Selected category: Greenhouse Gas Emissions

Ensuring Environmental Outcomes from a Carbon Tax

(This post originally appeared on EDF Market Forces)

How can we ensure that a carbon tax delivers on its pollution reduction potential? An innovative, new idea could provide greater certainty over the environmental outcome.

As momentum intensifies around the world for action to fight climate change, the United States is emerging as a leader in the new low-carbon economy. But if we are going to reduce climate pollution at the pace and scale required — cutting emissions 26-28% below 2005 levels by 2025 and at least 83% by 2050, on a path to zero net emissions —we need to roll up our sleeves on a new generation of ambitious climate policies that harness the power of the economy and American innovation. An emerging idea could be a game-changer for the prospects of a carbon tax to help tackle climate pollution.

Economics 101 teaches us that market-based policies, including cap-and-trade programs as well as carbon taxes, are the most cost-effective and economically efficient means of achieving results. Both put a price on carbon emissions to reduce dangerous pollution. Cap-and-trade programs place a “cap” on the total quantity of allowable emissions, directly limiting pollution and ensuring a specific environmental result, while allowing prices to fluctuate as pollution permits are traded. The “guarantee” that the cap provides is a primary reason this tool has been favored by EDF and other stakeholder s focused on environmental performance. That U.S. targets are based on quantities of pollution reductions also speaks to the need for policy solutions tied to these pollution limits.

In comparison, a carbon tax sets the price per unit of pollution, allowing emissions to respond to the changes in behavior this price encourages. The problem, from an environmental standpoint, is that a carbon tax lacks an explicit connection to a desired pollution reduction target — and therefore provides no assurance that the required reductions will actually be achieved. We know that a carbon tax will impact emissions, but even the most robust modeling cannot provide certainty over the magnitude of that impact. Furthermore, fundamental factors like energy or economic market dynamics can change over time, affecting the performance of a tax. Because greenhouse gas pollution accumulates in the atmosphere over time, even being slightly off the desired path over several decades can produce significant consequences for cumulative emissions, and thus climate damages.

A new approach: Environmental Integrity Mechanisms (EIMs)

Two recently-released papers by the Nicholas Institute at Duke University and Resources for the Future (RFF) directly address this key concern with a carbon tax —and suggest an innovative path forward. They illustrate how a suite of provisions – we’ll call them “Environmental Integrity Mechanisms” or “EIMs,” though each paper uses different terminology – could provide greater levels of certainty regarding the emissions outcome, by allowing for adjustment of the carbon tax regime over time to course-correct and keep us on track for meeting our targets.

EIMs – if carefully designed – can play an important role in connecting a carbon tax to its performance in reducing pollution. They are a type of built-in insurance mechanism: they may never be triggered if the initial price path achieves its projected impact, but provide a back-up plan in case it does not.

These mechanisms are analogous to well-studied “cost containment” provisions in cap-and-trade that are designed to provide greater certainty over prices. Cost containment provisions are included in several successful cap-and-trade programs around the world. For example, California’s cap-and-trade program includes a price collar that sets a floor as well as a ceiling that triggers the release of a reserve of allowances.

EIMs are a parallel effort to introduce greater emissions certainty into a carbon tax system. With the recent publication of these two papers, EIMS are beginning to receive well-deserved greater attention. These provisions help bridge the gap between caps and taxes, merging the strengths of each to create powerful hybrid programs.

How EIMs might work

Let’s take a closer look at how these “EIMs” could work.

• First, the initial tax level and/or growth rate could be adjusted depending on performance against an emissions trajectory or carbon budget benchmark. This could occur either automatically via a simple formula built into the legislation, by Congressional intervention at a later date based on expert recommendations, or by delegation of authority to a federal or independent agency or group of agencies.

There are clear advantages to including an automatic adjustment in the legislation. This avoids having to go back to a sluggish Congress to act; and there is no guarantee that Congress would make appropriate adjustments. Moreover, Congress is likely to be loath to relinquish its tax-setting authority to an executive agency — and such delegation could even face legal challenges. Delegating tax-setting authority to an executive agency could also introduce additional political uncertainty in rate setting.

