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The NAP should provide specific baseline and post-policy emission projections from 1990 through at least 2010.

The NAP should include a specific implementation plan including programmatic timetables and required budgets by agency.

The NAP should include an evaluation procedure for regularly assessing whether the U.S. is on track to achieving its stated emissions targets, with provisions for adopting additional measures (e.g., increasing energy tax rates) if emissions are higher than anticipated.

Additional Measures Needed to Cap Emissions

The most recent DOE/EIA reference case projection (Annual Energy Outlook 1993) indicates that carbon dioxide emissions will increase from 1340 million metric tons of carbon (MMTC) in 1990 to 1500 MMTC in 2000. Thus an emission reduction relative to the reference case of 160 MMTC by 2000 is needed to return emissions to 1990 levels by that date.

If properly implemented, many of the measures in the existing action plan could significantly reduce greenhouse gas emissions from projected levels. In particular, EPA's voluntary public-private partnerships, such as Green Lights, Energy Star Computers, and Golden Carrot Refrigerators, have been highly successful to date. These programs, however, remain woefully underfunded relative to what would be needed to achieve the market penetration targets in the NAP. If adequate funding is provided, the combination of EPA's programs, effective implementation of the Energy Policy Act of 1992, and ongoing state-level and utility efficiency programs might reduce CO2 emissions in 2000 by approximately 100 MMTC relative to reference case levels.

The policies enumerated below complement or augment those in the existing NAP. Estimated emission reductions are given for the year 2000 relative to reference case levels.' The total additional emission reduction potential comes to 80-110 MMTC, assuming that all savings are additive. This would give total emission reductions of 180-210 MMTC, significantly more than the 160 MMTC needed to achieve 1990 levels in 2000. For most of these programs emission reductions would be substantially larger in later years.

In practice emission reductions from each program are not simply additive. There would be overlap in projected savings in some cases and synergisms in others. It is clear, nonetheless, that an effective strategy to cap and reduce carbon dioxide emissions can be devised and implemented.'

These estimates are largely based on: Alliance to Save Energy, American Council for an Energy-Efficient Economy, Natural Resources Defense Council, and Union of Concerned Scientists, America's Energy Choices: Investing in a Strong Economy and a Clean Environment. (Union of Concerned Scientists, Cambridge, 1991.)

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A model capable of following the capital stock of the most important energy using buildings and equipment is needed to verify this result. Such a model was employed in the America's Energy Choices study cited above. The supply-demand scenarios developed in that study demonstrate that this conclusion is indeed robust.

The importance of timing can not be over-stressed, however. Much valuable time has already been lost since the 1988 Toronto Conference first called for a 20% reduction in emissions. The turn of the century is now just seven years off. Each program outlined here will take some time to get off the ground and additional time to achieve significant emission reductions as equipment turns over. The Administration and Congress must move quickly to adopt and implement a real National Action Plan to arrest global warming.

APPENDIX. ADDITIONAL MEASURES FOR NATIONAL ACTION PLAN

ENERGY/POLLUTION TAX

20-30 MMTC

The BTU tax proposed as part of the Clinton-Gore economic package is projected to reduce emissions by 1.5-2%. This reduction would come in part from the direct effects of the tax on its own, but perhaps of equal importance, it would allow the other measures to penetrate markets more effectively. The tax rates could, of course, be increased if necessary to achieve a particular emission target.

INCREASE AUTOMOBILE EFFICIENCY & REDUCE TRAVEL

30-50 MMTC

Substantial carbon reductions can be achieved in the transportation sector by improving vehicle efficiency and reducing vehicle miles travelled (VMT).

Options to slow the growth of VMT include increased investment in mass transit and introduction of transportation demand management measures such as pricing strategies (tolls and parking fees), removal of tax subsidies for parking, integrated transportation and land-use planning, and zoning reform to discourage sprawl. (Existing transportation, energy, and air quality legislation gives new impetus to these types of measures) Introduction, by states, of programs to collect insurance payments through a surcharge on fuel consumption (known as "Pay As You Drive" insurance), would help to further dampen VMT growth.

Improvement in vehicle efficiency can achieved by increased CAFE standards, complemented by a variety of market mechanisms (such as fee and rebates systems to reward consumers or manufacturers for the purchase or sale of more efficient vehicles). Because increased standards require roughly a five-year lead time, immediate implementation of an aggressive market incentives programs is necessary to provide significant carbon reductions by 2000. (Even in the current new vehicle fleet, consumers could shift to substantially more efficient cars. The average fuel economy of the most efficient models in each new car class is already close to 35 mpg)

Besides market incentives and raised CAFE standards, a public-private partnership to develop "super" clean and efficient vehicle, coupled with fleet procurement programs to develop markets for these vehicles, as recently announced as part of the Clinton-Gore

Technology Policy, could achieve some added near-term benefits and lay the foundation for long-term carbon reductions.

