Deep in the heart of state and regional environmental and energy agencies, engineers, economists, scientists, and lawyers are working hard to develop comprehensive climate action plans (CCAPs). Created by the Inflation Reduction Act, EPA’s Climate Pollution Reduction Grant (CPRG) program is funding a range of state and subnational planning and implementation measures, including the CCAPs, which are due in 2025.
In our recent issue brief, Comprehensive Climate Action Plans: What’s a Greenhouse Gas Reduction “Measure”?, we explore a key question: What is the nature of the “actions” that planners should include in their climate action plans? Or, to use the program’s term, what’s a climate “measure?” In preparing their CCAPs, planners may debate whether the measures should be general or specific, and whether they should just refer to the technological shifts we need — like more EVs — or also include the legal mechanisms for achieving them — like rebates, or grants, or sales requirements. How planners frame their climate “measures” will shape how well we can assess the plans and their impacts and, relatedly, the degree to which the planning process provides a meaningful forum for addressing critical policy choices.
The CPRG Program
The Inflation Reduction Act appropriated $250 million for two sets of climate planning grants to states, Tribes, and other subnational entities, including metropolitan areas. Forty-five states, dozens of metropolitan areas, and almost 100 Tribal participants signed up and have completed the first phase: Priority Climate Action Plans outlining actions that are ready for lift off.
The second phase, to complete the Comprehensive Climate Action Plans by 2025, differs substantially from the first phase. As the name suggests, the program contemplates “comprehensive” plans for this round. The plans must quantify emissions, set medium- and long-term emission reduction targets, and develop “measures” for meeting the reduction targets.
Clues to Defining “Measures”
EPA’s guidance document provides little direct information on the nature of expected measures. However, a couple of the other required plan components indirectly suggest EPA’s expectations. EPA requires the CCAPs to identify whether the planning entity has sufficient legal authority to implement the measures they have included. That suggests that the planning entity should articulate its planned policy mechanisms, not just state its planned technological shifts. For example, a measure would not just set a target for “25 percent passenger electric vehicles by 2030,” but would include the policy mechanisms for achieving that shift, like a manufacturer sales requirement coupled with a consumer rebate program.
Another clue derives from the guidance document’s environmental justice provisions. The guidance requires planners to demonstrate the measures’ environmental justice benefits and risks. If planners include only very general measures, and do not specify how the goals will be achieved, then their environmental justice assessments will be guesswork. In order to determine location-specific outcomes, planners have to develop measures that are specific enough to lead to those outcomes. Moreover, in many instances, impacts on environmental justice communities could not be realistically determined without defining legal mechanisms. Taking the passenger EV goal, planners cannot determine the impact on environmental justice communities unless the measures actually address how and to what degree EV ownership would be facilitated in these communities.
The Benefits of Spelling Out Specific Policy Frameworks
Providing enough specificity to identify the environmental justice implications of the CCAPs’ measures will encourage planning entities to consider environmental justice policies as they develop their plans. Moreover, it will enhance public participation, furthering compliance with the guidance’s requirement that planning entities meaningfully engage with low-income and disadvantaged communities. If the CCAP measures are too general to predict their benefits or risks, then communities will not have the information they consider necessary to their meaningful participation.
In addition, the planning process provides an all-too-rare setting for cross-agency deliberation. If planning entities’ plans remain vague and the agencies do little to frame their policy mechanisms, then key strategic decisions will fall to the agencies’ siloed departments. Because so many climate actions implicate multiple sectors, collaborative cross-agency policy mechanisms developed through the CCAP planning process could be more successful than having individual departments make the key decisions later in the implementation process.
Of course, planning entities face considerable time pressure, and only so much can be debated and resolved before the plans are due in 2025. And, even if planners establish relatively specific policy frameworks in the planning process, much will remain to be resolved in subsequent implementation steps within specific agencies. That said, the CCAP process provides an unprecedented opportunity for states, metropolitan governments, Tribes, and other entities to develop a vision for the future and begin to collaborate on strategic and beneficial policies to achieve a clean energy transition.
Check out Comprehensive Climate Action Plans: What’s a Greenhouse Gas Reduction “Measure”? for more.
