Cross-Cutting Actions
The following actions advance progress in more than one sector.
Cross-Cutting Action 1
Impose registration and reporting requirements upon all new large electric loads to inform greenhouse gas emissions analyses, and evaluate whether policy changes are needed to bring emissions in line with state policies. This would require an action from the Environmental Quality Commission.
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3 (Clean Electricity)
4 (Low-Carbon Fuels)
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2a (Utility-scale and distributed energy resources)
4b (Low-carbon fuels adoption)
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1 (decision-making)
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Although new tech loads, such as data centers, are expected to be the biggest near-term driver of electricity demand growth, relatively little information is available for these loads — or what resources will serve them. Some will be served by investor-owned utilities with clean energy requirements pursuant to HB 2021 (2021), but others — potentially a majority — will not. Most of Oregon’s consumer-owned utilities receive all or nearly all of their electricity supply from the Bonneville Power Administration. Yet federal law restricts BPA’s ability to supply new large loads at its lowest rates. Any service to those loads by BPA would be at a much higher rate that covers the full cost of that service or would be served by an alternative power supply that the COUs procure. A new large load is defined as “any new load, or expansion of an existing load, at a single facility that grows by 10 average megawatts (aMW) or more in any 12-month monitoring period.” This means a significant and growing amount of electric load in Oregon is not subject to HB 2021’s clean energy targets and might not be supplied by BPA, leading to potential increases in Oregon’s reliance on emitting electricity sources.
It is unclear at this time what the implications of these new loads may be for Oregon’s energy policy objectives, including Oregon’s economy-wide decarbonization goals. Many of the larger new tech load companies, including Amazon and Google, have adopted voluntary climate goals that prioritize the use of clean electricity and aim for net-zero carbon emissions in the coming decades. But the state does not have sufficient data to know how many of the new loads are subject to voluntary climate goals or not, nor does the state have sufficient data to assess whether progress toward voluntary goals is occurring consistent with Oregon’s economy-wide decarbonization goals.
Currently, the Oregon Department of Environmental Quality, pursuant to direction from the Environmental Quality Commission, requires all electricity suppliers operating in Oregon to register and report greenhouse gas emissions data for Oregon electricity sales. While this data provides utility level information, it is insufficient to evaluate new tech loads energy needs or their implications for the state’s goals.
Additional reporting — directly from new large loads about their operations and energy consumption — is needed to inform state decision-making. This policy action proposes a new statewide registration and reporting requirement for all new large loads. A statewide approach is more appropriate than focusing only on areas not covered by HB 2021, which could cause confusion or unduly affect business decisions about where to locate. A statewide approach may also provide insights on the potential effects of the largest businesses across the state that are subject to the Climate Protection Program and may be increasing their reliance on electricity. A statewide approach could also support future evaluation of impacts of new large loads on other natural resources, such as water consumption. Imposing state reporting obligations may pose a risk of discouraging new loads and new economic development in Oregon. Yet having improved data and transparency regarding the energy requirements of these large-load facilities would help the state and the communities in which the facilities are located make informed decisions.
Cross-Cutting Action 3
Establish a Tribal Energy Block Grant Program to support Tribal energy priorities, cultural values, and community needs through alignment with their own energy planning processes or the Oregon Energy Strategy.
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All
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1 (decision-making)
3 (incentive programs)
5 (partnerships and resources)
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A Tribal Energy Block Grant program would provide direct, flexible funding to federally recognized Tribes to design and implement energy programs that reflect their own priorities, cultural values, and community needs. Modeled after other successful block grant structures, such as federal housing block grants, this program would shift decision-making power to the Tribes by allowing them to determine how best to use their funds, whether for energy efficiency upgrades, renewable energy deployment, workforce development, planning and capacity building, or other strategies that align with the policy recommendations in the Oregon Energy Strategy or Tribal energy strategies. Rather than prescribing a one-size-fits-all approach, the program would recognize the sovereignty of each Tribe and support locally tailored solutions that promote energy resilience, affordability, and self-determination. The program should build in administrative support and multi-year funding to ensure the program’s stability and reduce the administrative burden that often accompanies competitive grant processes. Ultimately, this program could serve as a key tool in operationalizing the state’s commitment to equity and Tribal energy sovereignty.
