Georgetown Climate's Arroyo and Pacyniak discuss state recommendations on emissions standards

How can U.S. EPA craft its existing source rule for power plants to maximize flexibility for stakeholders? During today's OnPoint, Vicki Arroyo, executive director of the Georgetown Climate Center at Georgetown Law, and Gabe Pacyniak, an institute associate at the Georgetown Climate Center, discuss a letter sent to EPA this week by 15 states offering recommendations for the upcoming power plant rule. Arroyo and Pacyniak also comment on the agency's interaction with industry, states and environmental groups as it crafts its standards.


Monica Trauzzi: Hello, and welcome to OnPoint. I'm Monica Trauzzi. With me today are Vicki Arroyo, executive director of the Georgetown Climate Center at Georgetown Law, and Gabe Pacyniak, an institute associate at the Georgetown Climate Center and adjunct professor at Georgetown Law. Vicki, Gabe, thank you both for joining me.

Vicki Arroyo: Thank you for having us.

Gabe Pacyniak: Thank you.

Monica Trauzzi: Vicki, the Georgetown Climate Center along with a group of 15 states has sent a series of comments and recommendations over to EPA on its power plant emissions standards. And the states involved have achieved their own emissions reductions, and you're calling for a stringent but flexible framework as EPA moves forward. We hear this word "flexibility" a lot from the various stakeholders, and it seems like a lot of people have different definitions. So how do you define flexibility?

Vicki Arroyo: Sure, no, that's a great question. And I'll just start by saying that the states have been at this game for quite a while now, reducing emissions in a variety of ways that works for their own state. So you see over 30 states with renewable portfolio standards. You see 25, so half the country, with efficiency standards. You see the RGGI states in this region having reduced their emissions significantly, 40 percent actually from the carbon, of carbon from the power plant sector from their 2005 emissions. So what we mean by flexibility is to build on these programs, whatever they may be, from the states not just on the coast like California's A.B. 32 and the RGGI states, but even some of the Midwestern states that have signed on that have their own ambitious targets, and they're meeting them.

Monica Trauzzi: And so, Gabe, how are these 15 states that are involved in this proposal, this series of recommendations, how is that significant? They're all kind of from different places all around the country.

Gabe Pacyniak: Yes, it's a broad group of state environmental and energy and public utility commission representatives, leaders, agency leaders from 15 states including states on the West Coast -- California, Washington and Oregon -- states in the middle of the country including Colorado, Minnesota, Illinois, and then states in the Northeast, those states that participate in the Regional Greenhouse Gas Initiative. And I think what's very significant is that these states are showing that through a variety of different approaches they've really already achieved very significant pollution, carbon pollution reductions from the power sector, altogether 20 percent reductions from 2005 to 2011. And they're suggesting that the variety of models that they've, the variety of programs that they already have in place can be a model for how EPA could create a framework that would achieve meaningful reductions, but it would allow states to build and use programs that they already have in place.

Monica Trauzzi: So then, Vicki, what was the Climate Center's role here in bringing together all these stakeholders and coming up with, I mean, it sounds like there are maybe 15 different approaches here, so how did you come up with these recommendations?

Vicki Arroyo: Well, there are not necessarily 15 approaches because, as Gabe mentioned, the RGGI states, you know, nine states are on the same program, the same cap-and-trade program for quite a while. But the Climate Center was actually started about five years ago with and for the states. We started out as the Georgetown State and Federal Climate Resource Center, and that was of course, as you'll recall, Monica, in the days of the cap-and-trade bill debates on the Hill. But now the discussion has obviously shifted to how the states can fit in the Clean Air Act, and of course there's a long history of cooperative federalism with the states being the implementers of the targets that EPA sets, if you will. And so we have played this convening role, not just on this issue, but on many issues including adaptation to climate change as well as other issues like the Transportation and Climate Initiative that we facilitate. This is a role that our center plays. We have offices at the Hall of States where the states are based, as well as at Georgetown Law.

