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.
https://docs.google.com/document/d/1CMmVYrpxOwXxBPisUSoKQh_g6qCyvJy9oobdjmFp34c/edit?usp=sharing