Thanks, Mary. I'd like to offer more background on why I'm asking about SIPs in the GHG context, particularly for those in this conversation who weren't at the Pocantico meeting. In the first draft of the Presidential Climate Action Plan I'm working on, we propose that regulation and market mechanisms work in tandem. The President would direct EPA to begin regulating GHG under the CAA. If a cap and trade regime is passed by Congress (or implemented by the president), we may find that it doesn't work as expected, or takes longer than expected to have an impact. It may take awhile to get the caps and carbon pricing right, for example. My thought is that regulation would ensure some progress on GHG reductions in the meantime. If and when cap and trade or some other carbon pricing mechanism works effectively, regulation would become moot. If we carry this recommendation over to the final presidential action plan we'll release in August, I'm hoping it will include recommendations on how to make the SIP process effective.

Another approach we recommend in PCAP, by the way, is to increase the State Energy Program from $35 million to $1 billion annually. To be eligible for the money, states would create energy and climate security plans with some required and many other voluntary elements -- decoupling, feed-in tariffs, capture of stranded renewable resources, interconnection standards, distributed energy generation, cogeneration, state RPSs, etc. As is the case with State Energy Plans today, the new state plans would be approved by the U.S. Department of Energy and requalified every three years or so. In an ideal world, I suppose, these plans could be incorporated into SIPs by reference, assuming there's a way to credibly estimate their GHG impacts.

The SIP process is way to cumbersome and EPA takes too long to respond to changes. There are too many separate deadlines, all enforceable by citizen suits. Deadlines and citizen suits are key ingredients of the Clean Air Act and its public health protections but not well suited to a new and rapidly evolving program to address global climate change.
n most states, SIPS are developed by the air regulatory agency and never reviewed or endorsed by other state agencies. To be effective, state GHG reduction plans need support from the Governor and from energy, transportation, and economic development agencies at a minimum. The plans need not contain the level of detail that SIPS require. Monitoring and reporting of GHG emissions should be uniform across state lines, however, and there should be a national registry for voluntary GHG reductions and emissions trades.