At this past summer’s meeting of the National Association of Regulatory Utility Commissioners (NARUC), I served on a panel of experts discussing what might happen to America’s efforts to reduce greenhouse gas emissions in the wake of the Trump administration’s planned withdrawal from the Paris Agreement.

The outlook from my fellow panelists was rather pessimistic. They questioned whether, absent American leadership, global emissions would continue to decline. I was charged with discussing China’s actions to reduce greenhouse gas emissions and improve air quality, but as questions delved into my former experience as a state air quality regulator, we began to discuss what states might do now—without federal action.

The NARUC panel brought back memories from the 2003 United Nations Framework Convention on Climate Change (UNFCCC) Conference of the Parties (COP-9) in Milan, Italy, where then-U.K. Environment Minister Elliot Morley stated that the United States “isn’t doing anything” about greenhouse gas emissions. Minister Morley, and my fellow panelists at the recent NARUC meeting, perhaps overlooked the fact that state and city governments have pursued policies to reduce emissions and improve air quality for decades.

States and cities can’t sign binding international treaties or trade agreements, but they have proved effective crucibles to test ideas and policies, paving the way for implementation at scale.

For example, at the time of COP-9, the six New England states had already committed to working together to reduce greenhouse gas emissions 80 percent by 2050. That effort, led by governors from both political parties, laid the groundwork for the Regional Greenhouse Gas Initiative (RGGI). The seminal auctioning of greenhouse gas allowances through RGGI has raised nearly $1.5 billion in the past decade to invest in energy efficiency and renewable energy and protect low-income consumers. RGGI has reduced emissions in its member states almost by half while providing a range of additional benefits.

Keeping the Paris Pledge Alive

Almost immediately following the administration’s Paris announcement, the elected leaders of 14 states and territories, hundreds of U.S. cities, and 1,400 corporations pledged to stay the course on greenhouse gas reductions targeted by the Paris Agreement. Collectively, these jurisdictions represent nearly 40 percent of the U.S. economy. Nevertheless, many observers here and abroad openly questioned whether these pledges were meaningful, given that sub-national governments cannot be signatories to the Paris Agreement. For me, this was, as Yogi Berra once said, “Déjà vu all over again.”

It is easier for political leaders at any level, of course, to make bold pronouncements than it is to deliver actual reductions. Unless such commitments are paired with the policies and resources necessary to implement and enforce them, they can justifiably be regarded as meaningless political expressions. But this isn’t true for many, if not most, sub-national commitments.

In the United States, energy policy and environmental policy are highly devolved governmental functions. States have the legal authority to adopt and enforce a wide array of policy instruments that can reduce greenhouse gas emissions directly or indirectly, regardless of whether the federal administration supports or opposes such policies.

Cities and other units of local government generally have less authority to regulate, but 15 percent of U.S. electricity is sold by municipal electric utilities that answer to local government officials and the communities they represent. These utilities can and do respond to policies adopted by local governments. The combination of state and local energy policies has proven to be quite effective at reducing emissions: energy sector greenhouse gas emissions in the U.S. have declined 14 percent since 2005—in the absence of any binding federal emissions targets.

Tools of the Trade

How did this happen? Certainly, dramatic cost reductions in wind and solar helped. But much of the change was driven by four proven policy instruments adopted by state and local governments:

• Energy Efficiency Programs: As of January 2017, 26 states have established mandatory energy efficiency programs and energy savings targets for electric utilities, with 16 of these states also setting efficiency targets for natural gas utilities. U.S. retail sales of electricity grew by just 1.1 percent over the entire decade from 2006 to 2016, thanks to these sub-national policies and improved federal appliance efficiency standards. Over the same decade, U.S. gross domestic product grew by 14.2 percent, demonstrating that economic growth is no longer coupled with energy consumption.

(Source: 2017 Sustainable Energy in America Factbook, Bloomberg New Energy Finance)

• Renewable Portfolio Standards (RPS): RPS policies require utilities to procure a percentage of the electricity they sell from renewable sources. At least 29 states have RPS requirements, and several have adopted more ambitious RPS policies since the Paris Agreement was signed (e.g., Oregon, Maryland, Michigan, Rhode Island, and New York).
• Cap-and-Trade Programs: The states that launched the RGGI cap-and-trade program in 2009 agreed in 2012 to reduce greenhouse gas by 2.5 percent each year through 2020, and more recently, to an additional 30 percent emissions cap reduction by 2030. California’s greenhouse gas reduction plan caps emissions at 256 million tonnes by 2030, down from 441.5 million tonnes in 2014. Quebec has joined California’s greenhouse gas program, and Ontario is in the process of doing so.
• Motor Vehicle Emissions Standards: 13 states plus Washington, DC, have adopted California’s tailpipe standards limiting greenhouse gas emissions. The EPA adopted the California standards starting with the 2016 model year. Quebec adopted the California standards in 2014, and Canada aligns its national motor vehicle regulations with those from the United States.

Sub-national governments will continue to rely on these and other policies in the years ahead, whether the federal government leads or lags. And if enough sub-national governments implement policies to reduce greenhouse gas emissions, it is entirely possible—indeed, likely—that overall U.S. emissions will decline to the levels pledged in the Paris Agreement.

So, with hundreds of local and state commitments to reduce greenhouse gases, how can we know which ones will lead to results? Which ones might influence overall national direction?

Here are some key actions that states and local agencies can do to ensure the success of their policies:

• Prepare verifiable and transparent greenhouse gas emissions inventories using accepted accounting procedures;
• Develop a climate change action plan (CCAP) (or a multi-pollutant plan) that broadly involves stakeholders and selects specific policies to reduce greenhouse gas emissions, defines the amount of reductions expected, and estimates the costs and benefits associated with implementing and enforcing such policies;
• Identify the agencies responsible for implementing and enforcing each policy and provide the resources for them to do so;
• Identify a trajectory of greenhouse gas reduction targets that will occur over a specific time frame, including interim objectives (a single aspirational target is less likely to be achieved);
• Maintain a publicly accessible website that makes available the CCAP, its policy measures, expected reductions, and progress to date;
• Develop a replicable and transparent process through which the public and affected businesses are kept informed regarding the design, implementation, and enforcement of CCAP policy measures; and
• Institute a process to coordinate actions with other jurisdictions to share information, policy design and implementation, best practices, and lessons learned.

With apologies to Mark Twain, it would seem that reports of the death of climate action are greatly exaggerated. Real action? It’s alive and well in cities and states.

—With contributions from John Shenot.