Compliment and Clarification on Greenhouse Gas Editorial

Yesterday, the Star Ledger ran an excellent editorial on the “Regional Green House Gas Initiative” (RGGI) “Too many flaws in greenhouse gas bill“

I agree with much of the reasoning, and especially applaud the conclusion:

“Unfortunately, the proposed RGGI law being rushed through Trenton’s lame-duck legislative session reflects a miserable New Jersey political tradition. Every special interest imaginable has reached in to grab a share of the money or other benefits….

Gov. Jon Corzine’s administration is anxious to pass an RGGI bill so New Jersey can show its commitment to the regional consortium. But the current bill carries too much baggage”.

However, it is important that one key fact be clarified, because it sets the context for the entire RGGI discussion.

Public policy is about balancing of interests, so the alleged benefits of RGGI in terms of actual emissions reduction must be clearly understood.

So I must take exception to one fundamental factual claim repeated in this editorial. Due to the complexity involved, this claim tends to mislead the public about the alleged benefits of RGGI:

“The RGGI requires that power plant emissions be cut 10 percent by 2020.”
This claim is at best misleading. It is especially confusing because the public assumes that the RGGI 10% goal gets half of the the 20% emission reduction goal of the Global Warming Response Act. This is simply a false assumption that is unfortunately perpetuated by the misleading claim.

There are 3 essential elements of that RGGi claim that must be considered discretely:
a) the RGGI baseline emissions year
b) what emissions are in the baseline emissions inventory and what are not
c) the timetables

(I am leaving out the enforceability of the goal)

Taking each element of the claim under consideration, RGGI might more accurately be described generally as an:

“attempt to reduce the rate of increase in regional emissions from power plants”.

OR, if numbers are reported, RGGI could be described as:

“a plan to reduce actual and expected 2005 regional emissions by 10% between the years 2015 and 2019”.

OR if NJ’s goals under RGGI are described:

“a regional plan that would reduce NJ’s current in state emissions from certain power pants by 1% by the year 2019.”

The essential confusion stems from the fact that the RGGI baseline emissions inventory is flawed.

RGGI only included emissions from in state power plants larger than 25 megawatt capacity. Smaller in state emission sources were not included nor were those of out of state power plant emissions that occur due to large imports of electric power from mid-western coal plants.

RGGI inventory included actual current emissions plus those that were expected to occur. As a result, when the RGGI program agreement was fleshed out during 2004 – 2006, the emissions inventory was larger than actual emissions. Because emissions have gone down since then (contrary to projections) the baseline is even larger than current actual emissions.

This has been described as a “cushion”.

But what this means is that – for NJ – that the 10% emission reduction goal is in reality a 1% goal. See: Emissions proposal misses point

Because the Corzine Global Warming Response Act calls for a 20% reduction from total emissions by 2020, the RGGI goal must be placed in context.

RGGI does not govern all emissions. RGGI applies only to certain emissions in the electric power sector. But other sectors, like transportation and buildings, account for more than 2/3 of total emissions. This means the RGGI 1% emissions reduction is for less than 1/3 of the total.

So, we’ve got a long way to go to get there and RGGI is a very small step along that road.

Because RGGI calls for a 9% INCREASE in current power plant emissions and excludes emissions from electric imports, I think it is a step BACKWARDS along that road.

All this confusion could be easily avoided and real issues clarified if BPU had released the long awaited Corzine Energy Master Plan and DEP released the emissions inventory
BTW, DEP conducted an emissions inventory way back in 1997 under the Whitman Administration, a fact that has been completely ignored.
What ever became of that emissions inventory?

How does it compare to the new emissions inventory mandated by the 2007 Global Warming Response Act? (anyone remember the 60’s band “Ten Year’s After’? )