Performance standards could cover up to 54 percent of U.S.
greenhouse gas emissions. The pie chart above depicts all U.S.
greenhouse gas emissions in 2008.
The World Resources Institute (WRI) announced today that Dr. Kevin Kennedy will lead its U.S. Climate Initiative, within the Climate and Energy Program, starting in April 2011.
Franz Litz, Nicholas Bianco, Michael B. Gerrard (Center for Climate Change Law
at the Columbia University Law School), and Gregory E. Wannier (Center for Climate Change Law
at the Columbia University Law School)
Working Paper: February, 2011
This working paper explores how states and the U.S. Environmental Protection Agency (EPA) could reduce greenhouse gas emissions from power plants and industrial facilities using the standards
of performance under section 111 of the Clean Air Act.
If passed, the American Power Act (APA) would require companies to hold permits to emit GHGs for all emissions from
facilities emitting more than 25,000 tons of carbon dioxide (CO2) or equivalent gre
WRI and Standard & Poor’s were unable to conduct a full assessment of credit quality per subsector
under EPA regulation because of limited information on the EPA’s anticipated regulatory approach
The criteria for determining free allowances may change in future climate policy proposals, including the possibility of not distributing any free allowances to industry.
In Standard & Poor’s view, the profitability of commodity chemicals production is highly correlated
to energy and raw materials prices because these costs often make up the majority of a chemical
Using the EIA policy scenarios and projections of the American Power Act (APA), WRI analyzed the potential additional
costs or savings as a result of climate policy.
WRI and Standard & Poor’s examined the possible credit implications of the policy scenarios for 13 of the most greenhouse gas-intensive chemicals manufacturing subsectors.
WRI believes that 2016 is likely the earliest year that future EPA regulation would cover GHGs from
existing chemical facilities. The form of regulation is unclear.