In designing such an automatic adjustment, policy makers will need to consider the type, frequency and size of these adjustments, as well as how they are triggered. The RFF paper in particular discusses some of the resulting trade-offs. For example, an automatic adjustment will reduce the price certainty that many view as the core benefit of a tax. On the other hand, by explicitly and transparently specifying the adjustments that would occur under certain conditions, a high degree of price predictability can still be maintained – with the added benefit of increased emissions certainty.

• Second, the Nicholas Institute brief discusses regulatory tools that could be employed if emission goals were not met –including existing opportunities under the Clean Air Act, or even new authority. The authors point out that relative to automatic adjustment mechanisms, regulatory options are more difficult to “fine-tune.” Nevertheless, they could provide a powerful safeguard if alternatives fail.

• Finally, as the Nicholas Institute brief discusses, a portion of tax revenue could be used to fund additional reductions if performance goals were not being met. This approach could tap into cost-effective reductions in sectors where the carbon tax might be more challenging to implement (e.g. forestry or agriculture). The revenue could also be used to secure greater reductions from sectors covered by the tax — for example, by funding investments in energy efficiency. In a neat twist, the additional revenue needed to fund these emissions reductions would be available when emissions were higher than expected — that is, precisely when more mitigation was needed.

EDF’s take

Our goal is to reduce the amount of carbon pollution we put into the atmosphere in as cost-effective and efficient a manner as possible. This means putting a limit and a price on carbon pollution.

Even at this preliminary stage in the exploration of EIM design, one takeaway is clear: all carbon tax proposals should include an EIM with an automatic adjustment designed to meet the desired emissions path and associated carbon budget.

More work is needed to develop and evaluate the range and design of EIMs. And while a cap is still the most sure-fire means of guaranteeing an emissions outcome, this growing consideration by economists and policy experts opens a new path for the potential viability of carbon taxes as a pollution reduction tool in the United States.

The bottom line is this: The fundamental test of any climate policy is environmental integrity. For a carbon tax, that means an EIM.

Also posted in Economics, Policy| Comments are closed

Open Road Ahead for Clean Trucks

rp_iStock_000002312011Medium2-1024x768.jpgOur nation is making great progress in reducing the environmental impact of trucking.

This is tremendous news, of course, as trucking – the main method of transporting the goods and services we desire – is critical to the fabric of our society.

Consider these facts:

We’re making major progress because of a team effort from truck and equipment manufacturers, fleets, policymakers, and clean air and human health advocates. With protective, long-term emission standards in place, manufacturers are investing in developing cleaner solutions and bringing them to market. Truck fleets are embracing new trucks because of lower operating costs and improved performance.

(For a more detailed picture of the widespread support for cleaner trucks, see EDF’s list of quotes supporting recent national Clean Truck standards.)

We must continue this team effort to make further necessary improvements in the years ahead.

Despite our recent progress, diesel trucks continue to be a leading source of NOx emissions, which is why a number of leading air quality agencies across the nation, health and medical organizations, and more than  30 members of Congress are calling for more protective NOx emission standards.

Trucks are also a large and growing source of greenhouse gas emissions. Thankfully, the new fuel efficiency and greenhouse gas standards mentioned above – which were released this past August and just published in the Federal Register today – will cut more than a billion tons of emissions.

Trucking fleets are embracing cleaner trucks. UPS, for example, is expanding its fleet of hybrid delivery trucks. PepsiCo, Walmart, Kane and others have applauded strong fuel standards for trucks.

Manufacturers are developing solutions to further improve the environmental footprint of trucking.

In the past few weeks alone:

  • Cummins unveiled a 2017 engine that cuts NOx emissions 90 percent  from the current emission standard.
  • Volvo Trucks North American showcased its entry to the DOE SuperTruck program, which is  a concept truck capable of surpassing 2010 efficiency levels by 70 percent and exceeding 12 miles per gallon.
  • Navistar also revealed its SuperTruck, the CatalIST, which hit a remarkable 13 mpg.

The progress we’ve made to date does more than just improve conditions within the U.S. Our strong standards push U.S. manufacturers to develop solutions that will resonate with international markets. For example, the European Union, Brazil, India, Mexico, and South Korea all are exploring new fuel efficiency and greenhouse standards for big trucks. U.S. manufacturers will be well positioned to compete in markets that put a premium on fuel efficiency.

