Weathervane: A Climate Policy Blog from Resources for the Future

Jun23

Tune in Today: Toward a New National Energy Policy

As energy policy discussions slog along on Capitol Hill RFF researchers will today share the findings of a two-year research program, operated with the National Energy Policy Institute, aimed at assessing various major energy policies. You can watch the event live, starting at 9 a.m. EST here.

Their study, Toward a New National Energy Policy: Assessing the Options (executive summary and key findings available here), focuses on several key metrics that chart the effectiveness of alternative policies—specifically, in reducing oil consumption and greenhouse gas emissions—and assesses the economic costs they impose on society. Panelists at today’s event will examine how individual policies and combinations of policies compare to each other, and will highlight under what circumstances policies may be complementary or redundant.

Published: Jun-23-10 | 0 Comments

Jun11

Murkowski Amendment Update

Congress, EPA

The Senate has voted down Sen. Murkowski’s (R-AK) amendment that would have invalidated the EPA’s greenhouse-gas endangerment finding. I wrote about the amendment a few months ago, and predicted that it wouldn’t pass—largely because it had to overcome four hurdles to become law. Yesterday the amendment fell at the second hurdle when the full Senate rejected it. As a practical matter, I don’t think the vote means very much since neither the House nor the president would have been at all likely to sign on to the measure even had it passed the Senate.

One way to look at the rejection of the amendment is that it’s a good sign for action on climate in the Senate. I don’t think that’s right. The amendment failed 53-47, with all Senate Republicans and six Democrats voting for it. For this kind of measure, that’s close to passing—unlike new legislation, the amendment requires only 50 votes to pass, not 60. If you have 47 Senators against EPA action on climate, it’s hard to see how you get 60 for new legislation.

Now its possible that some of those who voted for the resolution did so for political reasons (easy when you know the measure will fail) and might vote for a climate bill. That’s plausible, but a closer look at the list of Democrats supporting the amendment makes me skeptical. There are no surprise “yes” votes; they’re all from the South or coal states and are not considered proponents of climate legislation. These six—Bayh, Lincoln, Landrieu, Nelson, Pryor, and Rockefeller—are the senators that will have to be brought on board to get a climate bill (plus one Republican, and without losing any other Dems). Their votes for the Murkowski amendment aren’t a good sign.

The EPA’s Clean Air Act powers to regulate greenhouse gases also aren’t safe yet. Sen. Rockefeller (D-WV) has another proposal to curtail that authority. It would require 60 votes, but as I’ve written before, it at least makes more sense than Murkowski’s proposal (since it would delay, rather than cancel EPA authority, and since it targets the most controversial, rather than least controversial part of that authority). Other senators have preemption proposals (some broader, some narrower) that may be considered in the future. Rockefeller’s proposal stands a good chance of passing the Senate, I think, given the vote breakdown for the Murkowski amendment. If it needed 50 votes instead of 60, I’d be sure it would pass. That doesn’t mean it would pass the House or be signed by the president, however. I don’t see this House agreeing to any substantial preemption of EPA authority outside of a climate bill, and I don’t see the president doing so as long as he’s in office.

This means the EPA will continue to move towards substantial greenhouse gas regulation over the next year. It will be interesting to see how that regulation affects the politics of climate. Will it make a bill more likely, or less? Hard to say for sure, but I tend to think EPA action will push at least some in industry to demand Congress finally do something, and I think there’s a better chance for that to be positive (a climate bill) than negative (naked EPA preemption).

Nathan Richardson is a Visiting Scholar at RFF. He also contributes to The Progressive Fix.

Published: Jun-11-10 | 0 Comments

Jun09

Indiana Senator Unveils 'Practical' Energy Plan

Congress, United States

Set in the frame of increasing American energy independence and improving energy efficiency across the board, Sen. Richard Lugar, R-Ind., released his plan (summary and entire bill) to increase national security and reduce greenhouse gas emissions today.

The Lugar Practical Energy Plan sets out to, by 2030, reduce American’s foreign oil consumption by 1.75 billion barrels. It also aims to cut energy use by 11 percent and reduce greenhouse gas emissions by 20 percent, when compared with business as usual, without putting a cap on greenhouse gas emissions.

