Climate 411

Investors, bipartisan former officials, others defend SEC climate risk disclosure rule

Photo by Jose Saenz

 

Extreme weather caused by climate change is a threat to human health and safety, but it is also increasingly the cause of serious economic disruptions. And in the transition to a lower carbon economy, companies are navigating both opportunities and challenges.

The Securities and Exchange Commission (SEC) recently adopted a rule to better equip investors to manage these risks. The rule will standardize public companies’ disclosures of climate-related financial risk information. (You can read more details about the rule here).

The SEC’s rule has received widespread support from a diverse array of stakeholders. However, certain state attorneys general, oil and gas interests, the U.S. Chamber of Commerce, and others have challenged the rule in court.

EDF joined Americans for Financial Reform, Sierra Club, and Sierra Club Foundation (represented by Earthjustice) and Natural Resources Defense Council (NRDC) to support the SEC’s climate risk disclosure rule by filing an amicus curiae – or “friend of the court” – brief in the U.S. Court of Appeals for the Eighth Circuit.

Our brief shows that:

  • The rule is rooted in decades of the SEC requiring financially relevant environmental disclosures and updating disclosure requirements to reflect evolving market dynamics and investor concerns.
  • The rule is reasonable and firmly supported by rigorous evidence of the importance of climate risk information to investors.
  • The rule furthers the SEC’s core missions of investor protection, market efficiency, competition, and capital formation.

Our brief is in good company. More than a dozen others from investors, experts, and a broad range of stakeholders have also been filed in support of the rule, underscoring the SEC’s manifest authority to require commonsense climate-related financial risk disclosure and the importance and benefits of doing so.

Here are a few highlights from filings supporting the SEC’s action:

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California’s carbon market continues to fund much-needed climate action with third auction

Wind energy in California.

Photo credit: Kendel Media via Pexels

Results of the latest Western Climate Initiative (WCI) auction were released today. While the auction sold out for the 16th consecutive time, a decline in the settlement price indicates potential market uncertainty about the cap-and-trade program’s design in the future.

This auction is expected to generate roughly $950 million for the Greenhouse Gas Reduction Fund (GGRF), which is dedicated to supporting initiatives aimed at strengthening climate resilience and reducing greenhouse gas emissions. The GGRF is critical to California’s climate strategy. In the past 10 years, climate investments like GGRF have cut emissions in California by 109.2 million metric tons — the equivalent of the annual emissions of more than 25 million cars — by investing in projects like building affordable housing near job centers, adding zero-emissions transport options, and more.

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Posted in Cities and states, Greenhouse Gas Emissions / Authors: / Comments are closed

How Long Beach is Leading the Charge Toward a Clean Energy Future

Written Q&A with Mayor Rex Richardson on Climate and Economic Progress in Long Beach, California

City of Long Beach Landscape

Long Beach, California, is showing communities around the country why embracing the clean energy economy is a winning strategy.

Home to one of the busiest port complexes in North America, with a long reliance on revenue from oil and gas, Long Beach is now charting a new path that marries climate progress and economic progress. Under Mayor Rex Richardson’s leadership, the city is making bold moves to electrify its port and cut harmful pollution, land coveted EV manufacturing jobs, and leverage billions in federal investment from historic climate laws – all while lifting up frontline and disadvantaged communities hit hardest by pollution and climate impacts.

Long Beach Mayor Rex Richardson

Long Beach Mayor Rex Richardson

EDF has worked with Long Beach to host a roundtable of climate stakeholders to support their Climate Action Plan and continues to collaborate with the city through its partnership with the African American Mayor’s Association.  To get deeper insights on the city’s transformation, I asked Mayor Rex Richardson about Long Beach’s climate and economic plans, some of the exciting projects that are underway now and what other mayors can learn from his approach. 

Let’s start with some big recent news: Ford has officially chosen Long Beach as its new home to develop its next generation of small, affordable EVs. What kinds of jobs and business opportunities will this new manufacturing facility bring to Long Beach? What has the response from the community been? 

RR: In the City of Long Beach, we are laying the foundation for the Long Beach of the future — a global, sustainability-centered hub that attracts emerging companies, industries, and technologies in clean and renewable energy. Our recent announcement that Ford Motor Company has chosen Long Beach as the home for its new Advanced Electric Vehicle Development Center is evidence of our unwavering commitment to move full-speed ahead towards a zero-emission future. 

