Building on Oregon Treasury’s 2025 Progress toward Net Zero Emissions - Part 1

February 18, 2026

Part 1: Building on Oregon State Treasury’s 2025 Progress toward Net Zero Emissions 

Divest Oregon applauds initial action, offers recommendations for future reporting, including the use of multiple metrics


To protect the Oregon Public Employee Retirement Fund (OPERF) from the financial and climate risks of the energy transition, the Oregon State Treasury is one of the few state pension funds with a strategy and commitment to reducing emissions across its portfolio. As part of this commitment, Treasury recently published its “2025 Progress Report: Tracking Net Zero and Climate Positive Investment Strategies.” Divest Oregon, a grassroots coalition representing unions, racial and climate justice groups, youth leaders, and faith communities, has previously applauded Treasury’s progress toward reducing its emissions and welcomes this report.


This progress reflects previous Treasurer Tobias Read’s commitment to Net Zero, the passage of the 2024 COAL Act and the 2025 Climate Resilience Investment Act (CRIA) as well as years of stakeholder, legislative, and coalition engagement (including with Divest Oregon). 


Part 1 of Divest Oregon’s review is below. Part 2 can be found here.


In her cover letter and public outreach for the report, Treasurer Steiner has emphasized three major “results of this strategy:”

1. A 50% drop in the “emissions intensity” in OPERF from 2022 to 2023

2. A doubling of “climate-positive” investments as of June 2025

3. A steady decline in fossil fuel private market holdings since January 2023


Divest Oregon has reviewed the report in depth, carefully analyzed these findings (read our full analysis here), and developed specific recommendations for future reporting from the Treasury. 


To understand these results, Divest Oregon took a deep dive into the numbers, asking not only “how could this happen” but also “what else can we learn about OPERF’s carbon emissions footprint?”


A 50% Drop in Emissions Intensity?

Treasury reports a 50% drop in emissions intensity in the OPERF holdings from 2022 to 2023 (the only time period considered in emissions calculations in the report).


A 50% reduction in any emission metric would indeed be remarkable, especially during years when the EPA estimated US emissions dropped by only 4%. How could this happen? 


There are multiple ways to measure portfolio emissions in the financial world, depending on what aspect of decarbonization you are interested in.


Pension funds are interested in measuring “transition risk” — the challenge the companies they invest in face in transitioning to a renewable energy future. They measure their holdings’ “emission intensity” to evaluate the size of that “transition risk.”


The emissions intensity metric measures how much carbon a company emits relative to the company’s revenue. In this case, “revenue” refers to the total amount of money a company earns from its operations, such as selling goods or providing services, before any expenses are deducted. The more emissions per revenue, the greater likelihood of a greater “transition risk.”


Here’s the catch: Even if emissions increase, the emissions intensity number can still decrease — simply because revenues (the divisor in the calculation) increase even more, which really doesn’t change the transition risk.

That appears to be what happened between 2022 and 2023:


  • The emissions associated with OPERF investments actually increased by 28%...
  • but because the reported revenue associated with its investments increased by 195%...
  • the “emissions intensity” fell 50%
When revenue grows faster than emissions, the emissions intensity falls — 
even if the climate impact doesn’t improve.

This surge in revenues was driven mainly by one asset class: private equity – and one company within private equity.


The report states that private equity revenues associated with OPERF’s investments went from $242 Billion in 2022 to over $1 Trillion in 2023 – an $780 Billion increase making up 80% of the total revenues associated with its investments. How could that happen?


Because private equity data is confidential, Treasury relied on modeling rather than company-reported numbers. That makes the results hard to analyze. The report states that private equity’s revenue increased over fourfold from 2022 to 2023 and Treasury shared with Divest Oregon that it attributed this exceptional increase to an indirect stake in a large global technology company with low emissions.


The total 2023 revenues of this global tech company make it a significant market outlier, but there is no way for outside organizations to verify this revenue. 


If OPERF’s share of its revenue, as a partial investor, is anywhere near $780 billion, total company revenues would have been multiples of that, into the trillions of dollars. Yet, no company worldwide is reported to have made anywhere near that level of revenue in 2023, or subsequently.


