Feedback to Doug
November 16, 2007
 
The Illinois Climate Change Advisory Group
A little over a year ago, Governor Blagojevich issued an Executive Order creating the Illinois Climate Change Advisory Group. His October 5, 2007 press release announcing the group stated it would “consider a full range of policies and strategies to reduce GHG [greenhouse gas] emissions in Illinois and make recommendations to the Governor.” The Governor’s release also stated “the Advisory Group has broad representation including business leaders, labor unions, the energy and agricultural industries, scientists, economists, and environmental groups from throughout the state.”

As with so many of Governor Blagojevich’s initiatives, the reality of this group’s make up, work process and recommendations is far different from the perception the administration presents.

Governor Blagojevich appointed Doug Scott, Director of the Illinois Environmental Protection Agency, to chair the group and hand pick the members. While touted as having “broad representation” the panel’s membership is unquestionably weighted toward environmental groups with agendas that are difficult for employers.

From the outset, it appeared the Governor was prepared to discount the knowledge and practical experience of industry experts responsible for managing and complying with state and national environmental laws and regulations. Industry experts such as those represented by the Illinois Environmental Regulatory Group (IERG) have long appreciated the reasonableness and practicality of balancing sustained economic growth through modernization and investment with ensuring healthy environmental outcomes. Yet, requests from Illinois’ business and industry organizations to have a seat at the table were summarily dismissed.

Before the Advisory group’s first meeting, Governor Blagojevich issued a February 13 news release announcing his goal to “slash” greenhouse gas productions to 1990 levels by 2020, and 60% below 1990 levels by 2050. These goals weren’t part of the executive order establishing the group; advisory group members were also not told of the planned announcement or his goals before the news release.

Thus, Advisory group members discovered a critical component of their expected recommendations was pre-determined before they even began their work.

Furthermore, ground rules provided at their February 22 first meeting limited them to comment and debate on “how to best meet the Governor’s GHG reduction targets” from a pre-defined list of suggested state climate policy options. Ground rules regarding parameters for the group’s agenda determined there would be no discussion or consideration of any federal approaches to the issue.

No doubt some of the appointees must have been wondering even then when the “advisory” capacity of this group would be honored since two major elements of any climate change report were pre-empted.

It is thought the IEPA staff is preparing a draft of the Advisory group’s recommendations for the Governor. This draft report has not been circulated among group members. Although expected at any time, there is no announced time or location for the report’s release, the next advisory group meeting, or any public hearings or input prior to adoption of a final report. Yet the website proclaims “Final Recommendations to the Governor” as approved at the July 10 and September 6 meetings.

Interestingly, at the July 10 meeting, five issues on the list were NOT approved, but tabled for a future vote because they were controversial -- controversial because, as recommended, they did not make good business sense to those Advisory group members representing labor and industry.

One recommendation called for a state level cap & trade program for emissions reductions. In a cap & trade system, carbon dioxide sources are allocated a number of credits and a limit on emissions. If a source exceeds the limit, fines or penalties could punish the producer. To avoid sanctions, a producer could purchase credits from other producers with emission levels below their allocated cap, who would be allowed to sell their excess credits. This could cost the utility industry and rate payers $1 to 2 billion annually. While this recommendation is primarily aimed at coal-fired electric generating facilities, it is readily applicable to industry boilers, manufacturing or any employer with on-site generation capacity.

Another recommendation would mandate automobiles sold in Illinois meet emission standards similar to those imposed in California. California has the most stringent auto emission standards in the nation, and is unique because the state adopted emission standards for cars in 1966, four years prior to the adoption of the federal Clean Air Act. IEPA recognizes adopting California standards could add from $1,000 to $3,000 to the price of a new car purchased in Illinois.

Another recommendation would mandate that automobiles sold in Illinois meet CO2 reduction levels similar to those proposed and being litigated in California. California already has the most stringent auto emission standards in the nation, and is unique because the state adopted emission standards for cars in 1966, four years prior to adoption of the federal Clean Air Act.

