The Policy Institute, based in Helena, Montana, blends authoritative research and hands-on political engagement to create public policy based on economic justice, fair taxation, corporate accountability and environmental responsibility.

A Response to the EQC's Solicitation of Public Input on the Climate Change Draft Report and Draft Legislation

August 21, 2008

Dear Sen. Wanzenried, Chairman of the Environmental Quality Council:

We write in response to the Environmental Quality Council’s solicitation of public input on the EQC’s draft report, “Climate Change: An analysis of climate change policy issues in Montana,” and the draft legislation that accompanies the report.

All of the organizations listed as signatories to this letter believe that climate change is a subject of utmost importance that must be addressed quickly, strongly, and comprehensively by all people and by the governments that represent them, including the State of Montana. Most signatories have attentively followed the EQC’s deliberations on climate change and have engaged with the EQC whenever possible to advocate for public policy solutions that measure up to the challenge posed by climate change.

Because public policy established by legislation will define much of Montana’s approach to climate change, the principal focus of this letter is the scope and content of the draft bills offered by the EQC for public scrutiny. In this regard, while we support almost any meaningful approach to reducing greenhouse gases in Montana, including most of the EQC recommendations, we are profoundly disappointed by the limited number and scope of solutions proposed by the EQC. The EQC’s response to one of the most compelling issues ever faced by the State of Montana falls far short of what is needed. We urge the EQC to reconsider its underpowered package of draft bills and to construct a legislative agenda that truly measures up to the scope of the climate change problem.

By our analysis (which necessarily has been done quickly and without a great detail of data, given the nature of the proposed bills), the 11 draft bills offered by the EQC have a collective net cost of roughly $175 million to Montana taxpayers in a 12-year period and can be expected to decrease carbon emissions by 10 million metric tons. Those figures may be compared to the estimated net economic benefit of $65 million and estimated 63 million-ton reduction that would occur over the same period if all 54 recommendations of the Governor’s Climate Change Advisory Committee were executed. (Though the Climate Change Advisory Committee’s recommendations should not be regarded as the be-all, end-all package for Montana in confronting climate change, we will use them as a reference point for our thoughts, just as the EQC has done.)

Thus, in reducing greenhouse gases, the EQC proposals would produce a net cost to Montana, instead of an economic benefit that would result from execution of the complete Advisory Committee package, and in the most fundamental objective of reducing pollution, the EQC proposals would have less than 16 percent of the estimated collective effect of the Advisory Committee’s recommendations.

In fact, the best measure of the EQC’s commitment to addressing climate change may be taken from the Advisory Committee recommendations that the EQC has chosen not to pursue. For example, the Advisory Committee’s recommendation for “Light-Duty Vehicle Clean Car Standards,” i.e., increasing miles-per-gallon requirements on new vehicles, would produce, if executed and as calculated by the Advisory Committee, 4.92 million tons of carbon reduction in Montana – almost half of the total pollution reduction potential of the EQC’s 11 proposals – and would have an estimated net economic benefit to Montanans (through reduced fuel expenses) of $492 million in a 12-year period.

We recognize that vehicle mileage standards are established at the federal level and that a state with a relatively small population cannot expect to have inordinate influence in creating higher national standards. But why wouldn't Montana, through a strong message from its Legislature, at least lend its voice and whatever political clout it can muster to an idea that would produce such significant return – in carbon reduction and economic value – to the state’s residents? In an era of formidable corporate influence and a federal government unwilling to act decisively on energy issues, how better to pursue sensible national policy than through the collaboration and full participation of states and regional constituencies? We see nothing in the EQC’s draft report to explain why EQC would pass on an opportunity to cooperate with others and pick this low-hanging energy fruit.

Other recommendations absent from the EQC proposals include energy supply portfolio standards for efficiency and conservation (5.4 million tons of carbon, $79 million economic benefit), demand-side programs (6.6 million tons, $141 million benefit), and state appliance standards (1.5 million tons, $55 million benefit), to name a few.

As explained in the report that accompanies the draft bills, most of the EQC’s proposals grew from the results of an opinion survey that was conducted in February. There would be a strong argument for such a representative approach to problem-solving were it not for two qualifying factors: 1) the opinion survey presented the Advisory Committee’s recommendations in a technical language not easily comprehensible to many people and without easy-to-access figures for the net economic value and the carbon-reduction impact of each recommendation; and 2) some significant energy-saving and carbon-reduction measures that found favor in the survey, such as market transformation/technology development programs (1.9 million tons, $43 million benefit) and industrial energy audits (3.6 million tons, $93 million benefit), were dropped by the EQC, with no explanation provided in the draft report. Though the EQC may have eliminated these measures after committee discussion, we suggest that a rationale for the omission of recommendations that were popular with both public and committee respondents to the opinion survey be written and made part of the final climate change report.