Treasury based much of its 50% improvement in Emissions Intensity on this one outlier. 


The Key Net Zero Measure: “Financed Emissions”

Achieving Net Zero for OPERF’s portfolio involves tracking and cutting emissions financed by pension plan dollars until they are balanced out by assets that actively remove carbon from the atmosphere. 


Tracking progress to Net Zero depends on tracking the total amount of carbon “owned” by the portfolio’s money. The share of carbon pollution the pension fund itself is responsible for, based on the percentage of the investment it is holding, is called “financed emissions.”


Using this metric:


  • OPERF’s total financed emissions rose from 35.8 million to 46 million tons of CO₂e (CO2e is “CO2 equivalents” as defined in the Treasury’s Report)
  • That’s a 28% increase… but, again, most of this comes from one asset class: private equity
  • According to the Report, nearly half of OPERF’s financed emissions increase came from OPERF’s private equity holdings.


If we exclude the modeled private equity data, a different picture emerges. Outside of private equity, the portfolio’s climate footprint appears largely unchanged. This aligns with broader trends: U.S. emissions changed only modestly over the same period.

Multiple Metrics Tell the Whole Story

Taken together, without the private equity data, these two metrics tell a story of rising revenues during a period when emissions remained about the same. And that is the story of 2022 to 2023, years when the economy was recovering from COVID shocks and energy demand increased. 


The reduction in emissions intensity was years before Treasurer Read presented the OST Net Zero Plan and focused staff on strategies to lower the pension fund’s carbon footprint.


No single view of a complex situation is likely to be accurate. Different climate metrics tell different stories and are needed to help tell the full story:

  • Emissions Intensity (carbon per revenue) reflects transition risk of the portfolio’s holdings — and is greatly affected by swings in the economy. This is the metric the Treasury used to determine its 50% reduction from 2022 to 2023.
  • Financed Emissions (total carbon owned) reflects the portfolio’s progress toward Net Zero. Although not highlighted or discussed, this metric is also reported.
  • Financed Emissions Intensity allows internal and external comparisons based on a portfolio’s financial responsibility for emissions.


Relying on the single number of Emissions Intensity — especially one tied to economic swings — can create a misleading snapshot. Experts recommend a dashboard approach using multiple measures. 


Better transparency about data quality and assumptions — especially for private equity — would help the public understand true progress.

But, perhaps most importantly, metrics themselves are just numbers. Understanding what is happening behind the numbers, why they go up or down or stay the same, is what makes numbers a meaningful guide to achieving goals. Without context, it is impossible to know what they really mean.


A Doubling of Climate-Positive Investments

To its credit, the Treasury reports that climate-positive investments doubled between 2022 and mid-2025, in line with the Net Zero Plan’s goal of tripling these investments in real assets and private equity by 2035.

These total about $2.4 billion in Real Assets, or roughly 2.4% of the portfolio.


This increase indicates movement in the right direction, though there is room for progress. As with other metrics, context matters: California’s public pension (CalPERS) has committed to investing about 18% of its portfolio in climate solutions by 2030. OPERF should follow suit. 


Private Market Fossil Fuel Holdings: Declining — or Just Losing Value?

Treasury reports that private fossil fuel holdings have declined since 2023.


But the report only shows market value. That makes it unclear whether the fund sold or exited fossil fuel assets or if these assets simply lost value.


From this report of annual investments, there is no way to know whether the fund is truly reducing exposure. More transparency is needed.


Building on Progress for Future CRIA Reports

Divest Oregon recommends several practical improvements for the next report mandated by the CRIA legislation and due at the end of 2026. 


The Oregon State Treasury should:


Develop a dashboard that includes multiple climate emissions metrics, including financed emissions, and provide data quality scores for the calculated emissions metrics.


Include scope 3 emissions more prominently to fully reflect real portfolio emissions.


