The President's plan contains the good, the bad and the ugly.
The GoodThe administration is finally using the authority ratified by a conservative Supreme Court to regulate greenhouse gas emissions under the Clean Air Act. The administration will rewrite rules for new plants (the old standard, which just passed its deadline in April, essentially blocked new coal power plants, so there's a strong chance the rewrite will weaken the original standard) and develop rules over all existing power plants. This is the most important tool the administration has, and if the rules are written the way they should be, it will go a long way toward protecting consumers and our climate. This initiative builds on the successful and strong automobile tailpipe standards that have already been successfully rolled out. The downside is that the late 2015 final rule date is far off in the future, and will be wrought with lengthy legal challenges, lending an awful lot of uncertainty to the outcome.
The plan also, helpfully, builds on existing programs and plucks some low-hanging fruit to reduce carbon emissions: Increasing renewable targets and efficiency on federal land, in the federal government's operations, in the Pentagon and in federally-assisted housing.
The administration set the table recently by rightfully increasing the estimated cost of greenhouse gas (GHG) emissions to society, from $23.80/ton to $38.
Targeting oil industry subsidies, as the administration proposes here, is also commonsense, and much needed policy.
The Bad
There is no mention in the plan of using a uniform, strong climate change impact assessment under the National Environmental Policy Act, which would require the costs and impacts of GHG in every federal environmental impact statement. The failure to utilize NEPA for GHG assessment is a major oversight.
Reserving the troubled loan guarantee program for "clean coal" is a taxpayer boondoggle waiting to happen. A case in point is the Obama-backed Kemper IGCC coal plant owned by Southern Co, which has seen costs balloon from $2.4 billion to $4.2 billion, and rising.
The Ugly
The President's embrace of an 'all of the above' strategy, including oil and gas expansion, is a disaster. His focus on fossil fuel exports - including the explicit promotion of LNG (liquefied natural gas) and his failure to curtail coal exports - threatens to undo the positive elements of the plan. By promoting LNG, the administration is moving full-speed-ahead on fracking, with no mention of how to control fugitive emissions, water contamination and other environmental problems posed by the controversial process. And while the proposed EPA rules over existing and new coal power plants will result in significant GHG reductions here at home, all of that will be negated (and more) if we ramp up our coal exports to China. Using NEPA and other statutes to ensure that the emissions of coal exports - and the fugitive emissions of fracked gas - are included in the environmental impact study (EIS) for export projects is essential.
The same goes for Keystone XL. Awaiting approval by the State Department, the Keystone XL pipeline's EIS is fatally flawed. The administration has a chance to re-write the EIS to take into account the true GHG impact of the tar sands, which would require this gas-price boosting project to be rejected.
At the end of the day, it would be helpful if the administration would lend its support to an existing climate bill - the Climate Protection Act of 2013. This legislation places a price on carbon, sending revenues back to families and into investments for a sustainable energy economy (not to mention regulating fracking and repealing oil industry subsidies).