WWF Testimony of Mr. T.J. Glauthier Director, Energy & Climate Change Policy World Wildlife Fund Subcommittee on Economic Policy, Trade and Environment 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 intemational 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 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 elements and research plans. However, the revisions that are needed are so extensive that the final version should be substantially different from the draft. I will expand briefly upon each of these recommendations, and will be happy to explain our thinking further in response to questions. (1) The draft Plan needs a 180° shift in orientation, to become a strategic document that sets goals and drives actions within the Administration. The draft Plan is not goaldirected. It is merely a compendium of programs and actions that are being undertaken anyhow for other reasons, and happen to help reduce greenhouse gas emissions. This Plan should be a strategic document. It should be the statement of strategy for our nation's climate action program. As such, it needs to set forth goals, priorities, and program directions that are instructive to other countries and useful on a day-to-day basis here in our own country in making research, policy, and resource decisions. Our final Plan should embrace the objective of the Convention and make a clear, explicit commitment to meeting the target of returning greenhouse gas emissions to their 1990 levels by the year 2000. Then, the body of the document should spell out in detail our strategy for achieving that. Our Plan should also include a commitment to monitoring our progress and adding additional measures to the Plan or increasing their pace, if subsequent information shows that the actions we've laid out are not adequate to meet the 2000 target. in making the Plan a goal-driven document, we recommend that a substantial amount of restructuring be done as well. The current draft dilutes the attention on mitigation actions, which should be the primary focus of our "Action Plan". It places that chapter in the second half of the book, after lengthy sections on the special circumstances of our country (namely, why we have so much difficulty reducing emissions) and on adaptation actions (how we can learn to live with climate change rather than stop it). In fact, together these chapters are twice as long as the chapter on mitigation actions, which should be the principal focus of the Plan. In revising the Plan, we recommend shortening these background sections drastically and increasing the emphasis that is placed on the actions that the U.S. is, or will be, taking to reduce greenhouse gas emissions to mitigate this problem. (2) 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 estimates presented in the draft show that greenhouse gas emissions under the Plan will still be 1.4 to 8 percent above 1990 levels in the year 2000. The treaty is quite clear that at least our national plans should "aim at" retuming emissions to their 1990 levels by the end of the present decade. To be a good faith effort, any Plan must at least project meeting that target. In fact, using the numbers in the draft, it is possible that the steps in the Action Plan will only go halfway toward the 2000 target! In addition, I understand that a number of the technical assumptions underlying these calculations are optimistic and may overstate the emissions reductions that will actually be achieved by the listed actions in the Plan. In particular, there are questions regarding whether the market penetration rates projected for new "green" technologies are achievable, given the level of resources and regulatory support anticipated for them. If the draft Plan's estimates are derived from a "rosy scenario", then the situation in the year 2000 may be much worse than we think, with an even greater need for additional emissions reductions. Another concem involves the way the U.S. draft Plan combines individual greenhouse gases into overall "carbon equivalents", in order to report a single, overall result. Unfortunately, while that is simpler to report, it is not consistent with WWF's understanding of the country's obligations under the treaty. Article 4.2(b) requires each developed country to report "...detailed information on its policies and measures as well as on its resulting projected anthropogenic emissions by sources and removals by sinks of greenhouse gases not controlled by the Montreal Protocol..." (emphasis added). WWF's reading of that requirement is that each country must report its projected emissions and removals separately, and to do so gas by gas. The draft, therefore, needs revision to disaggregate "net" emissions figures and data presented in carbon equivalents. Clearly, what is needed by the Clinton Administration is a credible package of programs and actions that technical experts agree will be sufficient to achieve our national goal under the treaty. That will require adding more measures now, and including a commitment to monitor results and add additional measures later if that is needed. Some of the additions will be straightforward. These are the actions in the President's economic proposal that will also have the benefit of reducing energy usage or other greenhouse gas activities. The Plan needs to contain quantified estimates of the emissions reductions that will occur as a result of steps such as: the energy tax. funding for mass transit, increased funding for EPA's "green" programs, such as "Green Lights", federal fleet conversions to alternative fuels, federa! facility improvements to increase energy efficiency, and support of technology and energy efficiency development programs. Other additions may require separate consideration. For example, this Administration could be more aggressive in implementing the energy efficiency and other provisions of the Energy Policy Act, passed last October, and then could take credit for such changes. If still further emissions reductions are needed, I would look for additional actions related to transportation, especially automobile fuel efficiency. 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