The latest California proposal to reduce carbon dioxide is synonymous with increasing fuel economy. The California fuel economy regulation has not yet been implemented in any state because only the federal government can set fuel economy standards. Toyota, Mitsubishi, Ford, Chrysler, General Motors, Volkswagen, Mazda, Porsche, and BMW have all testified that implementation of this fuel economy proposal is too aggressive and not achievable in the given timeframe. Compliance with this fuel economy regulation will therefore be realized through significant reductions in vehicle choice and capability in Illinois. Expert economists have predicted that Illinois consumers can also expect an average increase of at least $3,000 to the cost of new vehicles sold in the state if the advisory group’s recommendation is implemented.

The three remaining controversial issues include recommendations for CO2 emission performance standards for new electricity generation, carbon offsets for new fossil fuel power generation, and carbon capture and storage standards.

These recommendations represent a slap in the face to Illinois coal, a valuable and bountiful Illinois natural resource. Emissions standards proposed by the group would not only negate the market for Illinois coal to be burned in the state, but could well result in shutdowns of existing Illinois power plants. Today’s future of energy generation from coal is closely tied to investment in clean coal technologies such as coal gasification and carbon sequestration. Yet the group’s recommendations demonstrate little patience for the transition and survival of an industry that is extremely important to the state’s energy future.

The advisory groups’ recommendations were about as surprising as election results for Venezuelan President Hugo Chavez. When the vote on the five controversial recommendations was offered, each was pushed through along interest group lines: environmentalists and government representatives voted in favor, while business and labor interests against. You have to hand it to the Governor, he is a uniter: business and labor are united in opposition to these recommendations because, if implemented, they will severely and adversely affect energy costs, business investment and employment opportunity in Illinois.

While cap & trade programs and auto emissions standards -- if adopted in a truly reasonable and achievable approach -- are laudable ideas, the obvious problem is these recommendations (as presented by the group and championed by the Governor) would apply to Illinois only. Yet the key word in this important public policy debate is “global”.

Whatever you think of global climate change, most rational people would recognize the actions of one state won’t make a dent in global emissions in spite of the compliance burden and billions in costs this will cause Illinois’ employers to bear.

Carbon dioxide does not have a zip code. But economic leakage will undoubtedly occur if Illinois unilaterally chooses to regulate industry to the point that the cost of doing business leaves owners and investors with little choice but to pursue enterprises in a less costly, more business-friendly location. The consulting firm hired by the IEPA reported to the Advisory group that the results of an Illinois-only solution will bring no significant change in GHG emissions. Its conclusion was that electric generation and commerce will continue to occur … just not in Illinois. Other states will reap economic activity as trucking, electric generation or manufacturing shift investments while Illinois consumers would assume higher costs for no benefit.

Although advisory group members were forbidden from even whispering of federal efforts, let alone consider such initiatives, there are several significant federal efforts underway aimed at addressing climate change. Because Illinois is not an island, it’s obvious much greater impact on GHGs could be derived from nationwide and international efforts than from a patchwork approach pursued by a handful of states.

The US Climate Action Partnership (USCAP) is a group of businesses and environmental organizations supporting strong national legislation on greenhouse gas emissions. Their market-based approach includes a set of principles and recommendations addressing the need for a framework for policy change, and their first principle touches on the global impact of climate change.

The US Congress is considering several measures, including Senate Bill 2191 from Senators Warner and Lieberman addressing greenhouse gas emission reductions for the entire US. We elect federal lawmakers for good reason. Public policy issues like climate change warrant national and international debate and solutions.

As serious as the issue of climate change is, it is unfortunate this advisory group’s plan is an economic Trojan horse for Illinois. It is Governor Blagojevich’s latest venture in a long running pursuit of national issues that garner headlines but fail to yield real value for Illinois. Like these recommendations, previous initiatives to buy foreign drugs, import flu vaccine, provide universal healthcare, prohibit violent video games and impose a gross receipts tax on employers result in unnecessary, costly outlays of taxpayer dollars while simultaneously sending a message that is anti-business and anti-growth.

Sadly, the governor continues to demonstrate a lack of interest in real input or dialog with informed parties who have valuable perspectives to offer. Even if their viewpoint may be counter to his pre-determined objectives, the most valued advisors are not sycophants who are expected to simply tell you what you want to hear.

The Governor’s advisory group members are listed on the Illinois EPA’s web site. You can also find background on the issue, documents produced for and by the group and its sub-groups, and information on their meetings and conference calls, as well as their recommendations when they are formally released, online at http://wwwepa.state.il.us/air/climatechange/index.html.

 

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