On February 14, 2002, President Bush delivered two major proposals addressing air quality and global warming: the Clear Skies Initiative (CSI) and Global Climate Change Initiative (GCCI). The proposals were in response to criticism the Bush administration has received since releasing a national energy policy perceived to be environmentally unfriendly and rejecting the Kyoto Protocol, designed to reduce the loading of global warming pollutants. Bush argued that the Kyoto protocol unfairly apportioned pollution reduction requirements and would "cost millions of American jobs and inhibit industry's ability to make long-term investments in developing clean energy."

The White House claims that the Clear Skies Initiative is "the most significant step America has ever taken to cut power plant emissions." According to a fact sheet released by the Bush administration, the two initiatives will achieve the following: Clear Skies Initiative

• Cut sulfur dioxide (SO2) emissions by 73%, from 11 million tons to a cap of 4.5-million tons in 2010, and 3-million tons in 2018.
  
• Cut emissions of nitrogen oxides (NOx) by 67%, from 5-million tons to a cap of 2.1-million tons in 2008, and 1.7-million tons in 2018.
  
• Cut mercury emissions by 69%, from 48 tons to 26 tons in 2010, and 15 tons in 2018.
  
• The CSI proposes a market-based voluntary approach using a traditional cap and trade program modeled after the acid rain program.

Cut greenhouse gas intensity by 18% over the next ten years. Greenhouse gas intensity is the ratio of greenhouse gas emissions to economic output. The GCCI seeks to lower the rate of emissions from an estimated 183-metric tons per million dollars of GDP in 2002, to 151-metric tons per million dollars of GDP in 2012.

The means to achieve the emission reductions are not well understood, and there is no agreement that these new initiatives achieve any additional benefit compared with existing programs. During a recent Air and Waste Management sponsored webcast, Dale Heydlauff, senior vice president, Environmental Affairs of American Electrical Power, expressed his concerns with how these new initiatives overlap with existing programs and stated that "The programs needs more certainty. Uncertainty leads to greater conservancy." In this regard, the Agency needs to be very careful with the processes deployed to achieve the objectives. A cap and trade program may have worked with the acid rain confined and controlled market, but care should be taken to anticipate a national trading program proposed by CSI and the multiple pollutants involved.

As expected, there are numerous concerns on the other side of the isle. According to several State regulators and environmental groups, both CSI and GCCI fall well short of two previous proposals discussed in late 2001 and anticipated for release instead of the adulterated proposals that emerged. According to David Hawkins, director of the Climate Center for the Natural Resources Defense Council, CSI "does no better than current law." He is referring to a number of regulations designed to reduce emissions from power plants including: New Source Review, the Mercury Maximum Achievable Control Technology standard, the NOx State Implementation Plan Call, Section 126 Federal to Source Limits, Prevention of Significant Deterioration Plans, and others. He further suggests that the Bush proposals do nothing to improve upon existing programs, and, in fact, are less environmentally friendly and only seek to provide power companies an extended period of time to comply with new rules while providing a loop hole to avoid litigation for past violations.

In at least one respect, industrial and environmental groups share a similar concern regarding the purpose of the Clear Skies Initiative. That is, if the program aims to achieve similar results, why reinvent the process unless a new approach can guarantee a less burdensome process, more operational flexibility, reduced risk of violation and greater return on investment.

Conclusion

While we struggle in the United States to reach for the high fruit on the pollution-emission tree, are there global values to be achieved by assisting developing countries in grabbing the low hanging fruit? In other words, it may cost an American company 2-3 times as much to control emissions on an existing plant due to the level of sophisticated technology needed to achieve the newest tier of emission reduction. By assisting developing countries, the same, if not more, emissions can be reduced on a global scale for less cost. It should be noted, however, that this approach does nothing for localized health concerns from certain pollutants such as lung and heart disease and premature mortality, but it does reveal an approach to more economically address global warming and global air quality in the short term. For more information on CSI and GCCI: visit www.epa.gov/clearskies/