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Draft emissions reduction gap measures

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By Oregonians for Food and Shelter,

4/10/26 — This week, OFS submitted comments [6]on behalf of a large coalition in response to the Oregon Department of Energy’s recently released draft of emissions reductions gap measures [7]. These measures are being put forward for modeling to quantify potential greenhouse gas emissions reductions, and the information would be made available to decision-makers, including the Oregon Climate Action Commission and legislators. The extreme measures proposed for modeling by ODOE include, among others:

 

These proposals reach far beyond the authority of ODOE, ignore the needs and realities of Oregon’s food and fiber producing sectors, and undermine the stated goals and efforts of other state agencies such as Oregon Department of Agriculture. They seem to have been developed in a vacuum.

We encourage you to submit comments, which are due TODAY (Friday April 10th) at 5pm. Submit your comments by email to [email protected] [8] with the subject line “Public Comment on TIGHGER 2.0 Draft Gap Measures” and tell ODOE to focus on affordability and practicality rather than ideas for more top-down mandates from Oregon’s decision-makers.

 

OFS also submitted comments [9] this week to EPA, providing feedback on their proposed Qualified Conservation Program and Qualified Experts Program certification [10] that aims to facilitate compliance with ESA-related pesticide label requirements. Our comments encourage EPA to collaborate closely with other agencies, such as National Marine Fisheries Service, to ensure the programs would apply to all relevant label requirements, and to allow certification of relevant conservation programs that serve non-agricultural pesticide use sites.