Ezra Klein describes the gist of the bill as, “picking the low-hanging fruit on reining in carbon emissions,” and chatter about the plan centers largely on its general passibility. The Deepwater Horizon accident has put a spotlight on U.S. energy policy and, to use a lame metaphor, the public support pump is primed for the passage of energy legislation. Gossip has it that an energy-centric bill, like the one Lugar has proposed, may get a concerted push with the more ambitious climate plan from Sens. Kerry and Lieberman added as an amendment.

However absent a (say it with me now) price on carbon the environmental benefits of the bill will take a back seat to energy efficiency and security. But at least it’s a start. It seems the question before Senate Majority Leader Harry Reid is is a good start good enough?

Other highlights from the Lugar Practical Energy Plan:

Efficiency standards for medium and heavy-use vehicles
Energy savings from newly-constructed buildings of 30 percent by 2012 for residential and commercial properties
$2 billion in funding to retrofit existing buildings with technologies to improve energy efficiency
Clean energy standards—including nuclear power and ‘clean coal’ technologies—increasing to 50 percent of the nation’s energy portfolio by 2050
Voluntary retirement program for coal-fired power plants and additional $36 billion in nuclear loan guarantees

Published: Jun-09-10 | 1 Comment

May19

Kerry-Lieberman and the EPA

Cap and Trade, Clean Air Act, Congress, EPA

This post was updated on 5/21/2010

While climate legislation is moving through Congress, the EPA (as most of you know) is moving ahead with greenhouse-gas regulations under the existing Clean Air Act. Industry groups and many in Congress think the two paths should be mutually exclusive – they want new climate legislation to preempt the EPA’s existing authority. Many environmental groups want to keep both tools. Some states have also requested that Congress preserve EPA authority.

I’ve questioned elsewhere whether leaving Clean Air Act authority intact gets very much in the way of environmental results (though note that even if preemption isn’t very costly from a policy point of view, opposing it could be very useful from a strategic point of view – it’s a useful bargaining chip).

But this debate doesn’t have to be hypothetical anymore. We have draft bill text in the form of Kerry-Lieberman, and it’s worth taking a look at what effect it would have on EPA authority.

In short, the bill would preempt almost every major element of EPA Clean Air Act authority by preventing the agency from using most Clean Air Act programs to regulate pollutants based on their climate change effects. In a general sense, Congress would be repealing the holding of Massachusetts v. EPA that greenhouse gases (GHGs) can be regulated under the existing statute (and, of course, replacing the old statutory provisions with a new set of cap-and-trade tools).

But there are exceptions to the preemption: one big one that actually leaves the narrow holding of Massachusetts v. EPA intact, one relatively small one, and a variety of tiny ones that might be noteworthy, but probably interest only me and other climate law wonks.

Preemption

Kerry-Lieberman aims a series of rifle shots at the foundations of each of the existing programs the EPA might use to regulate GHGs. Section 2301 of the bill would block the agency from setting national air quality standards (NAAQS) for any pollutant based on climate change effects. Section 2303 would similarly forbid the agency to regulate GHGs as hazardous air pollutants, and Section 2304 would prevent the agency from using a little-used part of the Clean Air Act (Section 115, governing international emissions) that has been discussed by some as a plausible choice for regulating GHGs. Section 2302 blocks the agency from issuing GHG performance standards (NSPS) for sources covered under the cap – or emitters that the bill treats as sources of offsets. Finally, Sections 2306 and 2307 prevent the agency from requiring emitters to get permits (NSR) based only on their GHG emissions.

These five programs – NAAQS, hazardous air pollutants, NSPS, Section 115, and NSR permitting are the only routes available to the EPA to implement big regulations for stationary GHG emitters. By preempting this authority, Kerry-Lieberman blocks the agency from economywide GHG regulation under the existing CAA.

Mobile Sources Excepted

But this broad preemption applies only to stationary sources – what about the transportation sector? Like Waxman-Markey before it, Kerry-Lieberman largely leaves EPA authority to regulate vehicles alone. This means that the EPA’s recent rule setting new vehicle fleet emissions standards would stand – and could be strengthened in the future. This is the core result of the Massachusetts v. EPA decision – that the EPA has the authority to regulate GHGs from vehicles under the current statute – and it would continue to be the case under the new bill.

This isn’t surprising. Unlike EPA regulations of stationary sources (which are often portrayed as expensive and inefficient, though our research suggests they aren’t necessarily so bad), fleet fuel-economy and emissions regulations are broadly popular. The EPA measure released recently is in part the result of a compromise between states, the EPA, and the car industry. Whatever it’s flaws, it’s more politically expedient to let it stand than to preempt it and create a new program (though the new bill would bring transport-sector carbon emissions into the price mechanism as well).

