After Obama’s original cap-and-trade plan failed, he started using the agency regulatory powers directly. (This is how Obama has been able to issue new regulations on cars, fuel, appliances, and future power plants.)
So far, there is one hole in his regulatory agenda: power plants that currently exist. This is, unfortunately, a very large hole, as these plants, mostly coal, emit 40 percent of all U.S. carbon emissions....
Then, a few weeks after last year’s election, the Natural Resources Defense Council published a plan for the EPA to regulate existing power plants in a way that was neither ineffectual nor draconian. The proposal would set state-by-state limits on emissions....Much like a cap-and-trade bill, it would allow market signals to indicate the most efficient ways for states to hit their targets—instead of shutting coal plants down, some utilities might pay consumers to weatherize their homes, while others might switch some of their generators over to cleaner fuels....Here is a way for Obama to use his powers—his own powers, unencumbered by the morass of a dysfunctional Congress—in such a way that is neither as ineffectual as a firecracker nor as devastating as a nuke: The NRDC calculates its plan would reduce our reliance on coal by about a quarter and national carbon emissions by 10 percent....
[NRDC's] Lashof predicted the following sequence of events. The agency will finish drafting its regulation scheme by the end of the year. It will then take about a year of public comments and revisions, at which point it will finalize its rule. That will be the end of 2014, just after the midterm elections. Another nine months to a year will be required to carry out the rule, which will get us to the end of 2015—and the international climate summit.
I've thought the most likely outcome is that Obama would do the wrong thing on Keystone and match it with a right thing on something else about climate. Not sure if the timing proposed above would make it the right thing to be matched with Keystone. This is far more important than Keystone, though, if it happens.
The remainder of Chait's article argued that Obama has used the regulatory structure as much as he could for small-bore climate actions, and if you set aside the bully pulpit issue then he's done a decent job. My impression, not backed by solid data, is that he passed up a lot of politically viable chances for small-bore actions on climate.
NRDC's proposal is here. Basically your state's average emission rate has to be somewhat better than a combined rate for coal and natural gas produced by current plants, with the combined rate determined by the mix of coal and gas you currently have. AFAICT if your state already has little coal and a lot of renewables, you don't have to do much, but if your state has a lot of coal power, the punched is eased somewhat. Many different trading devices allowed to reduce emissions rate, including purchasing efficiency efforts by consumers.
UPDATE: clarified per the comment.
*ICYMI, ICYMI, means in case you missed it. I missed it when it came to that acronym for a while.