Cross-Cutting Action 5
Conduct a biennial survey on energy affordability and report on trends to inform state policymaking.
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All
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5 (partnerships and resources)
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Rising costs for electricity, gasoline and other energy uses are of concern to Oregon households and businesses across the state. Yet a holistic view of energy affordability is difficult to form due to lack of information, a problem exacerbated by the loss of federal tools and support. To obtain the most accurate picture of household and business energy costs and energy needs, the state should undertake a recurring survey of household and business energy costs and energy consumption patterns. Energy security includes access to affordable energy.17 For example, electricity service is not reliable if consumers cannot afford to use electricity to meet basic needs, such as air conditioning during extreme heat events. This information would help the state make informed decisions about the potential impacts of energy policies and how to shape policy to address them.
The survey of energy affordability should include energy costs both in buildings and transportation, as well as vehicle miles traveled and usage of alternative modes of transportation. In this way, this action should link to action Cross-Cutting Action 4, which recommends developing a shared definition of energy burden that includes both building and transportation related energy costs. This will ensure that, as the transportation sector evolves and vehicles electrify, Oregon is tracking the effects of this shift on household and business energy costs and consumption patterns.
Cross-Cutting Action 7
Identify gaps in current and estimated occupation-level employment to meet Oregon’s future energy needs. ODOE should recommend actions to support and expand workforce development efforts that complement existing efforts.
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All
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1 (decision-making)
4 (workforce)
5 (partnerships and resources)
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As the energy sector evolves to meet Oregon’s future energy needs and policy objectives, the energy industry workforce will need to evolve as well. The jobs analysis conducted for the energy strategy demonstrates a need for greater employment in several key occupations, including electricians, HVAC specialists, and others. If workforce development needs in these occupations are not addressed, this may lead to employee shortages and delay in meeting Oregon’s energy goals, particularly in rural, frontier, and remote areas. At the same time, industries engaged in the extraction, processing and refining, distribution, and use of fossil fuel are likely to see job displacement. This may lead to greater unemployment in certain industries if retraining and new opportunities are not available.
A workforce needs assessment would serve as a step toward improving our understanding of areas of potential shortage and displacement and provide guidance on strategies to support further development and retraining of the necessary workforce. The study should consider how different potential strategies for building the clean energy workforce would affect the promotion of a just transition, including considerations around: job quality, pay, benefits, demographic diversity in hiring and training geography/location, and the role of different development opportunities such as apprenticeships, college and vocational education programs, and dedicated training programs.
Cross-Cutting Action 9
Increase coordination between state agencies and community-based organizations, utilities, Energy Trust of Oregon, and other partners to advance consumer education and facilitate delivery of energy related services.
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All
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1 (decision-making)
5 (partnerships and resources)
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Oregon’s energy transition involves Oregon households and businesses making informed decisions about building upgrades, equipment purchases, vehicle purchases and other choices with long term energy implications. Resources that build on utility efforts should be developed to ensure that every Oregon home or business has the information needed to navigate complex energy decisions. Consumer education should be shared at level of consumers, customers, and communities through culturally appropriate materials that are translated and in plain or accessible language. Community based organizations and industry partners should have access to training and funding to enable participation, to ensure all energy related measures meet quality, performance and financial expectations.
This action recommends coordination to facilitate delivery of energy-related services. Equipment installers, vehicle dealers, and other providers of clean energy services are often the main actors engaging consumers and helping them make purchase decisions. As technologies evolve and to advance the state’s energy policy objectives, these service providers must be knowledgeable about new technologies and have information available for consumers, such as availability of rebates or low-cost loans, as well as information on upfront costs and operating costs over time to capture the benefits of more energy efficient technologies.
Cross-Cutting Action 11
Increase resources, funding, and staff levels at agencies as needed, and as funding becomes available, to implement actions necessary to advance Oregon’s energy policy objectives.