Carbon-reduction numbers are critical because decreasing greenhouse gas production lies at the core of the climate change issue. And because some Advisory Committee recommendations would reduce pollution to a much greater degree than others, the desirability of a particular solution is related in no small way to how much carbon reduction it can be expected to achieve. So, in addition to suggesting that the EQC beef up its climate change package by including several more of the Advisory Committee’s high-impact recommendations, we urge the EQC to quantify all of its proposals, as well as its selection rationale, in terms of carbon reduction and net costs.

A central reason for the limited nature of the EQC proposals is, without doubt, the antagonism felt by some EQC members toward the idea that climate change is occurring, or that humans bear responsibility for the phenomenon, or that government efforts should be made to address it. We have little expectation, given the ever-rising mountain of evidence for a warming planet and the role of humans in the process, to change those doubters’ minds, but we wonder why all EQC members – independent of their opinions on climate change and its causes – would not embrace, or at least enthusiastically investigate, the Advisory Committee recommendations that both save energy and offer significant economic value to Montanans.

By our calculation, there are 13 Advisory Committee recommendations that, collectively, offer a net economic return of more than $700 million over 12 years. That’s $1,942 per Montana household. Those recommendations include higher vehicle mileage standards (discussed above), higher efficiency standards in energy supply, appliance standards, strengthened building codes, industrial energy audits, fuel-efficient replacement tires, and heavy-duty vehicle idling reduction, among others.

Thus, while one who questions the existence of climate change or the need to address it may be able to explain opposition to a mitigation measure that has a net cost to society, we ask why any proposed public policy that not only decreases greenhouse gas emissions, but simultaneously reduces energy consumption, helps to alleviate the energy crisis, and yields economic benefit on a broad scale is not aggressively pursued. At the very least, any proposal that promises such positive outcomes should be further studied to confirm or refute the economic justification for the proposal.

We therefore urge the EQC to expand its list of legislative proposals to address – either through immediate enactment or further study – all those recommendations in the Advisory Committee’s report that offer both carbon reduction and net positive economic benefit to Montanans.

With regard to the 11 proposals offered by the EQC, we question why industry and major energy producers have been given no role or obligation in addressing the climate change problem. The EQC proposals lean on concepts of voluntarism (recycling), tax abatement (local food production and energy conservation), reporting (transportation), and study (biomass), but not on requiring participation from the corporations and businesses who figure centrally in so many climate change and energy issues. We urge the EQC to restructure its climate change package to allocate responsibility and obligation fairly among all constituencies.

Though we welcome most of the EQC draft bills, we take exception to the joint resolution “encouraging Congress to adopt the National Association of Counties’ resolution regarding hazardous fuels emergencies.” We have not fully analyzed the Association’s resolution, but we note that the EQC’s draft bill endorses “fast-track” forest planning that would exclude citizen participation as otherwise required by the National Environmental Policy Act. This provision appears to constitute a curtailment of government transparency and public involvement, at a time when a problem that affects everyone will be successfully resolved only with maximum citizen participation and commitment.

Thank you for your consideration,

Sincerely,

Alternative Energy Resources Organization: Ben Brouwer, Renewable Energy & Conservation Program Manager

Clark Fork Coalition: Garrett James Budds, Conservation Director and Staff Attorney

Good Works Ventures, LLC: Mary Stranahan

Montana Audubon: Janet Ellis, Program Director

Montana Conservation Voters: Theresa Keaveny, Executive Directors

Montana Environmental Information Center: Anne Hedges, Program Director

National Wildlife Federation: Tom France, Regional Executive Director

National Center for Appropriate Technology: Kathy Hadley, Executive Director

Northern Plains Resource Council: Beth Kaeding, Chair, Board of Directors

Sierra Club: Paul H. Shively, Senior Regional Representative, Great Plains

Sustainable Obtainable Solutions: Gloria Flora, Executive Director

The Policy Institute: Bob Decker, Executive Director

Western Organization of Resource Councils: Peggy Utesch, Chair, Responsible Energy Development Campaign Team