Ford plans to open their research-and-development campus in Douglas Park, adjacent to Long Beach Airport, in early 2025. This campus will include two buildings and will host around 450 employees focused on designing Ford’s next generation of low-cost, electric vehicles.  

Ford at Grow Long Beach - 26 June 2024 (1)

Long Beach Mayor Rex Richardson with Doug Field, Ford’s Chief Officer of EVs and Digital Systems, and Alan Clarke, Ford’s executive director of Advanced EV Development, at the city’s Grow Long Beach 2024 event announcing the automaker’s new EV development center. Photo courtesy of Long Beach, California.

As a part of our Grow Long Beach Initiative, and our city’s ongoing efforts to transition away from oil production revenues as a core funding source for city services, we are placing a focus on growing our economy by drawing thousands of new advanced manufacturing and engineering jobs that will support local Long Beach residents with competitive wages, and will allow graduates from our local schools and universities to buy a home and set roots in our community. 

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Posted in Cities and states, Energy, Innovation, Jobs / Authors: / Comments are closed

An obvious solution for building electric transmission faster: Use railroads and highways

The U.S. needs to build a lot more high-voltage electric transmission lines. Our current system is disconnected in all of the wrong places, leaving bountiful renewable resources stranded, individual regions isolated, and disadvantaged communities with unreliable power and exorbitant costs. Even where we do have connections, many of the lines are outdated and can’t accommodate all of the energy that is being produced.

To ensure that our grid is resilient to severe storms and heat, capable of meeting our climate goals, and can deliver energy at reasonable cost, we will need to build or upgrade around 75,000 miles of transmission lines – the equivalent of building 30 transmission lines connecting Los Angeles to New York City.

Historically, building transmission lines over long distances has been an arduous and time-consuming process. Many lines have taken decades to reach completion, while others don’t even make it to the construction phase. Since transmission lines typically pass through many separate state and local governments, transmission developers are required to apply for a permit with each of the individual states, and potentially the individual municipality that it crosses. Each of these state and local processes can take years, leading to potentially cascading timelines, particularly for longer distance projects. And of course, any of these permitting bodies could simply deny the project from being sited in their state or local jurisdiction, setting off further actions and delays that a transmission developer will need to respond to, if they don’t simply throw in the towel.

But there is a small exception to this sluggish process: a transmission line that is being built within a specific Department of Energy (DOE) designated “corridor” and that did not receive a construction permit from a state or local agency within one year of filing their application may seek a federal permit from the Federal Energy Regulatory Commission (FERC) to move forward with their project.

In May, DOE proposed 10 National Interest Electric Transmission Corridors (NIETCs, pronounced Nit-Sees). These NIETCs represent areas where DOE has found that new interstate transmission could provide outsized benefits to consumers affected by high electricity costs and reliability concerns. Transmission lines built in these corridors will become eligible for additional financial support under the Inflation Reduction Act and Bipartisan Infrastructure Law. These proposed designations represent a necessary step forward in the process of getting more transmission lines in the ground. However, whether these corridors can deliver on their promise of removing barriers to building new transmission projects depends on where the boundaries are drawn, and whether they include the range of reasonable alternative routes that a developer may need to consider.

An analysis commissioned by EDF found that the boundaries of the corridors were drawn far too narrow, unnecessarily excluding existing infrastructure corridors and their rights-of-way — such as highway and railway routes — that can create more pathways for delivering reliable and affordable power.

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Setting an 80 by 30 target is critical for the third RGGI program review, new EDF modeling shows

As the Regional Greenhouse Gas Initiative (RGGI) undergoes its third program review, it is critical that the program scale its ambition to both meet the demands of the climate crisis and to fully capitalize on the cost-saving potential of the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA).

Ensuring ambitious reductions in carbon pollution before 2030 is key to both these objectives. A RGGI cap that aligns with at least 80% emission reductions from a 2005 baseline by 2030 (80 by 30) would reduce cumulative emissions by 182 million tons (between 2025 and 2035) relative to a straight-line trajectory to zero emissions by 2040. Reaching at least 80 by 30 in the power sector is a critical step to achieving the United States’ 2030 economy-wide commitments in line with the U.S. Nationally Determined Contribution (NDC) under the Paris Agreement, and the RGGI states should lead the way. It will also significantly increase the value of the IRA funding currently flowing into the RGGI region.