In the coming years, we will need to continue to advance protective emission standards to protect the health of our communities and safeguard our climate. When the time comes, we will be building upon an impressive record of progress and cooperation.

Also posted in Cars and Pollution, Economics, News, Policy| Comments are closed

Cutting carbon pollution from aviation: A major breakthrough years in the making

dsleeter_2000

(This post originally appeared on EDF Voices)

Five years ago, I had one of the hardest tasks in government for someone who cares about climate action: running an interagency process in the White House on addressing carbon dioxide emissions from international aviation.

To put it mildly, climate action in the aviation sector was at an impasse.

The European Union was seeking to extend its greenhouse gas emission trading system to include international flights to and from Europe. The EU was well within its legal rights, and a range of studies showed that despite significant emission reductions the costs to passengers would be slight.

But the political opposition was widespread and fierce.

India had gone ballistic at the idea. Russia threatened to deny Europe access to its airspace. China said it would cancel orders for European aircraft.

In the United States, meanwhile, not a single senator was willing to block legislation that railed against Europe’s proposal to cover American air carriers.

And yet, last week, the 191 member states of the International Civil Aviation Organization agreed to the first-ever cap on carbon pollution from a global sector, adopting by broad acclaim a market-based measure on carbon dioxide emissions from international flights.

The agreement, while not perfect, is significant – not only for the emissions reductions it promises to achieve, but also because of the circuitous journey that got us here.

Industry: We need consistency

The impetus to find a way out of the impasse came from two quarters.

The first was a business imperative. What the aviation industry feared more than anything was a patchwork of regulations – one approach in Europe, another in the U.S. and still another in China. That made the industry, a strong opponent of the EU’s plan, willing to come to the table to get a global deal.

The second was the Obama administration’s commitment to climate action. If we couldn’t overcome the widespread opposition to Europe moving ahead, could we leverage the threat of EU action to land an international agreement?

ICAO, the aviation agency of the United Nations, had already agreed in 2010 to explore policy options to achieve a global solution. So in the fall of 2011, I raised the idea of pivoting to ICAO in a conversation with Mike Froman, then the White House Deputy National Security Advisor for International Economic Affairs.

A breakthrough came the following spring, when Tony Tyler, head of the International Air Transport Association, met with Mike and made it clear that the industry would support a robust market-based measure in ICAO.

EU: Get a deal or else

That summer, U.S. Special Envoy for Climate Change Todd Stern held the first of a series of informal meetings among countries to discuss an ICAO solution.

Meanwhile, the administration worked to ensure that when the anti-E.U. legislation was passed by Congress that autumn, it directed the administration to negotiate a global approach.

Work on a global market-based approach accelerated once ICAO agreed in 2013 to develop a proposal for formal consideration.

The EU kept the pressure on by making clear that it would reinstate its coverage of international flights if ICAO failed to act.

The industry remained supportive, just as Tony Tyler had pledged back in 2012. Environmental Defense Fund and our partners in the International Coalition for Sustainable Aviation, which EDF helped to found 20 years ago, published economic and legal analyses and provided technical support to governments, including through expert participation in ICAO working groups.

My former colleagues in the Obama administration spearheaded the effort to reach an agreement and put on a full-court diplomatic press in the last few weeks to secure participation from as many countries as possible.

Nations: We’ll move if we can compromise

The global market-based measure announced in Montreal last week will reduce carbon pollution by an estimated 2.5 billion tons over the first fifteen years of the program. It signals continued momentum on climate action, and positions the aviation sector as an engine of demand for high-quality emissions reductions around the world.

To be sure, the agreement is not perfect. An ideal agreement would apply to all anticipated emissions growth, whereas the deal currently covers 76 percent – although that will rise if more nations join.

The “carbon-neutral growth” target must be strengthened over time if the aviation sector is to do its fair share to address climate change – which is why the agreement includes provisions for regular review in light of the Paris Agreement’s long-term temperature goals.

To accommodate the concerns of fast-growing emerging markets, the agreement initially ties each air carrier’s responsibility to the sector’s overall emissions growth, not just its own emissions – arguably a more equitable approach, but one that dampens incentives for within-sector emission reductions.

