Rogue Advocates submitted public comment in advance of the December 17 meeting on the latest draft rules developed for the Land Conservation and Development Commission’s (LCDC) Climate-Friendly and Equitable Communities Rulemaking. The comments urge LCDC to ensure that its final rule reflects the urgency and severity of the climate crisis and corrects Oregon’s historic failure to meet its GHG emission reduction goals.
Governor Kate Brown’s Executive Order 20-04 directed state agencies, including LCDC, to update relevant rules to reduce emissions and meet Oregon’s climate goals. Since September 2020, a Rulemaking Advisory Committee (RAC) composed of representatives from a broad array of Oregon communities and organizations has been working to update Oregon’s Transportation Planning Rules (Oregon Administrative Rules Chapter 660, Division 12) through the Climate-Friendly and Equitable Communities Rulemaking. These Rules guide how local governments make land use and transportation planning decisions across Oregon.
Updating these rules is critical to Oregon’s climate response considering transportation accounts for 38% of Oregon’s GHG emissions and historic transportation planning has resulted in cities heavily dependent on automobile travel. One major land use tool the RAC has included in its proposed rules are Climate Friendly Areas (CFAs). CFAs are mixed-use urban areas designed to allow residents, workers, and visitors to meet most of their daily needs without driving. Read more about CFAs here. The current proposed rules call for 30% of all housing needs to be located in CFAs.
Rogue Advocates’ comments express support for the integration of CFAs into the proposed rules but urge LCDC to be more ambitious with its use of the tool. The need for ambition is made clear by the Oregon Global Warming Commission’s 2020 Biennial Report highlighting how far off-track Oregon is from meeting its GHG reduction goals with current policies (see, for example, figure detailing Oregon’s GHG emissions and goals above), as well as the short time frame for immediate and dramatic system-altering action discussed at the Glasgow COP26 summit.
Considering the urgency for change and the extent of Oregon’s failure to meet its goals, Rogue Advocates believes that calling for only 30% CFAs in city planning does not rise to the level of a systemic shift away from auto-dependent travel necessary to meet Oregon and global emission reduction targets. The 30% figure is derived from a transportation strategy developed in 2013, when decision-makers were less informed of the urgency of the climate crisis and not yet aware of Oregon’s failure to meet its GHG targets. Our comments also discuss the need for a tight deadline for adopting CFAs, the need for prescriptive measures, and the importance of effective climate policy to avoid inequitable outcomes for underrepresented communities.
The RAC’s final proposed rules will be submitted to LCDC in February 2022, and LCDC anticipates publishing its draft rules in March 2022. LCDC anticipates holding public hearings on the draft rules in April and May 2022.
Read the rest of Rogue Advocates’ comments here, and stay up-to-date with LCDC’s rulemaking process here. You can submit public comment in advance of the next (and final) RAC meeting on January 20, 2022 by emailing DLCD.CFEC@dlcd.oregon.gov at least three working days prior to the meeting.