Power sector modeling commissioned by EDF demonstrates that RGGI states can achieve at least this critical level of abatement while keeping costs low. Aligning the cap trajectory with at least 80 by 30 is a “no regrets” decision that would put the RGGI region on a path consistent with nationwide climate targets. In fact, EDF’s modeling shows that RGGI could go beyond 80 by 30, implementing an 85 by 30 interim cap, achieving even greater emissions reductions at modest cost.

On top of this, near-term reductions in the power sector are crucial to enabling the effective decarbonization of other sectors. A cap aligned with at least 80 by 30 is a strong foundation on which to drive the decarbonization of transport, buildings and industry.

Near-term action is critical

As EDF has argued before, setting an 80 by 30 interim target leads to better results than simply targeting reductions either by 2035 or by 2040 — the two budget trajectories that have been modeled by the RGGI states. A program with no 2030 target will leave critical carbon emission reductions on the table at the precise moment that climate impacts are accelerating and the U.S. is sprinting to deliver on its NDC. Decreasing economywide emissions 50-52% by 2030, as the U.S. NDC requires, will necessitate rapid emissions cuts in the power sector, as electricity is a large source of low cost abatement and a necessary precondition to decarbonizing sectors like transportation and industry where electrification is key. In fact, analysis after analysis indicates that at least an 80% cut in power sector emissions is a critical linchpin for achieving our economy-wide decarbonization commitments on the 2030 timeline.

Limiting the supply of allowances in the early years incentivizes rapid reductions in carbon dioxide emissions, leading to lower cumulative emissions over the study period. CO2 can persist in the atmosphere for centuries, meaning that every year a facility continues emitting, it is contributing more to the stock of CO2 in the atmosphere. Cumulative emissions of long-lived climate pollutants like carbon dioxide, the stock of pollution built up in the atmosphere, largely govern the maximum warming — and associated impacts — we will experience. As a result, the program’s performance on a cumulative basis is a critical measure of its overall climate benefits.

RGGI states need to do two things to improve program performance

First, with 2030 fast approaching, it is critical that the RGGI states quickly and decisively finalize the program review and put a new, ambitious cap into place. The sooner such a cap is adopted, the greater its effect will be on cumulative emissions, as facilities that could be taking additional abatement measures today instead continue to produce greenhouse gases under the significantly less ambitious current cap. Every year up to 2030 that the current cap remains in place leads to an additional 19-34Mt of emissions, relative to moving to a 0x40 cap or 24-62Mt relative to an 80 by 30 cap.*

Second, the cap needs to be as ambitious as possible on the 2030 time-horizon, which will improve cumulative performance and ensure these leadership states are actually achieving power sector reductions aligned with what is necessary to hit U.S. goals under the Paris Agreement.

Ambitious 2030 targets drive considerable additional cumulative emissions reductions, relative to adopting a cap with a straight-line trajectory to zero.

Compared to a zero by 40 cap alone, a zero by 40 cap with an 80 by 30 interim target would yield 19% lower cumulative emissions between 2025 and 2040. Implementing an even more ambitious 85 by 30 cap would lower cumulative emissions 30% relative to a straight path to zero by 2040.

Moreover, the chart above shows that if the RGGI states adopted a cap that went through 80 by 30 on the way to zero by 40, the increased near-term reductions would mostly compensate for the longer run up to deep decarbonization, relative to the zero by 35 scenario. Securing those reductions now, while they are significantly cheaper, would help the program achieve serious environmental ambition at low cost.

These potential savings indicate the stakes of the current program review progress. Should RGGI Inc. pursue an ambitious path forward, the region could see cumulative emissions fall considerably. The certainty of a firm cap will incentivize covered entities to act quickly, while further delay in the program review process — and a less ambitious near-term (2030) trajectory — will result in slower action.

EDF’s modeling approach

EDF’s new analysis evaluates a range of potential caps under various cost, electricity demand and policy design assumptions using FACETS, a multi-region energy system model used for power sector analysis. The model was used to demonstrate how different cap trajectories affect allowance prices, emissions, and electricity costs across a range of policy scenarios.

EDF’s modeling is intended to complement the modeling conducted on behalf of RGGI Inc. by ICF. Like ICF, EDF modeled deep decarbonization of the RGGI participants’ power sectors by 2035 and 2040 but modeled these caps both with and without an interim 80 by 30 target. EDF also tested the impact of different banking rules, leakage mitigation and the Emissions Containment Reserve (ECR) and Cost Containment Reserve (CCR).