Demonstrate more transparency by clarifying private equity assumptions (including estimates or modeling to support inclusion or exclusion of the data), defining what is considered a climate-positive investment, and providing more specificity about fossil fuel investments.


Increase insights and ambition in implementing CRIA by: Explaining how measurement results will guide future decisions including goals and timelines; Demanding transition plans for all private market funds with fossil fuel investments - no matter the amount invested; Stating goals and timelines for emissions reductions; Striving for a higher percentage of climate positive investments; Reporting on progress towards just transition including workers’ rights and Free, Prior, and Informed Consent.


See Part 2 of this blog for a continued analysis of the NZP Report.

September 25, 2026
Global emissions are up. Private equity is a culprit – and so is the Oregon Treasury. Private Equity Climate Risks consortium has just published its latest scorecard and report , endorsed by 21 organizations working on climate, environmental justice, financial accountability, and consumer issues, documenting (pages 10-28) that: ⚠️ 20 private equity firms’ energy portfolios: are responsible for producing an estimated 1.5 gigatons of greenhouse gas emissions annually. include more than 1,000 assets: 244 energy companies 250 oil and gas fields 15,000 miles of pipelines 35 LNG terminals 13 coal terminals dozens of LNG tankers hundreds of fossil fuel power plants. The Guardian (9/15/2026) on the Private Equity Climate Risks report: World’s top 20 private equity firms produce more greenhouse gases a year than most countries, report finds : Firms manage $7.3tn in assets and could afford to transition away from fossil fuels yet invest in natural gas and coal-fired plants to power datacenters. “Private equity firms have emerged as the largest datacenter owners outside  of big tech.” (See the case study on data centers starting on p 25 of the report.) What about Oregon? ⚠️Six private funds, held by the Oregon Treasury, hold at least 473 fossil fuel assets. These firms are: Blackstone, Brookfield Asset Management, Encap Investments, EQT, Global Infrastructure Partners (GIP), Quantum Capital. All are in the Real Assets holdings. As Private Equity Stakeholder Project commented to the Oregon Investment Council (see Public Comment book of 9/2/2026 , page 8): Through existing OST fund commitments, OPERF likely has exposure to many of these 473 fossil fuel assets, which also create global climate risk. Some funds held by OST are making new investments in fossil fuels, pushing the pension fund further from Oregon’s Climate Resilience Investment Act (CRIA) goals and creating more risk for the fund. One example: BlackRock’s GIP. Oregon invested in GIP (Global Investment Partners fund), created to finance a new LNG terminal (see Is the Oregon State Treasury Supporting Environmental Racism in the Gulf South? Divest Oregon 9/26/2024). The fund is now managed by BlackRock and it plans to acquire AES, a massive US-based utility company that also backs 23 fossil fuel-fired power plants globally. If the AES deal closes, BlackRock’s GIP will nearly double its fossil fuel power plant portfolio to 50, spanning 11 countries.
August 6, 2026
“As a PERS beneficiary, I am horrified that my pension funds private prison contractors and ICE detention centers.” Three recent Letters to the Editor of The Oregonian voice deep disquiet that the Treasury invests in immigrant detention facilities and spyware that are internationally recognized as engaging in human rights abuses and are flagrantly violating constitutional rights – instead of constructive investments. In June 2025, Oregon Treasury data shows investment of $51 million in CoreCivic and Geo Group, private prison contractors, and Palantir, maker of surveillance software used by ICE against US residents. Divest Oregon has been asking the Treasurer for years : Why aren’t investments screened to comply with Oregon Investment Council standards? See the blog: Why is the Treasury still investing workers’ retirement in fossil fuels, ICE contractors, and surveillance technology? for the backstory. In May, Treasurer Steiner stated that Treasury used its shareholder power to vote against four candidates for Geo Group’s board of directors because it was not conforming to Treasury’s investment standards – but kept the stock: Treasurer Steiner is “ deeply troubled ” about ICE contractor Geo Group…but OST has been a shareholder for years. The Treasury is investing public employee money. It has a responsibility to the beneficiaries and to all of us to follow its own investment guidelines. The letters voice a strong call for change: PERS should