And the agreement sets a two-year time frame for finalizing the crucial draft rules needed to determine what types of emissions units will be eligible for use in the program and ensure that they are not “double-counted” against other compliance obligations.

Such compromises, however, were crucial to garnering the support of a huge majority of ICAO’s member nations and getting the agreement across the finish line.

A good day for the climate

Some, including a few of my colleagues in the environmental movement, focus on the deal’s shortcomings to castigate it or at least damn it with very faint praise.

But letting the perfect be the enemy of the good is a luxury the world cannot afford – least of all the people of countries on the front lines of climate change, such as Jamaica, Burkina Faso and the Marshall Islands, whose representatives helped create momentum for the deal in the final days of the negotiations by eloquently urging ICAO to act.

Back home in New York the night after the deal was announced, my daughters, 11 and 14, asked how my day had been. I had to pause and let it sink in.

“Well, we got an international agreement that we’ve been working toward for many years that will limit carbon pollution from airplanes – and help make the future of the planet just a little bit safer” I told them. “So, yes, it was a very good day.”

Also posted in International, News, Partners for Change, Policy| Comments are closed

Hurricane Matthew And Climate Change: What We Know So Far

Image source: NASA

Hurricane Matthew. Image source: NASA

As I write this, Hurricane Matthew is battering the Atlantic coast of Florida, having wreaked havoc on Haiti and the Bahamas. In Haiti hundreds lost their lives due to the Hurricane’s destructive winds and storm surge.

With half a million Floridians already without power even before Matthew makes landfall, there is sure to be significant damage in Florida and other portions of the southeast U.S. from this Category 3 storm, the first major hurricane to strike the U.S. since Wilma in 2005. Our first and highest priority is to help the victims and others in the path of the storm.

However, as with any destructive weather event, people are asking about the role of climate change.

We know that increases in sea level caused by climate change result in higher and more destructive storm surges, like the one that swamped lower Manhattan during Superstorm Sandy in 2012. Coastal towns suffer greater damage because the ocean starts out higher, and the storm shoves more water inland. Coastal states like South Carolina and Florida – and the rest of us through taxes and insurance rates – will pay billions as a result.

But what about the connection between climate change and the strength of hurricanes themselves?

Hurricanes are fueled by the warm waters of the tropical oceans, which have been warming as the result of increased emissions of greenhouse gases.

However, hurricanes are also impacted by wind shear – the change of wind speed and direction with height. For a hurricane to grow and strengthen it needs a low wind shear environment, and some research indicates that climate change may actually increase wind shear over the tropical Atlantic. And that’s the rub. When it comes to climate change and hurricanes, the warming oceans and increasing wind shear are in competition. Science is still working out which mechanism will dominate as the global climate continues to warm – so stay tuned.

But there is more to the story than just the relationship between the intensity or frequency of hurricane and global warming. Because the climate system is so complex, no storm happens in a vacuum. Scientists have been working on the issue of “attribution”— How much can we know about the link between specific storms and climate change? The organization Climate Central has also been working intensively in this area.

While we await attribution studies, we shouldn’t lose site of the bigger picture: we already know that climate change is doing tremendous damage to our environment and our economy. Citibank estimates the cost of inaction on climate change is in the trillions. So let’s first help those hurt by this storm, then focus on cutting the pollution that is causing so much damage to our world.

Also posted in Basic Science of Global Warming, Extreme Weather, Oceans, Science| Comments are closed

Today’s Clean Power Plan Oral Argument: A View from Inside the Courthouse

rp_Gavel-and-earth-from-Flickr-300x199.jpgEarlier today the U.S. Court of Appeals for the D.C. Circuit heard oral argument on the Clean Power Plan — America’s first-ever limits on climate pollution from power plants, which are our single largest source of this harmful pollution.

For the first time, these vital safeguards are being reviewed on the merits. Ten active judges on the D.C. Circuit presided over today’s argument.

I was at the courthouse today. Here’s my read out:

Judges’ probing questions reflected their active engagement and preparation as anticipated in such a high profile case — as well as a skeptical view of opposing arguments

The judges today were prepared and engaged. They asked sharply probing questions of all sides.

