Monday, the Washington Post Editorial Board published the first in a “brief series” of editorials on the status of U.S. greenhouse gas (GHG) policies. The Post article gives a short history of GHG politics over the last 15 years and assesses the current state-of-play in and outside the beltway. Of course, the policy that is driving most of the discussion and debate when it comes to GHGs is the EPA’s June 2 proposed rule for existing power plants – a regulation the Post describes as “a cumbersome and expensive way to reduce emissions.”
If after reading through the 1,600 pages of regulatory text of EPA’s proposal you were looking for two words to sum up what likely consumed the better part of your summer, you could do worse than “cumbersome” and “expensive”. Anyone who sat through EPA’s two-day hearings on the rule in late July in Pittsburg, Atlanta, Colorado or D.C. repeatedly heard similar words used by the industries that will be most impacted by the regulation. The fact is the rule proposes to fundamentally change how energy is made, distributed and consumed in this country. There is little argument that it won’t have at least some upward pressure on energy prices and there is good reason to think the increases could be dramatic in many parts of the country. In fact, at some level, that is one of the end-goals of this regulation – to make electricity, and in particular fossil electricity, more expensive in order send a price signal to producers and consumers alike to change behavior. It’s always going to be hard for manufacturers – consumers of one-third of the nation’s energy – to get behind a policy designed to increase energy prices, particularly when our foreign competitors aren’t paying for similar price increases and are more than offsetting any of our emissions reductions.
However, what makes this rule all the more troubling is all of the uncertainty and questions it has created. Beyond questions regarding EPA’s legal authority to implement such an expansive rule – for which there are many. And beyond uncertainties of whether energy markets throughout the country can deliver uninterrupted electricity and heat under the proposed rule’s framework – EPA hasn’t model it. There are fundamental questions regarding what EPA is even proposing. For instance, how are certain new units treated for a state’s compliance in the rule? How does EPA plan to implement such a program if it does not approve of a state’s plan? How exactly does the interplay between net electricity importing and exporting states work for compliance? We are a month and a half away from when EPA will no longer accept written input on this rule and still these questions persist about what the proposed rule is proposing.
This doesn’t make sense. It’s time for EPA to take a step back. It’s time for the Administration to remove the arbitrary deadlines driving this expedited process. And as the Post will no doubt suggest in its coming editorial series, it’s time to explore better ways to establish our nation’s environmental and energy policies.