divest from ICE-contract prisons ( PDF , The Oregonian 7/27/2026) “Human Rights Watch reports that 52 people died in the custody of U.S. Immigration and Customs Enforcement in the first 500 days of President Donald Trump’s second term…." “It is tempting to feel powerless about this senseless waste of life. But here in Oregon, we have an opportunity to make a difference. We can demand that the Oregon Public Employees Retirement System divest from The Geo Group and Core Civic, two of the largest for-profit private prison corporations, which contract with ICE to run immigration detention facilities.” Oregon shouldn’t invest in ICE prisons ( PDF , The Oregonian 7/31/2026) “As a PERS member, I am not comfortable profiting from other people’s misery, and I am confident that others feel the same." “Reduced public investments and increased public awareness could even make investments in Geo Group and CORE Civic less attractive. Oregon should lead opponents of the cruelty in this immigration crackdown, epitomized by these prisons." Divest PERS from ICE-contract prisons ( PDF , The Oregonian 8/3/2026) “As a PERS beneficiary, I am horrified that my pension funds private prison contractors and ICE detention centers." “Oregon State Treasurer Elizabeth Steiner said she was 'deeply troubled' by Geo Group’s practices, and that the Treasury had used its shareholder power to vote against four candidates for the company’s board. Has that vote had any noticeable effect? Will Geo Group change its business practices as a result? These companies might take notice if the Oregon Treasury began pulling its investments.” “Like the people of Minneapolis, Oregon Gov. Tina Kotek, Oregon Attorney General Dan Rayfield and Portland Mayor Keith Wilson stood up to ICE. This is the moment for our Treasury staff to show the same courage."
July 6, 2026
Photo by SpaceX on Unsplash In a July 1 article Reuters reported that Oregon Treasurer Steiner wanted guidance from the federal Securities and Exchange Commission (SEC) about SpaceX. How should pension funds handle the new company with the giant market valuation? SEC Commissioner Mark Uyeda answered Elizabeth Steiner in an interview in Reuters . One takeaway is his simple point that if you don't like the governance arrangements of a stock, don't buy it. A message from the SEC's Uyeda: If you don't like SpaceX's governance, don't buy the shares ( Reuters Sustainable Finance , July 1, 2026) Note: The Oregon State Treasury has $6.8 million in exposure to SpaceX through one public equity index fund and one global equity portfolio ( Portland Business Journal July 2, 2026). Divest Oregon has made the same point to Treasurer Steiner, repeatedly. For example, Treasurer Steiner posted on Facebook on May 6, 2026 that she is “deeply troubled” by the ways ICE contractor Geo Group fails to adhere to Oregon Investment Council (OIC) policy. Divest Oregon responded : The Oregon Treasury has held stock in private prison/immigrant detention contractors for years, in spite of well-publicized abuse. If a company is violating OIC policy the Treasury has an obligation to sell the stock. In fact, Treasury’s screening process can and should prevent purchasing or holding stock that violates OIC/Treasury standards. The SEC Commissioner quoted in the Reuters ’ interview about SpaceX also says pension funds have the duty and ability to do such screening: Question by Reuters to SEC Commissioner Uyeda: "You write that ‘If prospective investors have concerns with the governance arrangements, then their most powerful tool is to not purchase shares of the stock.’ But critics like some big pension funds say the fast-track addition of SpaceX to big indexes could make them unwilling buyers of the stock. What would you say to such critics? Response from SEC Commissioner Uyeda: "Large pension funds have choices with respect to ​their investment decisions as part of their fiduciary duty to the plan. While index funds may have certain conveniences and low costs, there is a trade-off to outsourcing securities selection to a third party. There are alternatives, such as selecting a fund that follows a different index or is actively managed, or engaging in customized direct indexing that would provide more control over the portfolio.”
May 19, 2026
A Geo Group van leaving the Northwest ICE Processing Center in Portland Oregon. May 2026
April 9, 2026
