Friday, September 11, 2015

Play it again Uncle Sam - climate action for the next president without Congressional approval

I was going to write about Clinton's initial climate plan and still will, but I got distracted with a plagiarism proposal I want to suggest. Much of her plan requires Congressional approval, and we all now how problematic that will be. What can be done without it?

I think the answer is a lot - just by doing more of what we're already doing, by plagiarizing Obama's Clean Power and making it stricter. More specifically, wait until the Clean Power Plan has cleared all its legal hurdles, and then set up the sequel. (NOTE:  this refers to the Draft CPP and was written before the final CPP came out with substantial changes).

It's not all the easy to find the guts of the CPP, but it's here (starting on page 8). A modified version of each state's predicted baseline carbon emission rate per MWh is established, and here (page 34837, assuming I've read it correctly) each plant has to meet that average rate or find a way to offset the excess, possibly through some state-established system. If all the above-average emission facilities have to get to average levels in some form, then the total emissions go down.

CPP tries not to be arbitrary, so making it tougher in a non-arbitrary way presents a challenge. OTOH, one factor in determining the predicted baseline rate is each state's future Renewable Portfolio Standard (see first link, page 15). If instead of using the individual RPS, the EPA applies the best-in-class RPS from a similarly-situated state, then that could significantly knock down the baseline average emission that plants would have to match.

Figuring out the best-in-class is somewhat flexible, but you could look at every state with a similar or worse level of existing percentage of renewables, take the one that has the highest RPS for the future, and determine that to be the best-in-class. This wouldn't force each state to match the toughest RPS, because they could find other ways to reduce carbon emissions.

This is my version of the "if ain't broke, do it some more" rule. Regardless, serious presidential candidates need to say what they will do on climate change if Congress doesn't cooperate with reality.