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Comprehensive Climate Action Plans: What’s a Greenhouse Gas Reduction “Measure”?

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Climate Justice Climate Energy Environmental Justice Public Participation

State and regional governments across the country are engaging in climate action planning, some for the first time. Forty-five states, dozens of metropolitan areas, and almost 100 Tribal entities are participating in the Inflation Reduction Act’s Carbon Pollution Reduction Grant (CPRG) program, which provides funding for subnational climate action planning and implementation. The next “deliverable” for each grant recipient, due in 2025, is a comprehensive climate action plan (CCAP).

Decarbonizing our energy system and achieving carbon neutrality will have economy-wide implications and require careful planning to mobilize necessary changes to electricity generation and transmission, industry, building infrastructure, transportation, land use, waste management, agriculture, forestry, and more. And a clean energy transition will require coordination among diverse sectors, as vehicle and building electrification impact the electricity sector, household-level investments affect housing costs and rents, and land use decisions implicate transportation options. Planning is necessary for an effective transition and for optimizing benefits — for achieving the widespread potential benefits of a clean energy transition and reducing potential harms.

Federal planning grant recipients are confronting a key question as they develop greenhouse gas reduction measures: what, exactly, is a climate measure? Are “measures” simply the needed technological or behavioral shifts, like electric vehicle adoption rates and percentages of renewable energy? If so, how specific should the measures be? In addition, should states or other planning entities describe the legal mechanisms they intend to deploy to achieve particular goals or technological shifts?

In this issue brief, we provide insights into the kinds of measures that planning entities should include in their CCAPs. The brief first provides an overview of the CPRG program and its guidance for comprehensive climate action plans. It then provides an overview of the resources on “measures” that EPA provided. In the absence of a definitive model, we evaluate what the guidance’s other requirements reveal about the kinds of “measures” planning entities should include. Because EPA expects planning entities to evaluate their legal authority to implement their proposed measures and expects them to detail the measures’ impacts in general and on environmental justice communities in particular, we conclude that planning entities should include relatively specific policy mechanisms for achieving their decarbonization goals. Providing specific policy frameworks will help planning entities consider the distributional impacts of their chosen policies, enhance meaningful public participation, and take advantage of the interagency collaborations encouraged by the CCAP process.

Read the issue brief.
Read the related blog post.

Climate Justice Climate Energy Environmental Justice Public Participation