Four principles for climate policy design

350 Seattle has just sent in its recommendations for Washington state climate policy to Governor Jay Inslee and his climate policy task force.  Cascadia Planet offers these recommendations as a model not only for Washington, but also as a set of four principles to guide climate policy design in general – P.M.

From 350 Seattle to Governor Jay Inslee and the Carbon Emissions Reduction Taskforce: Our thanks and our recommendations

Dear Governor Inslee and Task Force Members:

350 Seattle is a grassroots organization working for climate justice by educating people and engaging them in the movement for a livable planet. We applaud your commitment to designing an effective climate and carbon policy for Washington State.  We are grateful for actions that move Washington State off fossil fuels and towards a highly efficient economy run on clean energy sources.

As you know, the impacts of carbon pollution on our state are already severe, from record wildfires to shellfish industry distress.  Like you, we recognize the urgency of reducing carbon pollution as quickly as possible.  Though Washington represents only a small portion of global emissions, it is incumbent upon us to act where we can and set an example for other states, our nation, and our world.  Your climate policy design work is extremely important.

In the spirit of joining to ensure a climate legacy for our children and coming generations, we offer the following recommendations:

Regardless of the type of carbon-pricing system, ensure that it is strong enough to make a difference quickly.

Examples of ways to do this include:

●     Limiting the role of carbon offsets. The governor has recommended that emitters be able to cover no more than 10% of their carbon reduction requirements with offsets.  We agree that it is important to limit offsets, to provide the greatest possible incentives for direct emissions reductions.  For this reason we urge that the target be set lower.  California limits offsets to 8%, and the Northeast’s Regional Greenhouse Gas Initiative (RGGI) limits offsets to 3.3%. We believe Washington State should set a limit closer to RGGI and suggest that no more than 4% of obligations be covered by offsets.

●     Including language about enforcement, and making sure there are adequate resources for enforcement. Unfortunately, we all know that some emitters may try to slip by without cutting their emissions as required. However, if all emitters know that their actions will be monitored, they will respond, and in fact will probably look for innovative ways to cut emissions.

●     Putting a price on a high share of emissions from the start. We recognize that it can make a big difference to businesses if they have a ramping-up period to help them adapt to carbon pricing. At the same time, ramping down emissions is urgently demanded by our current situation. If a cap-and-trade system is chosen, we believe the initial level of auctioned permits should be well over the 15% suggested by the governor. Similarly, if a carbon-tax system is chosen, the system should cover most types of emissions sources right from the start, and not offer exemptions for significant sectors of fossil fuel energy use.

Consider ways to accelerate Washington carbon reductions, in line with climate science.

Climate science pioneer James Hansen and his team have calculated the carbon reduction trajectory needed to return the atmosphere’s carbon dioxide concentrations to 350 parts per million (ppm) by 2100; this is the level at which planetary energy balance is restored and the planet stops accumulating solar heat (it is also the reason for our organization’s name). It is therefore essential to reach this goal.  That requires emissions reductions on the order of 6% annually plus significant increases in biological carbon storage. The Hansen study is available at this site:

Washington’s current non-binding targets, set in 2008 legislation, are a return to 1990 emissions levels by 2020, a 25% reduction by 2035, and 50% by 2050. For Washington to achieve carbon reductions in line with global targets set by Hansen et al, our goals need to  be approximately  a 30% reduction by 2020, 70% by 2035, and 90% by 2050. We recognize the tremendous challenges involved in meeting those targets globally, let alone by a single state.  Nonetheless, we ask the Governor to consider ways to accelerate carbon reductions beyond the 2008 targets, particularly in early years when deep emissions cuts are most crucial.

The Governor has instructed the CERT to design policy around the 2008 targets. In line with the Governor’s order to Department of Ecology to “review the state’s greenhouse gas emission limits and recommend updates” we urge the Governor to consider proposing higher binding targets to the legislature. Another option would make the current targets binding, but set stretch goals to be achieved by complementary policies and investment of carbon revenues in specific emissions reductions strategies.  In any event, climate legislation and rulemaking processes should be crafted to allow for tighter carbon caps in response to emerging science and the understanding of carbon reduction opportunities.

It is abundantly clear from the science  that not taking strong early action may lead to climate tipping points and changes with centuries-long impacts. We should all recall the collapse of the summer Arctic icepack in 2007, decades ahead of projections. Our planet is capable of delivering dangerous surprises, so we must act on the side of caution. We need to take bold action sooner rather than later.

As much as possible, use carbon revenues for investments in carbon reduction.

We recognize that carbon pricing will increase energy costs; to instill a sense of fairness and increase public support, we need to reduce the impact on low-to-middle-income people by rebating a portion of carbon revenues. Apart from this, carbon revenues should be invested as much as possible in carbon-reducing activities.  We believe that the following investments have greatest potential to reduce carbon emissions. 

●        Low-cost financing for building energy retrofits that fully capture efficiency opportunities.

●        Elimination of all coal- and gas-generated electricity used in Washington, replaced with renewable energy and improved energy efficiency.

●        Increased incentives for rapid transition to electrified transportation in all sectors where feasible, including light-duty vehicles and railroads.

●        Reduction of the need to drive by upgrading transit and other options to the automobile, and building affordable housing close to job centers.

Reduce atmospheric CO2 levels by investing in biocarbon.

Most projects to build up biological carbon storage for climate goals have been in the offsetting framework. But these projects only neutralize a current carbon emission. Achieving climate stability requires reduction of pre-existing atmospheric carbon concentrations, already at 400 ppm. Though technological modes are being developed to soak CO2 from the atmosphere, plant photosynthesis is currently the only economically feasible way to do this. Hansen’s team estimates that 100 billion tons of atmospheric carbon must be absorbed  and stored as biocarbon this century to reach the target of 350 ppm by 2100.

Washington State has magnificent natural assets that can store large amounts of biocarbon, including our forests, farms, and wetlands. We need to invest carbon revenues in carbon-mitigating land use management. Here are some examples of possible high-value biocarbon investments:

●     Extending harvest rotations on Department of Natural Resources forest lands

●     Purchasing private forest lands to add to state working forests and reserves

●     Buying conservation easements on private forest lands

●     Providing incentives for farmers to shift to soil-building practices such as no-till cultivation

●     Supporting the capacity of Washington State University and conservation districts to provide technical assistance for implementing soil-building practices

●     Providing additional funding for wetlands restoration.

These measures can also provide the additional benefit of building resilience in the face of climate impacts. Healthy forest stands retain moisture, thus working against drought stress, as well as floods and slides caused by heavy rainfall.  Soil rich in organic carbon reduces crop losses by retaining moisture, improving fertility, and building resistance to pests and disease. Wetlands buffer against storm surges and floods.

Washington State is a climate leader. By setting a high bar for carbon reduction goals, limiting offsets, and investing in actions to reduce carbon emissions and atmospheric carbon concentrations, we can set the pace for other states and the nation as a whole.

350 Seattle asks you to consider our recommendations as you design climate policy and legislative proposals. We are leaving our children with a terrible legacy. Please do absolutely all you can to give them a fighting chance by designing and proposing the strongest possible climate and carbon policy for Washington State.  Leadership on this issue is the best legacy you can possibly leave.