Some Performance Standards Excepted

As I mentioned above, the EPA wouldn’t be able to set GHG emission performance standards for emitters that are subject to the cap set by the bill. The EPA would still be able to set such standards for uncapped sources, however. For example, industrial sources that emit less than 25,000 tons/year of CO2-equivalent GHGs aren’t included under the Kerry-Lieberman cap. The EPA would still have authority to regulate these sources under the Clean Air Act.

~~This isn’t much of an exception, however.~~ The EPA has shown no interest in regulating such small GHG sources to date. The tailoring rule it released this week exists solely to avoid regulating small sources, and it’s unlikely that the agency would have a newfound interest in them if the bill were to pass.

Update: It appears that this exception is somewhat broader than I initially realized. The bill in fact allows EPA to set performance standards for most coal plants as well. Specifically, the EPA can (through the states) set standards for all coal plants permitted before 2009, and also all plants permitted more recently, until the agency determines carbon capture and storage technology is available or 2020, whichever comes first. When either of those things happens, the bill has its own, new, performance standards that essentially require CCS.

If you’re not interested in the deep details of EPA preemption, you can stop reading – though if you’ve gotten this far. . .

Loopholes

Beyond these apparently intentional exceptions, the bill has some smaller loopholes which would allow the EPA to exercise its existing authority. These may be unintentional, or may simply have been thought too trivial to be worth addressing.

First, the statute allows the EPA to consider the effect on GHG emissions of performance standards it issues for other pollutants. This would allow the EPA to consider the climate-change “co-benefits” of regulations on traditional pollutants like sulfur dioxide: if the agency tightens regulations on those pollutants, fuel switching or technical changes could reduce GHG emissions as well. Of course, this can cut in the other direction: some regulations on traditional pollutants could increase GHG emissions – and the EPA could consider that too.

Second, Sections 2306 and 2307 of the bill that limit the ability of the agency to require permits from GHG emitters aren’t completely clear. My interpretation of these sections is that the EPA wouldn’t be able to require permits based on GHG emissions alone, but that the agency could consider GHG emissions for a source that is required to get a permit for other reasons.

Finally, and this may really only interest me, the bill prevents the EPA from using some of its existing authority based on a pollutant’s climate change or ocean acidification effects. In other sections, though, ocean acidification isn’t mentioned. The EPA could still in principle use ocean acidification (or other non-climate harms) to allow regulation under those programs. The chances of the EPA actually attempting this approach zero.

It’s possible there are other loopholes that I haven’t noticed, and it’s possible that those I point out will be filled in a final version of the bill.

Despite these loopholes and exceptions, however, I think the right story to tell about the bill is that advocates of EPA preemption have gotten essentially everything they asked for.

http://www.flickr.com/photos/sierraclub/ / CC BY-SA 2.0

Published: May-19-10 | 0 Comments

May17

How Kerry-Lieberman Stacks Up

Congress, Cap and Trade, Waxman-Markey, Carbon Market, Cap and Dividend

Wondering how the recently-released Senate climate bill stacks up to the rest of this Congress' market-based legislative efforts? RFF's Danny Morris has this side-by-side comparison chart to shed some light on that question.

Click to Enlarge

Daniel F. Morris is a Research Associate with Resources for the Future. He’s a regular contributor over at the Progressive Fix and has been know to write a thing or two for Common Tragedies

Published: May-17-10 | 0 Comments

May13

Exelon CEO Praises Market-Based Climate Solution

Congress, Nuclear

Top brass at one of the nation's largest utility companies says the path Sens. John Kerry (D-Mass.) and Joseph Lieberman (I-Conn.) mapped yesterday to address climate change and set the nation on course for a low-carbon future is a step in the right direction.

Speaking at a Resources for the Future Policy Leadership Forum Wednesday, Exelon Chairman and CEO John Rowe offered praise for the (protracted) efforts of the duo and its (now) shadow compatriot, Sen. Lindsey Graham.

“By implementing a market-based solution that puts a price on carbon emissions, we can take major steps toward a low-carbon economy for an incremental 3 to 5 cents per kilowatt hour,” Rowe said. “But if we just pick the technologies we think are most elegant, with no regard for cost, we could spend three times the cost the markets would give us, as much as 10 cents per kilowatt hour.

