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Department of Environmental Quality’s Office of Greenhouse Gas Programs,
As members and supporters of E2 (Environmental Entrepreneurs), we are writing in support of a well-designed Cap and Reduce Program that will drive emission reductions consistent with science-based climate goals. Substantially reducing emissions from statewide large stationary sources, transportation fuels, and other liquid and gaseous fuels is critical to avoiding the worst impacts of climate change while creating an economic opportunity to advance the state’s transition to a prosperous and resilient low-carbon economy.
E2 is a non-partisan network of business leaders from every sector of the economy who advocate for policy that is good for the economy and good for the environment. E2 members have founded or funded more than 2,500 companies, created more than 600,000 jobs, and manage more than $100 billion in venture and private equity capital. E2’s Pacific Northwest Chapter was founded in 2009 and our network now includes over 450 businesspeople working throughout Oregon’s economy including cleantech investors, clean energy entrepreneurs, farmers, foresters, and small business owners.
The Department of Environmental Quality (DEQ) has a tremendous opportunity to develop and implement a strong and robust Cap and Reduce Program, which is a central element of Governor Brown’s Executive Order 20-04. If developed and implemented appropriately, the Cap and Reduce Program will help reduce Oregon’s greenhouse gas emissions and provide necessary public health improvements by reducing air pollution. The Program also has the potential to jumpstart critical economic development that will drive statewide job growth and position Oregon to thrive in the low-carbon economy of the future.  A well-designed program will help Oregon become a national hub of clean energy innovation and low-carbon businesses. It can incentivize investments in clean energy and clean technology innovation, as well as drive investments into rural communities through carbon sequestration projects on working and natural lands. It can also enhance the competitive advantage of Oregon businesses through increased energy-efficient operations that reduce costs and move businesses away from reliance on volatile global oil markets and towards domestically-produced clean energy.
In order for DEQ to fully capitalize on the pollution reduction and economic development benefits, a well-designed Cap and Reduce Program should include the following foundational design principles:
  • The Program should cover all greenhouse gases referenced in state legislation and all sources of emissions within the state with annual emissions equal to or greater than 5,000 tons CO2e, including electric generation. Including all major sources provides a level playing field on which businesses can compete for emission reductions and invest with confidence.
  • The Program must set and maintain an economy-wide declining carbon cap stringent enough to backstop achievement of the Governor’s EO and drive reductions consistent with or exceeding the state’s science-based climate goals.
  • The Program’s required rate of emissions reductions can be no less stringent than a linear trajectory extending from 2005 emissions levels to the 2050 goal, and the Program should incentivize steeper early reductions to the greatest extent possible.
  • The Program should use a multi-year average emissions period relatively free from significant distorting factors to establish a point of departure for future emission reductions.
  • The Program should be designed to contain costs through thoughtful flexibility provisions, potentially including multi-year compliance periods, alternative compliance options (with strict requirements and limits on offset projects), and allowance trading, banking, and reserves.
  • Program design, implementation, and oversight should include full representation from impacted communities, with an emphasis on historically underrepresented communities.
As business leaders representing a wide range of industries in Oregon and on behalf of the E2 business community in Oregon on the whole, we call on DEQ to develop and implement a Cap and Reduce Program that will drive meaningful reductions in our economy-wide emissions and set Oregon on the path towards a prosperous and climate-stable future.

Paul Ahrns
Program Director, Sierra Business Council
Stephen Aiguier
President/Owner, Green Hammer Inc.
Ben Brint
Operations Lead, Lyft​
Becky Brun
Owner, Pitchfork Communications
Scott Burns
Professor Emeritus, Portland State University
Bryce Clarambeau
Chris Dennett
Director of Strategy and Integration, The Tofurky Company
Heather Dennett
Kaiser Permanente
Sally DeSipio
Creative Consultant
Rebecca Eaton
Managing Member, Eaton Synergies LLC
Eric Corey Freed
Senior Vice President, Sustainability , CannonDesign
Linda Gerber
Owner, North Logan Farm
Kate Hammarback
Principal, Occam Advisors
Bill Harris
Ian Hill
CEO, SeQuential Biofuels
Bill Hoelzer
Principal, Volta Strategies
Tyson Keever
COO, Crimson Renewable Energy & SeQuential
Alexia Kelly
Director, Sustainable Solutions, ENGIE Impact
Kellen Klein
Senior Manager of Stakeholder Engagement, Future 500
Carola Lacy
Reed Lewallen
Investor Care Team Lead, CrowdStreet
Lach Litwer
Principal, Wōden
Cameron Madill
CEO, PixelSpoke
Aspen Mayberry
Mike Mercer
Principal, MMercer Consulting
Danny Metcalf
Director of Business Operations, Brew Dr Kombucha/Townsends Tea​
Jeremy Mohr
Senior Project Director, WSP USA
Linda Perrine
Owner, Honor Earth Farm
Christian Rees
Director of Installations, Defense Threat Reduction Agency
Andrew Shakman
President/CEO, Leanpath
Steven Sloop
President, OnTo Technology LLC
Shannon Souza
Principal, Sol Coast Consulting & Design
Jane Stackhouse
Consultant, Jane Stackhouse Consulting
Katie Stone
Operations Manager, PixelSpoke
Bettina von Hagen
Managing Director & CEO, EFM
Charles Weiss
Account Manager, GEL America
Alex Wick
Founder & CEO, Cascadia Carbon
Graham Zimmerman
Producer & Director of Development, Bedrock Film Works

38 members


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