From: Jenny Holmes
Sent: Fri Aug 31 21:06:53 2012
To: CleanFuelsAug2012
Subject: Clean Fuel Comments
Importance: Normal
Attachments: OIPL-EMO clean fuels comments.doc; August 31, 2012 Attn: Cory-Ann Wind, Oregon Clean Fuels Program Oregon DEQ, Air Quality Division811 SW 6th Avenue Portland, OR 97204. Dear DEQ: Ecumenical Ministries of Oregon (EMO) and its Oregon Interfaith Power (OIPL) and Light project strongly support the adoption of Oregon’s Clean Fuels Program (OCFP) administrative rules. The Oregon Legislature rightfully set greenhouse gas emission reduction goals for the state, and the OCFP will serve to reduce overall transportation sector fuel emissions to meet these goals, while improving local air quality and bolstering good-paying jobs across the state. By participating on the Advisory Committee, EMO and OIPL have seen the evolution of Oregon Administrative Rules 340-253-0000 through 340-253-307 into a solid foundation for building a more ethical fuel supply throughout the state. These rules will provide a fuel market choice for source alternatives to a petroleum supply increasingly derived from the destructive mining, processing, and shipment of tar sands from Alberta. With the full OCFP, Oregonians will more likely have the opportunity to replace these high-carbon low-quality bitumen products, shipped by more pipelines and rail cars going over the Rocky Mountains and down the I-5 corridor, with advanced biofuels derived from products in the state and region that better meet the carbon performance standard. A substitution of Clean Fuels for tar-sands derived petroleum will provide better public health, higher personal incomes, and a stronger economy in Oregon, as has been predicted by the economic models run for the DEQ. Please also do not set an arbitrary 250,000 gallons per year ‘small importers’ threshold for reporting. A large opportunity for gaming the system, without adequate checks on accuracy or contract shuffling, will occur if this high threshold is adopted. And this program will only be effective if the Legislature removes the 2015 sunset. We encourage the EQC to make it known that removing the sunset is essential for the full success of the Clean Fuels program, and for Oregon to meet the GHG emission goals the Legislature itself has set for the state. We see a moral and technical urgency for Oregon to stay in its leadership role in providing a cleaner fuels choice for its citizens. Thank you for the opportunity to participate in the development of the rules and to provide a clear voice in support of a more ethical fuel supply for Oregonians. Sincerely, Jenny Holmes Environmental Ministries Director 0245 SW Bancroft, Suite B Portland, OR 97329