But the big news is that a majority of judges appeared receptive to arguments in support of the Clean Power Plan.

The court understood that EPA was carrying out long-established legal authority — affirmed in three separate Supreme Court opinions — to tackle the urgent threat of climate change by addressing our nation’s largest source of climate pollution.

Judge Millett characterized petitioners’ arguments against EPA’s authority as a “bait and switch”— one that would gut the Supreme Court’s conclusion in an earlier groundbreaking case, American Electric Power, which concluded that Section 111(d) “speaks directly” to EPA’s authority regulate greenhouse gases from existing power plants. (564 U.S. 410, 424, 2011)

Judges also recognized that the Clean Power Plan’s approach reflects familiar, time tested strategies to reduce pollution — strategies that the Supreme Court and the D.C. Circuit have upheld in numerous past Clean Air Act programs adopted under administrations of both parties.

The judges’ questions demonstrated their keen understanding of how the power sector works. Several judges underscored the unique nature of the interconnected electricity grid system —which distinctly enables sources to reduce emissions cost-effectively through shifting generation to lower-emitting sources — in discussing EPA’s inclusion of generation shifting as part of the best system of emissions reduction reflected in the Clean Power Plan. Judge Tatel, for example, expressly recognized the point that generation-shifting strategies incorporated in the Clean Power Plan are “business as usual” for power companies.

Meanwhile, the judges expressed skepticism towards petitioners’ claims. In one exchange, Judge Pillard questioned why petitioners’ arguments would not entirely “immunize” highly polluting sources from pollution control.

Legal experts representing a wide variety of perspectives forcefully and effectively argued in support of the Clean Power Plan

A diverse and impressive suite of presenters argued in support of the Clean Power Plan.

Seasoned U.S. Department of Justice (DOJ) attorneys articulated the clear and compelling legal and technical basis for the Clean Power Plan, which was informed by an unprecedented level of public and expert input including more than four million public comments. The DOJ attorneys underscored how the Clean Power Plan’s approach carefully respects statutory limits on EPA’s authority and embodies well-established, proven strategies to reduce pollution.

The attorney representing power companies supporting the Clean Power Plan — a robust coalition that represents almost ten percent of America’s electricity generation capacity —emphasized that the power sector is already reducing its carbon pollution by shifting to low-cost cleaner generation, making Clean Power Plan targets eminently achievable. For these companies, the carbon reduction strategies EPA recognized in the Clean Power Plan are “business as usual” — the phrase that was then raised by Judge Tatel later during the day. The power company attorney’s remarks also emphasized that petitioners’ approach would ask EPA to ignore the widespread strategies that power companies are already using to reduce carbon pollution cost-effectively through shifting generation to lower and zero emitting resources.

Counsel for the numerous states and cities across the country that are supporting the Clean Power Plan spoke on behalf of their citizens on the urgent need for protections against climate pollution. The state attorney’s remarks highlighted how the rule’s flexible approach echoes other traditional, successful Clean Air Act programs, and properly respects states’ role in the interconnected electricity grid system.

Sean Donahue, counsel for public health and environmental organizations including Environmental Defense Fund, forcefully articulated the clear basis for EPA’s authority and the urgent need to protect our communities, our families, and our economy against climate change. In particular, Donahue underscored that Clean Power Plan opponents seek to fundamentally obstruct any progress in addressing the most pressing environmental challenge of our time – climate change. Indeed, opponents of the Clean Power Plan have, in previous statements, conceded that EPA has authority to issue the Clean Power Plan — entirely undercutting their current claims to the contrary.

It’s challenging to predict an outcome from oral argument

It’s difficult to guess a case’s outcome from any oral argument. That’s even more true in today’s case, which was heard by an en banc court – all ten active judges on the court, aside from Judge Merrick Garland who recused himself. With ten judges to observe and interpret, each with an individual perspective and background, prognostications are particularly challenging.

Nonetheless, we have many reasons for optimism after today’s rigorous review of petitioners’ claims. Most of all, the rock solid legal and technical foundation for the Clean Power Plan gives us confidence that climate protection can win the day.