The high end of our estimate for carbon reductions (50 MMT by 2000) can be achieved through a combination of reducing VMT by 5% to 8% below the projected year 2000 level and by increasing new light-duty vehicle (car and truck) efficiency by an additional 17% over the 10% improvement assumed in the baseline.

RESIDENTIAL AND COMMERCIAL BUILDINGS

Federal Buildings

5 MMTC

The National Energy Policy Act of 1992 calls for a 20% reduction in the energy consumption of federal buildings by the year 2000. If this goal were actually achieved, it would produce annual carbon reductions of about 5 MMT by 2000.

Energy Efficient Mortgages

5 MMTC

A uniform Energy Efficient Mortgage (EEM) program could upgrade the energy efficiency of at least 1 million homes per year by 1996 and a total of 6 million homes by 2000. Implementation of an effective EEM program requires: uniform and streamlined documents and procedures for all mortgage underwriters (Fannie Mae, Freddie Mac, HUD, VA); incentives for home buyers, lenders, and investors; coordination with utility Demand Side Management (DSM) programs; training for realtors and lenders; and aggressive marketing. Energy savings equal to 40% of national average residential consumption in each of 6 million homes could be achieved by 2000, reducing emissions by 5 MMTC.

Advanced Heat Pumps

5 ММТС

Both the penetration and average energy savings can be increased compared to what is currently in the Action Plan, increasing savings by 5 MMTC.

Green Thermostats

5 MMTC

The installed costs of computerized automatic set-back thermostats could be reduced dramatically through aggressive mass production and marketing. Savings of 15% in 30% of the housing stock would cut emissions by 5 MMTC.

SHIFT TOWARD LOW CARBON FUELS

10 MMTC

In addition to the energy tax discussed above, there are other in portant measures that could be taken to encourage a shift toward natural gas and renewable energy sources. These include removing barriers to the use of natural gas (at both the state and federal level), aggregating a market for renewable energy technologies to encourage economies of scale, and expanding targeted tax incentives for renewable energy supply.

WWF

Testimony of

Mr. T.J. Glauthier

Director, Energy & Climate Change Policy
World Wildlife Fund

Subcommittee on Economic Policy, Trade and Environment
House Committee on Foreign Affairs

March 1, 1993

Hearing on

"Global Climate Change: Adequacy of the National Action Plan"

I am T.J. Glauthier, Director of the Energy and Climate Change program at the World Wildlife Fund ('WWF"). I also coordinate the policy work of WWF_organizations throughout the world on energy and technology transfer related to climate change.

World Wildlife Fund is the U.S. affiliate of the international WWF family. WWF is the world's largest private conservation orgnization, with over 1.2 million members here in the U.S. and over 4 million members worldwide. We have national organizations or representatives in nearly 40 countries around the world, including developing countries in Asia, Africa, and Latin America. Since its founding in 1961, WWF-US has supported over 2,000 projects in 116 countries.

I also wish to identify myself and my organization as active participants in the Climate Action Network ("CAN"), a coalition of non-govemmental organizations working on the climate change issue here in the U.S. and around the world. The members of CAN have reviewed the U.S. National Action Plan in detail and are preparing extensive comments that will be filed shortly with the government as part of the public comment

process. While I cannot speak specifically for all of the members of CAN, my comments today, together with those of Dan Lashof and Irving Mintzer, who are also active in CAN, will give you a sense of the general reaction of the NGO community to the U.S. Action Plan. It is particularly timely that you choose this time to address the U.S. National Action Plan that is called for under the Framework Convention on Climate Change, which the United States ratified in October 1992. This is the time to decide how to proceed with the Action Plan, since the new Clinton Administration is now getting its staff in place, the comment period on the draft Action Plan of the Bush Administration draws to a close a week from today, and the next meeting of the parties to the Convention occuring in two weeks.

There are four key recommendations that I would like to make today with reference to the draft National Action Plan for Global Climate Change, published in December 1992: The draft Plan needs a 180° shift in orientation, to become a strategic, document that sets goals and drives actions within the Administration.

The "Action Plan" needs more actions. The current draft does not meet the test of a good faith plan, because it does not achieve the emissions reduction goal of the treaty.

The technology transfer section of the draft Plan should also be changed to be "strategic". It should contain specific goals that will drive the program, and actions to assist the U.S. private sector in undertaking projects abroad.

The revised U.S. National Action Plan is needed soon-the Administration should put it on a "fast track" as the pacing activity for our nation's climate change program. We should commit to publishing it by August 1993 and call on other developed countries to do likewise.

The Subcommittee raised the question of whether the draft U.S. Plan should be revised or completely scrapped in favor of a fresh start. This question is largely a matter of semantics. In either case, the thinking and public comment that has been collected is

relevant and some sections of the draft will be useful, such as descriptions of program

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