How Much Does the Existing Regulatory Patchwork Reduce U.S. Greenhouse Gas Emissions

Abstract

This paper offers an answer to the question, “What levels of greenhouse gas (“GHG”) emissions reduction do the constituent programs in the U.S.’s existing regulatory patchwork achieve?” Its answer represents an attempt to measure the same effect from eight regulatory interventions: EPA’s Prevention of Significant Deterioration program, as it is expected to operate following the Supreme Court’s UARG v. EPA decision in 2014; EPA’s Clean Power Plan; EPA’s renewable fuel standard; the federal Corporate Average Fuel Economy standards for light, medium, and heavy duty vehicles; the renewable electricity generation Production Tax Credit and Investment Tax Credit; the Regional Greenhouse Gas Initiative, which encompasses 9 states in the mid-Atlantic and Northeast; California’s Global Warming Solutions Act of 2006, Assembly Bill 32; and state renewable portfolio standards. Notably, though it seeks to measure the same effect of diverse policies, this paper does not purport to measure the aggregated net effects of those policies on GHG emissions.Most important among its conclusions are the following. First, federal CAFE standards, the Clean Power Plan, and state renewable portfolio standards will be crucial for achieving emissions reduction goals. Second, the reductions available from the renewable fuel standard are uncertain and highly contentious. And third — an important subtext — the effectiveness (and cost-effectiveness) of this patchwork of programs is unwieldy even to measure, much less to ensure.