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All
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1 (decision-making)
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As legislators and the Governor consider actions in the energy strategy, this action urges them to provide needed funding and to implement those actions. While current financial challenges at the state level may mean additional investment may not be possible in the near term, this action signals the importance of making investments when resources are available.
It is clear that the clean energy transition will be most effective and equitable if managed well. Yet no single entity has explicit authority to undertake this management work. Instead, a number of different Oregon state agencies play a role in enabling, supporting, and overseeing the energy transition. The scale of the challenge brought to these agencies often outbalances the scope of resources currently available to them.
Agencies named in the energy strategy include key agencies responsible for implementing energy policy and providing essential analysis and information across the transportation, fuels, utilities, and broader energy systems. This includes the Oregon Department of Transportation, Department of Environmental Quality, Public Utility Commission, Department of Energy, and Department of Land Conservation and Development. There are many other agencies involved in supporting implementation of Oregon’s energy policies in way that protects natural and working lands, inland and coastal waters, economic development, housing development, public health, and many other essential public services.
Wherever named or included in the implementation of an action, it is important to ensure that resources are made available to enable agency action.
Cross-Cutting Action 2
Establish and identify a source of funding for a revolving loan fund to provide a stable source of low-cost and no-cost loans to support the energy transition and resilience.
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All
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1 (decision-making)
3 (incentive programs)
5 (partnerships and resources)
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This action would establish a dedicated revolving loan program that primarily serves to amplify the lending capacity of existing entities delivering grants and loan programs to support access to clean energy technologies for households and businesses. Examples include local credit unions, utility programs, Energy Trust of Oregon, community organizations, local governments, and state agencies. It would be necessary to work with state agencies and the legislature to identify seed funding and establish an appropriate framework. It will be important to ensure that the new financing does not result in defunding or re-prioritizing programs and/or assistance for energy efficiency measures for households with low and moderate incomes.
The energy transition will require significant investment in new technologies and infrastructure. A stable source of financing is critical to support the pace and scale of investment required to both reduce greenhouse gas emissions and enhance resilience to climate impacts. A revolving loan fund can provide a stable and growing pool of money to support measures driving uptake of clean energy technologies over time.
A revolving loan fund also provides an opportunity to support loan products that provide access to financing for low- and moderate- income and environmental justice households who have either not had access to loans or been subject to predatory lending practices. A revolving loan fund can enable existing grant and rebate programs to focus more direct assistance funding to low- and moderate-income households who do not qualify for traditional loans.
The revolving loan fund should include programs that make financing available in, at minimum, the following areas: energy efficiency and electrification measures in residential and commercial buildings; light-, medium- and heavy-duty zero emission vehicle and ZEV charging or fueling infrastructure; and distributed resources.
Cross-Cutting Action 4
Develop a state-wide definition of energy burden that combines household and transportation costs to help inform Oregon’s energy transition.
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All
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1 (decision-making)
5 (partnerships and resources)
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Under this action, the Oregon Department of Energy would develop a consistent, cross-agency definition of energy burden that incorporates both building energy costs and transportation-related energy expenses. This updated definition can be used across agencies to assess and track how policies – particularly those related to electrification in buildings and transportation, as well as investments in multimodal transportation – affect household energy costs over time. Under this action, ODOE would cooperate with other agencies in developing this definition, including OHCS, OPUC, ODOT, DEQ, and DLCD.
Currently, transportation energy costs – often the largest single energy expenditure for many families, as demonstrated by the Energy Wallet analysis – are not included in traditional definitions of energy burden. As Oregon moves toward widespread electrification of buildings and vehicles, a modernized definition is critical for understanding how shifts in energy consumption and fuel sources affect affordability, particularly for low-income, as well as currently and historically marginalized communities. Without updating how energy burden is calculated, the state risks overlooking significant changes in household energy spending, such as the shift from gasoline to electricity for vehicles.
Incorporating transportation into the energy burden framework would also allow agencies and policymakers to more accurately assess the impact of alternative mobility investments, such as expanded public transit, safe biking and walking infrastructure, and other strategies that reduce household transportation costs. A common, inclusive definition would provide a valuable tool for guiding equitable policy development, targeting financial assistance, and measuring progress toward affordability and environmental justice goals statewide.