At the March 2026 OIC meeting, John Goldstein from Goldman Sachs spoke of the strength of renewable energy stocks (recap in Net Zero Investor 5/3/2026 ). Bill McKibben shows us how the sector is evolving with battery technology advances. Night into Day ( The Crucial Years substack 3/30/2026): “For the first time, the United States now has the capacity to supply 100% of domestic energy storage project demand with American-built systems,” said Noah Roberts, executive director of the U.S. Energy Storage Coalition. “That is a fundamental shift from where we were just a year and a half ago, when the majority of battery storage systems were imported.” “Already, the U.S. has enough capacity to meet demand for finished grid battery enclosures…. By the end of this year, the U.S. will also achieve self-sufficiency in a higher-value part of the supply chain: the battery cells themselves. It’s a major industrial coup that is bringing thousands of high-tech manufacturing jobs to communities across the country.” Solid-state batteries are becoming a possibility; they promise to solve several problems: “Batteries are now being tested by multiple companies that can go 800 miles on a single charge….“In September, Mercedes drove a modified EQS over 1,200 km (745 miles) using 106 Ah solid-state battery cells supplied by US-based Factorial Energy. Factorial launched the first commercial solid-state battery program in the US …earlier this year.” The Finnish company Donut Labs shows where this is heading: “The Donut batt can charge to full in five minutes…; has a practically unlimited lifespan (100,000 charging cycles); is unaffected by heat and cold (-30C to 100C); and contains no rare earth, precious metals or flammable liquid electrolytes. With all that, Donut Lab says it will be cheaper to produce than conventional lithium-ion batteries…” “And the technological miracles are only beginning. For instance, Christopher Mims reported last week in the Journal on a new round of ‘thermal batteries that store solar power as heat instead of electricity, perfect for use in high-temperature industrial processes.’” “Marija Maisch was reporting in January that…salt-based batteries are nearing price and performance parity, if not for cars then for utility scale batteries.” And this chart shows the surge of batteries coming online as solar installations lose sunlight. Night into day.
March 17, 2026
A question from Divest Oregon, a coalition of a hundred organizations with strong PERS representation, remains unanswered: What screening process does the Oregon State Treasury (OST) use, if any, when investing PERS funds or choosing investment managers? Is the Treasury screening investments in fossil fuel companies? Andrew Bogrand, Divest Oregon’s Communications Director, spoke at the Oregon Investment Council (OIC) in January 2026. He noted that investment in fossil fuels contributes to global instability, using Venezuela as an example. (See this blog .) The current Iran war emphasizes this point. Andrew regularly comments on the ties between insecurity and fossil fuels as a policy lead for human rights and natural resource justice at Oxfam. The argument that fossil fuel investments are a sensible diversification of a portfolio has long been outdated. But looking at the most recently published June 2025 public equity and fixed income data, the Treasury is still investing in fossil fuels. Under fiduciary duty and the Climate Resilience Investment Act ( CRIA ), the Treasury must move to alternative investments that align with the reality of climate change and a rapidly destabilizing world. Is the Treasury screening investments prone to legal liability, human rights abuses, or reputational risk? In an April 2023 report , Divest Oregon called out the Treasury's investment in private prisons and surveillance technology as context for the question: Does the Treasury have a screening process? If so, what is the screening process? One example given in that report was the NSO/spyware technology that OST heavily invested in. The Guardian reported extensively (2022) on the OST’s investment in NSO/Pegasus spyware: “However, it now appears that the Oregon pension fund, one of the most prominent in the US, gave its tacit approval over an investment in NSO several years ago – at a time when security researchers were already publicly raising alarms about the company.” In a more recent report, Oregon Treasury’s Investment Screening Failures ( October 2025 ), Divest Oregon again questioned the Treasury’s investment screening process. Examples of questionable investments included GEO Group, CoreCivic, and Palantir. Investments in GEO Group and CoreCivic fund private prison contractors and ICE detention centers. Investment in Palantir funds ICE surveillance software used against US residents. See additional information below for each of these companies. The most recent public data ( June 2025 ) shows that the Treasury continues to invest in these private prison and surveillance technology companies with a long history of human rights abuses and legal vulnerability. These companies are central to the current federal