Rowe took his speech as an opportunity to release an updated illustration of the affordability of meeting his company’s goal to eliminate its 2001 carbon footprint by 2020. The image provides some interesting insight into the most cost-effective ways to reduce greenhouse gas emissions.

Click to Enlarge

Still, he made no bones about his preferred energy source. Exelon operates the nation’s largest fleet of nuclear facilities with sites across the Midwest and a few on the East Coast. But as a strong advocate for a market-based solution to the issues of climate change, he concedes he’d find a new preference if the market doesn’t support a robust nuclear portfolio.

“Let’s get these choices on a playing field. Let the market decide and I’ll do what the market tells me, not what I like.”

Tiffany Clements is managing editor of Weathervane.

Published: May-13-10 | 0 Comments

May11

Catching up Before the Senate's Climate Bill

Congress, Kerry-Boxer

After months of anticipation and speculation, the release of the Senate's comprehensive climate and energy legislation is upon us. But what can you make of the ballyhooed bill once the pages are finally in your hands tomorrow?

The Progressive Fix today wrapped up Danny Morris and Nathan Richardson's primer, Cheat Sheet for Climate Policy. There are many complex factors in play here, so go check it out. Danny and Nathan walk you through the essential considerations for legislation, the important ones, the negotiable elements, and what could distract from the passage of a quality bill. And in case you've lost track of the big picture throughout the bills sputters and stalls in the last few months, Dave Roberts breaks down the state of political play over at Grist.

That should keep you busy for the rest of the day.

Published: May-11-10 | 0 Comments

May07

Updated: Applying Yesterday's Energy Lessons to Tomorrow's Energy Policy

Congress, Testimony

As national attention converges on the Gulf Coast in the wake of the Deepwater Horizon accident, plenty are wondering what implications the spill may have for the future of U.S. energy policy. But with the short and long-term policital and economic landscape uncertain to say the least, maybe reflecing upon past energy policies will prove more fruitful than attemptin to read the tea leaves for the future.

RFF President Phil Sharp and Robert Fri, visting scholar and former RFF president, recently sat down to reflect upon the economic and technological lessons learned througout the last of 40 years of American energy policy. Their audio comments are available for streaming here (Sharp) and here (Fri). You can read more of their reflections on contemporary energy policy in this post, featuring links to testimonies delivered before the Senate Committee on Appropriations Energy and Water Development Subcommittee.

Tiffany Clements is managing editor of Weathervane.

Published: May-07-10 | 0 Comments

May04

Can the Senate Climate Bill be Exposed with FOIA?

EPA, Congress

After the dramatic cancellation of last Monday's unveiling, the Kerry/Graham/Lieberman Senate climate bill is on hold. Everybody interested in climate policy wants to know its contents. Some of them have taken matters into their own hands. Energy & Environment News and the American Energy Alliance (an industry group) have filed Freedom of Information Act (FOIA) requests with the EPA seeking materials related to the bill that the senators have sent to the agency for analysis. If successful, these requests would make the bill proposal (or at least its framework) public.

The EPA claims it doesn't have much, certainly no legislative text, but that’s still more than anyone outside of Congress appears to have. Whatever the agency does have, will these FOIA requests succeed?

Somewhat surprisingly, I think they might. None of the standard exceptions to FOIA requests (like national security, private information about individuals, etc.) appear to apply.* The reason why the EPA, and not Congress, is the target of the FOIA request is simple: FOIA does not apply to Congress at all, only executive agencies. But the EPA admits it has something—so it should, in principle, be reachable through FOIA.

Congress is also protected by the Speech or Debate Clause of the Constitution, but this generally applies only so long as information is within Congress’ control. For example, efforts to prosecute former senator (and presidential candidate) Mike Gravel for obtaining the Pentagon Papers and reading them into the official record of a Senate subcommittee failed due to the protection offered by the Speech or Debate Clause. However, the clause did not protect an independent publisher to whom Gravel had given the papers. For FOIA requests, the relevant test (Goland v. CIA, 607 F.2d 339) is whether the material held by the agency has “passed from the control of Congress and become property subject to the free disposition of the agency with which the document resides”. If it has, then it is an agency document subject to FOIA.