Now, the judges deliberate

The judges now turn to deliberation and discussion. In a typical case, the D.C. Circuit can take several months to issue an opinion. Here, there is a true sense of urgency in resolving EPA’s clear authority to combat climate change — earlier in the case, judges issued an order for expedited consideration — but there will also be ten judges’ opinions to resolve. Our nation’s biggest step to protect the health and well-being of our communities from climate pollution hangs in the balance.

Also posted in Clean Air Act, Clean Power Plan, EPA litgation, News, Partners for Change, Policy| Read 1 Response

New Analysis: Clean Power Plan Compliance Within Reach for Litigating Companies

rp_scales_of_justice-300x280-300x280.png (EDF Attorneys Tomás Carbonell and Martha Roberts co-authored this post)

Tomorrow – Tuesday, September 27th – the U.S. Court of Appeals for the D.C. Circuit will hear argument about the historic Clean Power Plan.

The Clean Power Plan places the nation’s first limits on climate-disrupting pollution from the electricity sector, which is responsible for almost 40 percent of U.S. emissions of carbon dioxide.

Many utilities, power producers, and state regulators recognize the importance of addressing climate change – and support the Clean Power Plan. However, some in the electric industry have instead chosen to take a reactionary, obstructionist position against climate progress. They are participating in litigation against the Clean Power Plan. A wide array of prominent legal experts have concluded that these companies’ legal arguments are unsupported. Moreover, in many cases, opponents’ claims are even contrary to their own actions. (See Opening Brief of Petitioners on Procedural and Record-Based Issues, page 12, West Virginia v. EPA, No. 15-1363, D.C. Cir. Apr. 22, 2016)

EDF has just released a new analysis of this issue. It examines a diverse selection of power companies that are litigating against the Clean Power Plan, including Southern Company, American Electric Power, Big Rivers Electric Corporation, and Tri-State Generation & Transmission.

We find that:

  • Overall, power sector emissions of climate pollution are already 21 percent below 2005 levels. As a result, the sector is already two-thirds of the way towards meeting the 2030 emissions reduction requirements of the Clean Power Plan.
  • Even though these particular companies are opposing the Clean Power Plan in court, they are already using a variety of approaches to drive significant cost-effective reductions in climate pollution from their existing fossil-fuel powered units, thanks in large part to favorable economics for lower and zero-carbon generation.
  • These are the same practical, cost-effective methods that EPA identified as the “best system” of emission reduction for climate pollution from power plants, and that formed the basis for the emission limits in the Clean Power Plan.
  • With these investment decisions, power companies are well positioned to comply with the Clean Power Plan, even though they are making claims to the contrary in court.
  • These companies’ own actions affirm the reasonableness of the Clean Power Plan targets as well as EPA’s approach in setting the standard, even though the companies are repeatedly claiming otherwise in court.

This is not the first time some of these companies have advanced deeply flawed “sky is falling” claims about clean air safeguards. Back in the 1970’s, AEP published a series of Washington Post newspaper ads claiming:

There is no way on God’s green earth that the present sulfur-dioxide emissions standards can be met. (Washington Post, April 30, 1974, AEP Display Ad 13)

Not surprisingly, coal plants across the nation are routinely meeting sulfur dioxide limits far more stringent and at very low cost.

This was also true in 1990, when AEP told the Boston Globe that bipartisan solutions to address acid rain could lead to:

the potential destruction of the Midwest economy.

Of course, they then proceeded, along with the rest of the industry, to go out and comply at a small fraction of the costs predicted by EPA. This same story is playing out again today.

The Clean Air Act has achieved deep reductions in pollution and delivered benefits exceeding the costs by 30 to 1 – all while our economy has prospered, and all at a small fraction of the costs predicted by obstructionists in the power industry.

The Clean Power Plan is no different. As our analysis shows, day by day it becomes clearer that the reductions it requires are wholly consistent with driving trends in the industry, and that the benefits will far exceed any cost of compliance.

The full analysis is available here.

Also posted in Clean Air Act, Clean Power Plan, Economics, EPA litgation, Policy, Setting the Facts Straight| Comments are closed
  • About this blog

    Expert to expert commentary on the science, law and economics of climate change and clean air.

  • Get blog posts by email

    Subscribe via RSS

  • Categories

  • Meet The Bloggers