Cross-Cutting Action 6
Facilitate the sharing of data and joint planning to enhance energy resilience and reliability. The Oregon Department of Energy should identify relevant actions that support the Oregon Energy Security Plan.
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5 (Resilience)
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5a (Cross-fuels planning)
5b (Resilience measures)
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5 (partnerships and resources)
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The Oregon Energy Security Plan highlights the need for coordination between energy providers and the state to ensure that credible contingencies are part of their planning regime and there is adequate coverage across the state. Energy providers in the Pacific Northwest have already begun to explore enhanced coordination and planning, and this action would call on the state to support and build on these efforts. The state would encourage participation by electric and gas utilities, fuel providers, and energy stakeholders.
Greater coordination can help energy providers share high level resource adequacy data and engage in and participate in state emergency planning. This activity would provide transparency into Oregon’s larger energy system, how energy use may change over time based on energy provider data like new large loads joining the electric system, and how the system may respond during an event. Results of planning activities and data will inform future iterations of the Oregon Energy Strategy and the Oregon Security Plan.
Cross-Cutting Action 8
Advocate for federal policies that support advancement of state energy objectives.
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All
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1 (decision-making)
5 (partnerships and resources)
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Federal policies play an important role in relation to state energy objectives. For example, the Clean Air Act Section 209(b) waivers (often referred to simply as the California waivers), ENERGY STAR program, appliance and equipment standards, and funding are examples of federal programs that support state energy objectives. Federal policy can also make it more difficult for Oregon to reach its energy policy objectives.
This action directs state agencies to identify existing federal programs that align with the Oregon Energy Strategy and advocate for policies that support achievement of state energy objectives and continue to elevate the needs of environmental justice communities. This includes engaging with Oregon’s federal delegation to ensure that Oregon’s voice is heard in Washington, DC.
Cross-Cutting Action 10
Align the Oregon Economic Development Strategy and the Oregon Energy Strategy through collaboration between Business Oregon and the Oregon Department of Energy to foster decarbonization and economic growth through consideration of industrial symbiosis, clean energy innovation, emerging technologies, and incentives.
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All
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1 (decision-making)
4 (workforce)
5 (partnerships and resources)
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Business Oregon is developing an Economic Development State Strategy and modernizing their business incentives to better support growth, competitiveness, and innovation across Oregon. The Oregon Energy Strategy identifies how the changing energy landscape will bring opportunities for energy infrastructure development, innovation, and new technological solutions to the challenges we face.
Business Oregon and the Oregon Department of Energy should work together to determine where and how the state’s economic development goals are best aligned to realize economic benefits from the opportunities outlined in this strategy. This alignment effort should also take into consideration previous work on this topic, including the findings from the Governor’s Clean Tech Task Force. Both state agencies will share data and research and foster communications with key public partners to inform strategy development and implementation. The aligned strategies will advance solutions to Oregon businesses needing to modernize operations and foster home-grown technology innovations from Oregon industries, leading to an affordable and prosperous energy transition.
Cross-Cutting Action 12
Develop a community benefits framework at the Oregon Department of Energy that can be used as appropriate across the agency to address outreach and engagement, workforce needs, prioritizing environmental justice communities, and equitable practices.
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All
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1 (decision-making)
5 (partnerships and resources)
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Federal uncertainty highlights the need for a formalized state community benefits framework that provides meaningful involvement with Environmental Justice communities as defined in HB 4077. Community Benefits Plans were required in many Inflation Reduction Act and Infrastructure Investment and Jobs Act grant funded programs. Changes in federal policy will likely result in community benefits plans no longer being required or funded by the federal government.
A community benefits framework would provide a foundation to continue supporting and funding community benefits through the state. It would provide an opportunity for ODOE-administered projects/programs to learn more about community needs and interests as well as direct benefits through metrics and then develop an implementation plan that carries those benefits throughout the life of the project. It could serve as a starting point for broader consideration of how to incorporate community benefits considerations in programs across the state. ODOE commits to applying the Equity and Justice Framework in developing and implementing the community benefits framework.