administration’s construction of a police state and its massive violation of due process. See Trump’s Mass Deportation Campaign ( The New Yorker 3/15/2026). For example: Recent private prison contractor GEO Group news: In February 2026, the Supreme Court found that GEO Group, a private prison operator running an Immigration and Customs Enforcement (ICE) facility, cannot claim governmental immunity from lawsuits for violating human trafficking laws, even if those violations were under government orders. Recent surveillance technology company Palantir news: In Portland, now, Palantir’s Elite app is being used to identify potential deportation targets, generate dossiers on individuals and provide a “confidence score” on the person’s address. ( The Guardian 3/13/2026) Why should the Treasury screen its investments? Screening is necessary to avoid investments that contravene Treasury standards, OIC policy, legal standards including fiduciary duty, or Oregon State law. For instance: The Oregon Department of Justice has recently opened an inquiry as to whether OST investment in companies with contractual ties to ICE violates the Oregon Sanctuary Promise Act of 2021 . The CRIA Act of 2025 mandates that the Treasury: -- “actively analyze and manage” climate risk to the portfolio -- report on its progress toward investing in public equity holdings that incorporate the tenets of a just transition in their overall priorities and portfolio
February 18, 2026
Part 2: Building on Oregon State Treasury’s 2025 Progress toward Net Zero Emissions Divest Oregon applauds initial action, offers recommendations for future reporting, including the use of multiple metrics
January 29, 2026
Thanks to the passage of CRIA and the Coal Act, Oregon is moving toward a more transparent assessment of climate-related risks, engaging with asset managers and companies, and identifying climate-positive investments. OPERF has nearly $90 million invested with Exxon, $40 million in Chevron, and $5 million in Shell. Can the Treasury hold these companies accountable and protect the wider portfolio from major conflict exposure? Following is incisive testimony to the January 2026 Oregon Investment Council by Andrew Bogrand, Divest Oregon’s volunteer Communications Director. For over five years, the Divest Oregon coalition has encouraged the Oregon State Treasury to take seriously the financial risks associated with fossil fuel investments, particularly within the context of the wider energy transition. Treasury, as well as the Oregon Investment Council, has listened and responded. Thanks to the 2025 Climate Resilient Investment Act (CRIA) and the 2024 Clean Oregon Asset Legislation (COAL) Act , our state is moving toward a more transparent assessment of climate-related risks, engaging with asset managers and companies, and identifying climate-positive investments. Of course, much of the work remains. In the spring of 2025, Divest Oregon provided testimony to lawmakers in Salem about the coalition’s support of CRIA. We shared how the bill would help Treasury address “new economic realities, where geopolitical contestation…and natural resource competition will upend the financial logic of passive investing.” A year later, this statement rings painfully true. We stand on the precipice of resource-driven conflicts in Venezuela, Greenland, and Iran. We are witnessing a deterioration of the international rules-based order, which will come with serious financial implications. This breakdown is not random. Chevron has played “the long game” in Venezuela, spending millions lobbying the Trump administration and positioning itself to profit following the US invasion. Shell is seeking a multi-billion gas project following the illegal ouster of President Maduro, which presumably also secured ExxonMobil’s interests – not in Venezuela, but in neighboring Guyana . And, the American Petroleum Institute, an industry lobby group including Chevron, Shell, and Exxon, recently pledged to “stabilize Iran” if the regime is ousted there, too.  Of course, whether these companies will profit from this new era of resource colonialism remains unclear. Darren Woods, the CEO of ExxonMobil, said bluntly that Venezuela is “un-investable.” Chevron has also acknowledged that any future work in Venezuela will require extensive guarantees and long-term stability, conditions which remain absent. Despite all the money spent on lobbying, the oil market remains volatile and these companies will likely seek taxpayer support and sanctions relief for risky bets abroad Treasury has nearly $90 million invested with Exxon, nearly $40 million in Chevron, and over $5 million in Shell. Now the question is how to hold these companies accountable and protect the wider portfolio from major