Monday, September 25, 2006

The Regional Greenhouse Gas Initiative, Kudzu, and Upstate

The Global Warming story out of California that we blogged about last week got us wondering about what has been going on with the Regional Greenhouse Gas Initiative (RGGI or "ReGGIe"), a plan by northeastern states to reduce carbon dioxide emissions to help combat global warming.

The answer is that plenty has been going on. A Memorandum of Understanding between the signatory states was released 12/20/05 and amended 8/8/06. A 163 page Model Rule was released 8/15/06. New York State DEC just announced that New York will propose a draft regulation this fall. So, it appears that the Northeast is well on its way to bringing itself into allignment with those countries who signed on to the Kyoto Protocol even though the US as a whole has not.

What does RGGI have to do with Kudzu? If you remember Kudzu, planting of the vine was encouraged to control erosion. It did that very well ... In fact, it did that too well. The vine grew like crazy and became a problem itself, choking out beneficial vegetation and, basically, coverning everything, including entire buildings.

Kudzu illustrates the "Law of Unintended Consequences" (or LUC): An action intended to solve one problem creates a host of unforseen effects. Bad LUC happens when someone concentrates so hard on the solution of a problem that potential negative effects of a different nature go totally unnoticed. We fear that will be the case with RGGI.

First of all, Faultlines is skeptical that RGGI, even if combined with a fully implemented Kyoto Protocol, has any potential to significantly alleviate global warming. While anthropogenic global warming appears to be taken as "gospel" by many scientists and politicians, there are a number of professionals who feel that the theories are not sound enough upon which to base public policy.

Assuming for the sake of argument that RGGI will contribute to solving the global warming "problem," what other effects will RGGI create? The fact is, we don't know because it has not been studied. The National Environmental Policy Act and the New York State Environmental Quality Review Act were intended to avoid unintended consequences by requiring a thorough study of impacts before actions (including policy making in NY) are taken. We've searched all over and have yet to find an environmental impact statement for RGGI. So we don't know what the unintended consequences of RGGI might be. We suspect that the RGGI carbon cap-and-trade system will hasten the abandonnment of fossil-fuel fired generating plants Downstate, increasing the need to "import" "clean" energy from or through other areas SUCH AS UPSTATE.

Will Upstaters really care that the world's temperature is .0001 degree cooler when their landscape gets covered with windmills and powerlines to feed the Downstate market? We don't think so.

RGGI was the brainchild of Gov. Patacki, someone who is interested in higher office and might want to appear "green" for a national audience. We don't think RGGI has been adequately thought through . . . Neither does Massachusetts nor Rhode Island which opted out of the agreement.

Before any further action is taken to implement RGGI, an Environmental Impact Statement needs to be developed that examines, among other things, how Upstate NY will be impacted.

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