So did the climate bill pass from congressional control when it was sent to the EPA? It’s hard to tell, since we don’t know under what terms the information was given. If Congress told the EPA to keep the information secret and return what it had been given, Congress might be said to have retained control. Otherwise, it may not have. There is apparently no specific time when Congress has to assert continuing control, but cases suggest that doing so after the FOIA request is made is too late (though one case claims a congressional resolution would be sufficient even after the FOIA request). Of course, Congress can always fix the problem in the future with legislation. A new FOIA exception for all documents created by Congress, for example, would do the job (though EPA analyses based on Congress’ documents might still be subject to FOIA). Since it has the power to change the rules, Congress has the luxury, if it chooses, of facing this kind of problem only once.

So what if the FOIA requests succeed? Leaving aside for the moment any possible changes to FOIA that Congress might make, I tend to think it’s actually a bad thing. I want to know what the senators have planned in their bill as much as anyone, but if FOIA is used to get this information, it will chill congressional attempts to get good analysis of their proposals in the future. If Congress contemplates a climate bill, I want EPA to weigh in; if Congress contemplates a change in defense policy, I’d similarly want the Department of Defense to have some input.

If requests for agency analysis or comment are subject to FOIA, Congress is unlikely to make them. Even FOIA’s most ardent supporters, I suspect, admit the value of private debate in Congress. If agencies can’t be asked to participate without that debate becoming public, then Congress is crippled. That’s not good for good public policy.

* The fifth FOIA exception, for inter- or intra-agency materials, doesn’t apply since Congress is not an executive agency.

Nathan Richardson is a Visiting Scholar at RFF. He also muses on things law and climate over at The Progressive Fix.

Published: May-04-10 | 0 Comments

Apr26

A Plan B for Climate Policy: Part 2

Cap and Trade, Congress

Reeling from a weekend of big climate legislation news and all dressed up with no bill to read, there’s no better time than now to start considering alternatives to an economy-wide carbon pricing program.

In his first post of this series originally appearing on the Progressive Fix, Danny looked at the Cantwell-Collins “cap-and-dividend” bill. This post examines the Carper-Alexander “3P” plan introduced in February. The bill would regulate only non-greenhouse-gas pollutants that some have suggested could be expanded into an electric-sector carbon cap-and-trade plan.

In early February, Sens. Tom Carper (D-DE) and Lamar Alexander (R-TN) introduced what we will call the “3P” (P for pollutant) bill, which tightens emissions of SO₂, NOx and mercury from coal and oil-fired power plants through cap-and-trade markets. While the bill covers only non-greenhouse-gas pollutants, it has been discussed as a possible template for a climate bill targeting the electricity sector—or “4P.”

Carper-Alexander is nothing radically new. Considering how knowledgeable the American public is about cap-and-trade in general, it’s a safe bet to say most people don’t know that there is already a cap-and-trade market working to reduce air pollution from fossil fuel-fired power plants in the U.S. as we speak.

The 1990 amendments to the Clean Air Act established a pollution reduction market to address acid rain in the Northeast. Specifically, it created a cap-and-trade market for sulfur dioxide (SO₂: primarily responsible for acid rain, not a greenhouse gas) and nitrogen oxides (NO and NO₂, both commonly labeled NOx: harmful to humans, primary precursor to ground-level ozone, which is a greenhouse gas) for the eastern half of the country. Since its inception in 1990, it has impressively reduced acid rain problems at much lower costs than initially predicted. It is the example advocates and economists point to when discussing how cap-and-trade can help control greenhouse gas emissions. This program was further strengthened in 2005 when the Environmental Protection Agency (EPA) issued the Clean Air Interstate Rule (CAIR), which established permanent caps and aggressive reductions for SO₂ and NOx emissions beyond the Clean Air Act.

Designed to protect human health, CAIR is in poor health itself. A D.C. Circuit Court in 2008 found it failed to follow Clean Air Act statutory mandates and vacated the rule. The court then reinstated it under the stipulation that the EPA make some significant changes. The EPA is currently retooling CAIR to bring it in line with the court ruling. Just like with carbon emissions, however, it would be nice if Congress stepped up to the plate and made a law that clearly told the EPA how to administer these regulations. Unlike on carbon emissions, there’s a chance Congress can act relatively quickly.

The Basics

The Carper-Alexander bill sets a 3.5 million ton cap for a national market of SO₂ emissions in 2012, then ratchets it down to two million tons in 2015 and 1.5 million tons in 2018, an 80 percent reduction of 2008 emissions. This final limit would remain unless after 2021 the EPA finds a lower cap is needed to protect public health.