Monica Trauzzi: So, Gabe, talk a bit about this mass-based approach and whether this is the type of thing that EPA might propose in its initial proposal, or if it's something that it might accept from states down the line in terms of compliance.

Gabe Pacyniak: Sure. That's a great question, Monica, and maybe let me just back out a little bit to say that overall what the states suggest here, and it really was the states who have developed these recommendations, is that EPA allow for a variety of different approaches, and they're not choosing any particular approach here, but that EPA look to the state's experience and see what's already worked in reducing carbon pollution. And as we mentioned before, that's a variety of approaches including cap-and-trade programs like the RGGI states have in place or emission budget programs, but also renewable portfolio standards, energy efficiency standards, a variety of things that states are already doing to reduce pollution. So these states in their comments have suggested that a mass-based budget would be the easiest approach, and for them to use their existing programs to, as a method of compliance under Section 111(d). But they do suggest that EPA could either establish emission budgets for states, or it could use a rate-based standard and then provide a mechanism for translating from a rate-based standard to a mass-based emission budget, as long as it was equivalent, there was a way of making sure that all states were achieving equivalent reductions and requiring the same level of effort.

Monica Trauzzi: How effective do you think the agency's communication and interaction with the various stakeholders has been up until this point?

Gabe Pacyniak: Let me just pass that to Vicki, because we've had a series of convenings.

Vicki Arroyo: Sure. I mean, again, you know, our center plays this role where we often facilitate dialogues, and in addition to the two in-person convenings and several phone calls, as you can imagine, and a lot of email traffic in developing these recommendations, we've also recently put out a success stories document, a report on success stories with these and other states actually and power companies who've been able to reduce their emissions. And I will say that at both of those convenings, or sets of convenings if you will, we invited and had senior officials from not only EPA, but DOE, the White House come by to express their interest, listen to the lessons that are coming from the states and from the firms, and then that's in addition to their own outreach, which has been quite extensive on this role, and I would say pretty unprecedented really before they even get to the proposal stage.

Monica Trauzzi: So, Gabe, how does the agency address this fact that there are so many different starting points in the various states?

Gabe Pacyniak: Well, let me speak to what the states mentioned here in their comments, which is that they urge EPA to take an approach that would recognize the different starting points, but also seek comparable rigor for different kinds of states. And one of, you know, there are several different ways that EPA could do that under different frameworks, and the comments don't go into specific approaches except to suggest some potential approaches to consider.

Monica Trauzzi: Which states do you think provide the best examples of how emissions reductions can successfully happen on the more localized level?

Gabe Pacyniak: Well, I think what's interesting here is that we have a couple of different models. So you can see a state like Minnesota, which has achieved 17.5 percent reductions from 2005 to 2011 and they've done that through their renewables portfolio standards, through their energy efficiency standards, through other programs that are intended to promote upgrades to existing fossil fuel plants, and of course through changes in the resources in energy markets. And then you have a state like Colorado that's using some innovative legislation -- the Clean Air-Clean Jobs Act -- which encourages and actually requires utilities to plan on how they're going to reduce some of their conventional pollutants, but also has the benefit of promoting carbon pollution reductions. I think they're expecting 29 percent reductions by 2020.

Vicki Arroyo: And of course RGGI has already been a success story. If you look at the fact that they've been able to plow $1.6 billion worth of value back into their economy while creating 16,000 jobs according to an external analysis, while actually lowering the overall energy cost to their communities, I think RGGI has to be an example that you'd look at if other parts of the country are interested in that model. But that's not to say that we suggest that you should impose RGGI on other states, but that RGGI could be a model. In some states that might be interested in joining RGGI, that could be one approach to meeting a 111(d) target.

Monica Trauzzi: All right, a lot to watch here. Thank you both for coming on the show.

Vicki Arroyo: Thank you.

Gabe Pacyniak: Thank you, Monica.

Monica Trauzzi: And thanks for watching. We'll see you back here tomorrow.

[End of Audio]



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