAT, represented by Dr Pat DeLaquil, prepare comments and testimony throughout the process, emphasizing that the Company’s long-term plan for compliance with the Climate Protection Plan did not represent a least-cost, least-risk strategy, and that the plan did not represent reasonable balance of future risks and incentives between the company and ratepayers.

Link to Comments: Written Comments to PUC on LC79

Portland General Electric IRP/CEP Review

MCAT was part of a group of interested parties, known as the Energy Advocates, that participated in the Oregon Public Utility Commission Docket regarding the Portland General Electric’s 2023 Integrated Resource Plan and Clean Energy Plan. MCAT experts contributed to the detailed comments submitted by theEnergy Advocates which covered: centering energy justice and community engagement in their Clean Energy Plan, increasing projections for distributed energy and other resource options that can defer transmission upgrades, concerns over GHG emissions from electricity exports, improving community benefit indicators, and increasing supports for community benefit renewable energy projects.

Link to Comments: Energy Advocates’ Round 1

PacificCorp Oregon IRP/CEP Review

MCAT was part of the Energy Advocates group that participated in the Oregon Public Utility Commission Docket regarding the PacifiCorp’s 2023 Integrated Resource Plan and Clean Energy Plan for Oregon. MCAT experts contributed to the detailed comments submitted by the Energy Advocates which covered:community engagement and community benefit indicators, coal plant extension through conversion to gas, the lack of community-benefit renewable energy projects and other clean resource options and an unwarranted commitment to nuclear power.

Link to Comments :Energy Advocates’ Round 1 Comments

Department of Environmental Quality

2023 Climate Protection Plan Rules Update

MCAT was part of a large group of interested parties that participated in the 2023 Rulemaking Update process with DEQ staff and the Environmental Quality Commission regarding implementation of the Climate Protection Plan. MCAT experts contributed to the detailed joint comments and submitted individual comments as well urging the EQC to direct staff to strengthen the final rules so as not to undermine the equity goals of the CPP by restricting biomethane and hydrogen used for CPP compliance to that which produces direct benefits for Oregonians; and requiring that existing BAER facilities cannot expand beyond the 10,000 MT CO2e /year limit without an updated BAER review and a reduction in their per-unit emissions level

Link to Comments: MCAT CPP Rules Update Comments