Twenty major environmental groups sent House Speaker Nancy Pelosi a letter (here) urging that she make three key improvements in the Waxman-Markey bill and reject attempts to weaken it.

The groups, which include the Sierra Club, the National Wildlife Federation, the National Audubon Society, Environment America, the League of Conservation Voters, the Natural Resource Defense Council, and the Union of Concerned Scientists, want to

  • “Increase the portion of pollution allowance value dedicated to delivering” clean energy;
  • “Preserve EPA’s ability under the Clean Air Act [CAA] to require existing power plants, refineries and other sources to meet up-to-date carbon pollution standards”; and
  • Strengthen the renewable energy and energy efficiency standard as follows:

Strengthen renewable electricity provisions to achieve 20 percent of sales generated from clean renewable energy by 2020, including the flexibility to achieve another 3 percent that could come from either efficiency or renewables by 2020. Increase the energy efficiency requirement so that utilities achieve 10% energy efficiency by 2020.  Strengthening these standards will generate hundreds of thousands of new clean energy jobs.

Can’t argue with any of those improvements (with caveat on CAA below).

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If I had to pick one to fight for, it would be strengthening the energy efficiency standards.  Given how lame the renewable standards are in the Senate bill and given how big a push Obama and Congress have given to renewables in the stimulus – see “EIA projects wind at 5% of U.S. electricity in 2012, all renewables at 14%, thanks to Obama stimulus!” – (and are planning to give in various pieces of legislation, including Waxman-Markey), I have doubts that the final bill will substantially increase renewable energy beyond business as usual.

But energy efficiency is the clean energy strategy that

  • can deliver the most low-cost kiloWatt-hours
  • needs the most help from legislation to tear down market barriers


I know many enviros want to preserve the CAA authority, but I do not believe that the Obama EPA was realistically going to use the CAA to “require existing power plants, refineries and other sources to meet up-to-date carbon pollution standards.”  Using the CAA to regulate existing power plants would take many years, require waiting for the states to demonstrably fail to take action, involve multiple lawsuits, and could easily be overturned by a subsequent administration.

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Obama would, I think, have used the CAA authority to regulate new sources.  Since he has already announced the most aggressive action on new vehicle greenhouse gas emissions (see “Obama to raise new car fuel efficiency standard to 39 mpg by 2016 – The biggest step the U.S. government has ever taken to cut CO2“), that mainly leaves new coal plants.  I’m not sure if Obama would have block every new dirty coal plant with the CAA, but he certainly would have blocked a great many of them.  But I think W-M is going to block as many as Obama would have, so I’m not certain it preserving this authority is worth a humongous political fight.

If you’re going to expend a lot of political capital, you should do so for something you can win and which would have a big impact.  That I think is most true of strengthening the efficiency standard, though it may well be possible to get some more allowances for clean energy and that is worth pushing for.

The other change I would certainly fight for, as I’ve discussed, is to sunset the offsets provision.

Finally, I agree 100% with the green groups when they write:

Unfortunately, some members of Congress and special interests have said they would like to roll back the already weakened target for reducing carbon dioxide emissions by 2020. We urge you to reject any effort to weaken these targets. We also urge you to preserve the provision ensuring that the latest science informs the policy and strengthen the policy response to that science.

Our top priority is to enact legislation that jump-starts a clean energy economy, creates millions of clean energy jobs and reduces global warming pollution while giving the U.S. credibility to lead international negotiations on climate change. By strengthening and passing the American Clean Energy and Security Act, the House of Representatives can take a critical step towards accomplishing that goal.