Beyond cap and policy options scenarios, EDF tested the impact of cost assumptions for renewables and natural gas, as well as high electricity demand through a range of sensitivities.

FACETS does not solve for zero emissions, instead using a 95% emissions reduction (over 2005 levels) as an approximation of net zero.

This analysis complements ICF’s modeling using IPM, by using broadly similar assumptions and demonstrates that a more ambitious cap on the 2030 time horizon can yield very significant emissions benefits at very low cost.

High ambition at low cost

These emission reduction benefits can be achieved with a low price tag. When the cap includes an 80 by 30 interim target on the way to deep decarbonization in 2040, allowance prices remain below the recent RGGI average through 2030, and even through 2040, average allowance prices remain at or below the ECR trigger level. The RGGI system could even go beyond 80 by 30 at modest cost. Under an 85 by 30 cap, allowances prices remain near the ECR trigger price for roughly a decade and fall below the ECR trigger after 2035. Throughout the entire study period, allowance prices remain well below the CCR trigger under an 85 by 30 cap. As illustrated earlier, this cap trajectory yields considerably lower emissions, indicating that cheap abatement opportunities are readily available in the region.

Further, the EDF analysis shows that a more ambitious cap has only a modest impact on electricity costs. The cost of delivered electricity follows a similar trajectory in scenarios with and without the 80 by 30 interim target, in spite of the emissions benefits the near-term target achieves.

Wholesale electricity costs are expected to rise over the next decade in the RGGI region, whether or not the cap is tightened. A 2040 deep decarbonization cap does not push these costs up much further and an 80 by 30 interim target does very little to drive costs up beyond that. Ultimately, gas prices and high electricity demand represent much larger upside risks to electricity prices regardless of the cap scenario. Under reference gas price and demand assumptions, an 80 by 30 cap is associated with at most a roughly 2% increase in electricity prices. To the extent that increase in wholesale prices is reflected in actual consumer bills, the impact is likely to be even smaller than 2%, as retail electricity prices include other costs and states are often deploying other strategies, including using RGGI revenue, to help lower customer bills.

The low cost of ramping up RGGI’s ambition is attributable in part to the investments made by the IRA. A November 2023 analysis from Resources for the Future modeled a nationwide 80 by 30 cap with and without the IRA, finding that inclusion of the IRA is associated allowance prices 43-66% lower than under the cap alone. While the RFF analysis considered a nationwide cap, the same fundamental dynamic is at play in the RGGI system. That is, the IRA buys down the cost of clean energy resources, easing the cost burden of electricity providers substituting away from fossil fuels.

It is the perfect moment for RGGI to take advantage of the IRA investments, leveraging the significant cost declines to lock in policy frameworks to ensure emissions abatement at significantly lower cost.

Conclusion

EDF modeling results clearly show that more ambitious caps for the RGGI system — caps that actually match the ambition necessary from the electric power sector — will not drive up costs. Enacting a cap that requires at least an 80% reduction below 2005 levels by 2030 would generate significantly greater climate change mitigation benefits without meaningfully impacting electricity prices. The RGGI states should prioritize including this interim pollution reduction goal in their third program review.

 

* The difference in annual emissions between cap trajectories varies from year to year, with caps beginning to diverge in 2026. The difference between the BAU cap and more ambitious caps general increases in the later years, as the BAU cap levels off after 2030 but other caps continue to decline.

Posted in Carbon Markets, Cities and states, Greenhouse Gas Emissions, News, Policy / Authors: , / Comments are closed

Five years into New York’s climate law, the state needs a bold cap-and-invest program to bring emissions goals into reach

This blog was co-authored by Lulu August, State Climate Policy Intern

This month marks five years since New York State’s Climate Leadership and Community Protection Act (CLCPA) was signed into law. At the time of its enactment in 2019, the groundbreaking climate law set New York apart as a national and global climate leader.

Indeed, action in line with the CLCPA’s emissions and environmental justice requirements would be transformative — promising a safer future, cleaner air and good-paying jobs in the growing clean energy economy for New Yorkers today and for future generations.

Five years in, however, New York does not yet have the rules in place to deliver on the climate law and all the promise it holds for New Yorkers.

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Posted in Carbon Markets, Cities and states, Economics, Energy, Greenhouse Gas Emissions, News, Policy / Authors: / Comments are closed