EPA Analysis of Federal Bills Omits Key Assumptions

WRI’s bill analysis remains an accurate portrayal of the differences in the U.S. emissions levels under each bill. EPA recently released its analysis* of the atmospheric global warming emission concentrations under three proposed federal cap and trade bills. This analysis makes a key point: the U.S., acting alone, is not likely to be able to solve the global climate change problem. However, the results as presented obscure what is equally important: there remains a significant difference in the emissions reductions demanded by each bill. The emissions reductions target set by the U.S. will almost certainly have major implications for the global effort to solve the global climate problem. WRI’s bill analysis remains an accurate portrayal of the differences in the U.S. emissions levels under each bill. Although the U.S. is responsible for only 20% of global emissions, it is clear that as the world’s largest emitter, choosing a weak target will have environmental and diplomatic implications. Almost all analysts believe U.S. leadership in setting aggressive greenhouse gas (GHG) caps will be necessary to spur needed international action on climate change, and that developing countries will be more likely to take positive action if the U.S. takes on aggressive targets in line with its industrial peers rather than only adopting weak efforts. A number of critical assumptions underlie any bill analysis. EPA uses some assumptions that appear to differ from the text of the bills themselves. For example:

• The EPA analysis (which was requested by Senator Bingaman) assumes that the Bingaman-Specter (S.1766) bill’s Technology Accelerator Payment (a price cap on emission allowances) is not triggered. In fact, WRI’s review indicates the price cap is highly likely to be triggered (particularly if complementary measures such as a renewable energy standard and an increase in automobile fuel economy are not enacted).
• The language in the Bingaman-Specter bill will require that future legislation is adopted in order to enact a mandate to achieve a U.S. emissions reduction of 60 percent below 2006 levels by 2050. Although the language in the Bingaman-Specter bill only requires reductions in emissions through 2030, the EPA analysis is based on enactment of this future legislation that would achieve far greater reductions than those in the current proposal.

These two assumptions lead the EPA to project that there is a similar outcome under the Bingaman-Specter bill and those of Lieberman-McCain (S.280) and Kerry-Snowe (S.485). WRI has also undertaken an analysis of the total emissions that would be allowed under each bill. In WRI’s review of the cumulative emissions, we note there are significant differences in the emissions level achieved under each proposal. It is the total emissions level, not the annual emissions which drive global greenhouse gas concentrations. WRI’s analysis is based on what would need to be done globally to achieve greenhouse gas levels that will avert the most dangerous climate change impacts (scientists believe we must stabilize emissions in the range of 450-550ppm). Our analysis and chart demonstrate what U.S. emissions reductions need to be to achieve this goal. There are indeed significant differences in the outcomes from the various bills when this is taken into account. * “EPA Analysis of Bingaman-Specter Request on Global CO2 Concentrations,” October 1, 2007. Related Links

• WRI’s analysis of Climate Change Targets in the 110th Congress

Figure 1: Legislative Climate Change Targets in the 110th Congress Click the chart for a high-resolution version Figure 2: Cumulative Emissions Budgets under Legislative Climate Change Targets in the 110th Congress Click the chart for a high-resolution version