conflict exposure. Not all energy companies are equal. In contrast to Chevron, France’s TotalEnergies, which Treasury also owns, has no intention to enter Venezuela despite its operations in nearby Suriname, presumably worried that their presence could make a humanitarian crisis worse or even directly fund human rights violations. If Treasury is serious about engagement, as set forth in CRIA, now is the time to exercise this commitment toward the most politically-exposed companies. Extraction by military force pushes the absolute boundaries of the social license to operate and undermines other holdings in Treasury’s portfolio. Companies have a major and well-recognized responsibility to avoid contributing to war. This responsibility is rooted in the UN Guiding Principles on Business and Human Rights as well as in international humanitarian law. Companies are expected to conduct rigorous human rights due diligence to ensure that their operations, supply chains, and technology do not fuel or contribute to conflict. If companies like Chevron and Exxon fail to respond to engagement along these lines then divestment is both an appropriate business decision -- and the right thing to do.
November 6, 2025
Oregon Treasury Investment Team Causes $3.7 billion loss to PERS Retirement Fund since 2023. Treasury staff disregarded policies limiting private equity investments. Overview A Divest Oregon analysis of Oregon Treasury private equity investment practices finds that years of exceeding the Oregon Investment Council’s (OIC) policy limiting high-risk private equity significantly reduced the performance of the Oregon Public Employees Retirement Fund (OPERF). These effects total about $3.7 billion in reduced value since 2023 . At the center of this issue is Oregon Treasury Chief Investment Officer Rex Kim and his investment team , whose long-term private equity acquisitions significantly exceeded OIC’s risk tolerance for OPERF as stated in its investment policy targets. The OIC is a trustee , and an agent’s failure to follow a trustee's instructions is a breach of trust . These events raise broader questions about policy oversight, internal accountability, and the Treasury’s ability to align its investment practices with new directives under the Oregon Climate Resilience Investment Act (CRIA) . Policy Departures and Oversight Challenges Since at least 2019, OPERF’s investments in private equity substantially went over the levels established in OIC’s policy targets. Corresponding reductions in lower-risk public equity went well below target. While the OIC sets investment targets, it relies on Treasury investment staff to implement them faithfully. By 2022, excessive amounts of private equity led to urgent pressure within OPERF to obtain cash for PERS benefit payments. Treasury then undertook substantial sales of public equities. During this time, the CIO argued ( audio at 1:26:40) that OIC’s private equity policy target was just “some 20 per cent artificial number” and existing overinvestments in private equities should continue. His remark highlights the continuing tension between policy set by the OIC and its implementation by Treasury leadership. Documented Financial Impact In 2025, the Oregon Journalism Project reported that Treasury’s overinvestment in private equity reduced OPERF’s exposure to better-performing public equities and caused $1.4 billion in lost value during 2024 alone. Treasury officials did not contest the reported dollar loss, although Treasurer Elizabeth Steiner noted that a single-year snapshot cannot fully capture the long-term effects of complex portfolio dynamics. Nonetheless, she acknowledged in October 2025 the need to rebalance OPERF’s exposure away from private equity toward more liquid, lower-risk assets. Broader Review by Divest Oregon Following Oregon Journalism Project reporting, Divest Oregon conducted an independent examination of Treasury’s investment return statements from January 2020 through the third quarter of 2025. Impacts were calculated by looking at investment yields as they would have been had the Treasury leadership followed OIC policy targets, and comparing them with the yields that Treasury reported. The analysis confirmed the substance of the Oregon Journalism Project’s finding of a $1.4 billion underperformance in 2024, and identified additional damage to OPERF returns totaling $2.3 billion for 2023 and 2025. Divest Oregon’s Chart 1 shows these underperformances resulted in cumulative damage of $3.7 billion to OPERF returns since 2023. Had Treasury met the OIC targets, Divest Oregon calculates that OPERF’s total returns would have increased by 1% to 1.5% annually in 2023 and 2024, improving the system’s funded ratio in 2024 by roughly 1% , from 73% to 74%.