The NOx market would operate slightly differently, as the country would be split into two zones, with the eastern states and western states each getting their own NOx market. The eastern market will face a cap of 1.39 million tons in 2012, which will tighten to 1.3 million tons by 2020. The western market will be capped at 510,000 tons in 2012, cranking down to 320,000 ton by 2020. When combined, the two markets will reduce NOx emissions from 2008 levels by 53 percent. The bill calls for mercury to be reduced by 90 percent by 2015, but it is not regulated in a market. Rather, the bill sets a cap for mercury (no trading) and leaves it to the EPA to promulgate the program rules.

A 4P bill could be very similar to the 3P proposal. Likely, the bill would establish a single market for CO₂ emissions from power plants with reduction goals for future years, likely extending out to 2020. The bill could possibly call for New Source Performance Standards on all four pollutants for new plants. It might also include offset provisions for CO₂ production. This legislative approach could be appealing if a more comprehensive proposal fails to gain support in the Senate and legislators begin to look for smaller-scale, more piecemeal approaches to emissions reduction.

The Good

The 3P bill takes aggressive action to reduce harmful air pollutants that derive from the combustion of fossil fuels, namely coal and oil, for electricity generation. Even though it targets only non-greenhouse gas pollutants, 3P could actually lead to indirect climate change benefits. While pollutants capped under the bill can be lowered through the use of filters and other technologies, a 3P scheme could also spur plant upgrades, the retirement of older (and dirtier) plants, and fuel-switching to less carbon-intensive sources, including natural gas, renewables, nuclear and hydropower — all of which would lead to lower carbon emissions. By successfully applying a cap-and-trade system for mitigating environmental damages, 3P also reinforces the notion that these systems can work in the real world without harming the economy.

Furthermore, 3P saves the EPA from legal limbo by clearly establishing the reduction goals for SO₂, NOx and mercury emissions over the next 10 years and providing clarity for both firms and regulators. The bill also seems politically innocuous — even infamous climate change denier Sen. Jim Inhofe has said vaguely positive things about it. If the Obama administration goes looking for a bipartisan win on the environmental front, it may look to push the 3P.

The Bad

As already mentioned, 3P is not a climate bill, though it may have some indirect climate benefits. But even a 4P climate bill would be less than ideal. If CO₂ were added to the 3P’s list of targeted pollutants, the bill would still fall short as it would regulate only the electricity sector — transportation, manufacturing and other carbon-emitting sectors would evade regulation. Electricity generation accounts for roughly one-third of total greenhouse gas emissions in the U.S., meaning that a 4P bill would still be far less preferable than an economy-wide cap-and-trade system.

Additionally, were a 4P bill to be structured similarly to the current 3P bill, it would give a great deal of authority for market design and administration to the EPA as CO₂ would technically be regulated under the Clean Air Act. Regardless of your opinion about the EPA’s ability to properly administer a massive emissions market, it’s a political sticking point, as highlighted by current proposals to strip EPA of its authority to regulate greenhouse gases.

The Upshot

The 3P bill could provide a viable pathway for carbon regulation of the electricity sector. If the highly anticipated tri-partisan climate bill from Sens. John Kerry (D-MA), Joe Lieberman (I-CT) and Lindsey Graham (R-S.C.) does not create the kind of momentum for climate and energy legislation the authors are hoping for (more on that in the next entry), one option could be for the Senate to take a more piecemeal, sector-by-sector approach, in which a 4P bill (SO₂, NOx, mercury and CO₂) moves forward.

Both Carper and Alexander have sponsored carbon emissions legislation specific to electricity generation in past sessions of Congress. Both those bills called for electricity-specific cap-and-trade markets to reduce carbon emissions. Carper has signaled he’s open to incorporating his bill into a broader climate bill, though it’s unclear if he meant including CO₂ in the structure of his bill or working the SO₂, NOx and mercury caps into another piece of legislation.

The Carper-Alexander bill provides a simple structure, and clarifies existing regulations within EPA. It would not be an ideal approach to emissions reduction, but if all else fails, it could provide a workable jumpstart. The Clean Act Air showed that cap-and-trade can work once before, and it might have a chance to do it again.

In addition to his work at the Progressive Fix, Danny Morris is a Research Associate with Resources for the Future and a regular contributor to Common Tragedies

Published: Apr-26-10 | 0 Comments

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