Posted on April 30, 2024 by Steven Chester
In mid-April of this year, the Climate XChange, a non-profit organization dedicated to advancing state climate policy, announced that it, along with RMI and the Evergreen Collaborative, had reviewed “6,795 pages of state climate plans.” These plans had been submitted to the U.S. Environmental Protection Agency (EPA) as part of the Carbon Pollution Reduction Grants (CPRG) program authorized by the Inflation Reduction Act. Before considering several key requirements of the CPRG program, let’s give credit where it is due and thank the Climate XChange and its partners for undertaking the review, and for offering their preliminary observations on the various measures proposed by the states to address climate change and advance a clean energy economy.
President Biden signed the Inflation Reduction Act on August 16, 2022. The White House has described the Act as “the most significant action Congress has taken on clean energy and climate change in the nation’s history.” . The Act created the two-phase CPRG program, with the first phase to provide $250 million in noncompetitive planning grants for state, local, territory and tribal governments to develop climate plans; and the second phase to provide $4.6 billion in competitive grants to those parties that received planning grants from EPA and submitted preliminary climate plans to the Agency.
In accordance with the CPRG program, states that obtained a planning grant from EPA were to submit a “Priority Climate Action Plan” (PCAP) by March 1, 2024, followed by a “Comprehensive Climate Action Plan” (CCAP) to be submitted in mid-2025. The differences in the scope and required detail of the PCAP and CCAP are significant. And therein lies the rub.
The PCAP is a preliminary plan, whereas the CCAP is intended to be a comprehensive plan. The CCAP must include substantially more greenhouse emission reduction (GHG) data, analysis, and funding information than identified in a PCAP. For instance, unlike a PCAP, a CCAP is required to include GHG emission projections, targets, and a comprehensive list of quantified GHG measures. The CCAP also must include a detailed benefits analysis, and work force planning analysis. Importantly, in addition to federal funding, the CCAP must identify state, local and private funding sources for its proposed climate initiatives and strategies.
The Climate XChange and its partners reviewed 47 PCAPs from 45 states, Puerto Rico and Washington D.C. Only five states chose not to submit a PCAP (Florida, Iowa, Kentucky, South Dakota and Wyoming). Indeed, this is an impressive response from the states. (Numerous local government groups and tribes also submitted PCAPs.) The reviewers noted that in their preliminary plans the states identified numerous “priority measures” to reduce GHGs but that there was considerable variability among the states in the number of identified measures. Also, certain economic sectors were covered in most of the state plans, such as buildings and electricity generation, but other sectors were underrepresented, notably the industrial sector which is a large source of GHG emissions. And one of the reviewers’ more significant observations was that very few states included “regulatory measures” in their climate plans and instead referenced only voluntary programs and projects.
The states have just over a year left to prepare and finalize their CCAPs. The amount of work and analysis that must go into the CCAPs will far exceed the effort taken to prepare the PCAPs. Based on EPA’s CPRG guidance to the states, the Agency will expect specific, well documented GHG targets and goals, comprehensive benefit and work force analyses, the identification of specific voluntary and regulatory mechanisms to implement each of the GHG reduction measures, and clearly identified state sources of funding (not just federal funds) to finance each of the state’s GHG initiatives and strategies at full program scale. EPA will look to the states to adopt best practices as part of their CCAP development. Those states that dedicate the resources and make the investment to submit a quality CCAP will better position themselves as candidates for federal CPRG funding, additional matching funds, and ultimately leveraging opportunities from the private sector. The open question is how many states will make the effort.
Time will tell.