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that far exceeds what we can afford if we learn we need to stabilize CO2 concentrations in the 350 to 550 ppm range. At first glance, these numbers may suggest we still have lots of time to study this issue but consider that to keep the next hundred years' emissions under 300 Gt we would need to cut today's global emissions immediately by more than 60% and keep them there while the world grows in population and affluence. Or we might pursue the cut more gradually but then we must achieve even deeper cuts later to stay within the same budget. While this example is for the 350 ppm option, the same dynamic exists for each of the higher stabilization targets: the longer we delay adoption of policies that limit business as usual growth in emissions, the deeper the cuts the planet must achieve to hit any stabilization target. And if we delay too long, each successive stabilization target becomes impossible to achieve.

Dr. James E. Edmonds of the Department of Energy's Pacific Northwest National Laboratory and colleagues have estimated least-abatement cost schedules for reducing emissions to meet these stabilization targets. He points out that these schedules require global emissions to drop below business as usual paths in the very near future. Here is a summary of this information as he presented it to the Senate Energy Committee on June 28, 2001:

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Year in which Global Emissions Must Break Today 2007 2013 2018 from Present Trends

2023

As can be seen, for the lower targets, the dates for achieving significant global emission reductions are upon us now and the dates for preserving even the higher targets are very close. To appreciate that these dates do not allow time for further delay in adopting policies, consider the sequence of events that must occur to actually succeed in reducing global emissions. Clear public policies must be debated and adopted, not just in the U.S. but in other countries too. The private sector must develop strategies for response to those policies. The strategies must be translated into specific investment decisions needed to carry out the strategies, most likely involving additional development work for certain technologies. The investment decisions must be followed with detailed engineering and planning work. And this work must be followed by deployment of lower-carbon technologies in the field on a sufficient scale to actually reduce global emissions below current forecasted increases. Thus, to reduce global emissions by dates like 2007-2020, we must start today with adoption of effective policies.

Stated another way, further delay in adopting policies to limit global warming pollution means we are discarding the options of stabilizing concentrations at levels closer to the lower end of the range of targets. I cannot prove today that stabilizing CO2 at 350 ppm is essential for our well-being. But I think it is self-evident that it is not responsible to eliminate this option without any assurance that we can live well with the resulting future. As the National Academy of Sciences panel noted in its report to President Bush, "risk increases with increases in both the rate and the magnitude of climate change." By committing ourselves to ever-higher CO2 concentrations, we are committing to higher rates and magnitudes of climate change for our descendants and ourselves.

Fortunately, there are no technical or economic impediments to adopting policies today that will restore U.S. leadership on fighting global warming and send important signals to the private sector and to other countries that the time for effective action has arrived. Congress has before it a number of major legislative initiatives that will address the principal sources of global warming pollution in the U.S. in a way that will stimulate the new technology that is essential to meeting the challenges of limiting these emissions

Near-term domestic policies to address global warming

A.

Comprehensive power plant clean-up legislation

NRDC supports comprehensive legislation to reduce all four major pollutants from electric generation-sulfur oxides, nitrogen oxides, mercury and carbon dioxide. Electric generation is responsible for 40% of total U.S. CO2 emissions. We have the technology to make significant reductions in CO2 from this sector though a combination of efficiency measures on the supply and the demand side, and through increased reliance on cleaner fuels. Enactment of a cap and trade program for CO2 from the electric sector would produce the needed market signal to all the players in the electric production and consumption sectors that there is value in reducing carbon emissions. The bipartisan bill, S. 556, the "Clean Power Act," sponsored by Senators Kerry, Lieberman, Collins, Jeffords and Snowe would accomplish this objective and NRDC strongly supports it.

Complementary policies to reduce emissions from electric generation include renewable portfolio standards proposed in the last Congress in S. 1369, to facilitate the deployment of renewable energy resources, a public benefits fund as proposed in last year's S. 1369 and this year's S. 597, to promote continued investments in demand side management programs and net metering provisions (as found in both bills), to promote clean and efficient distributed generation.

B.

Policies to Reduce Petroleum Dependence and Protect the Environment and Public Health

1.

Close the Light Truck Loophole and Raise Fuel Economy Standards to 40 Miles per Gallon

Incentives for advanced technology vehicles will be most effective if enacted in combination with updated fuel economy standards. This can be accomplished in two steps. First, congress should quickly eliminate the light truck loophole in the current fuel economy standards. The share of new vehicles that are classified as light trucks (SUVs, minivans, and pickups) has increased dramatically from 20 percent of sales when the CAFE law was first enacted in 1975 to nearly 50 percent of the market today. Yet the vast majority of vehicles currently regulated as light trucks are in fact used in exactly the same way as passenger cars. EPA recognized the need to eliminate the light truck loophole in its Tier II tailpipe standards beginning in 2004. Congress should follow this lead and eliminate the light truck loophole in fuel economy regulations in the same time frame. Congress should raise the overall fuel economy standard for the entire light vehicle fleet over a longer time period. A recent report by the Union of Concerned Scientists shows that the fleet average efficiency could be increased to 40 miles per gallon (mpg) by 2012 and 55 miles per gallon by 2020. The 40 mpg standard could be achieved through

incremental improvements to vehicles with conventional drive trains, although hybrid and fuel cell vehicles would likely contribute to achieving this efficiency level. The 55 mpg standard could be most easily achieved by applying hybrid technology throughout the vehicle fleet.'

Congress should also set standards for replacement tires. It is a little known fact that auto manufacturers use highly-efficient tires to comply with current CAFE requirements, but comparable tires are not available to the consumers as replacements. Congress should require replacement tires to meet the same specifications as those sold on new cars. This measure alone would save over 70% more oil than is likely to be found if drilling were permitted in the Arctic National Wildlife Refuge.

2.

Pass the CLEAR Act: Tax Incentives for Advanced Technology Vehicles and Alternative Fuels

The CLEAR Act (S. 760) provides a comprehensive set of performance-based tax incentives to accelerate the commercialization of advanced technology vehicles and alternative fuels. This bill is a major advance over previous vehicle tax credit proposals because it is the first proposal to link publicly-funded incentives directly to the public benefits provided by the vehicles that get the incentive, in this case the amount of petroleum and carbon dioxide displaced. This is accomplished by linking the amount of the tax credit it offers in part to the actual fuel economy of the qualifying vehicles. The bill also includes important provisions to ensure that public support only goes to truly advanced vehicles that reduce local air pollution as well as global warming pollution and petroleum consumption.

The policy advances incorporated into CLEAR reflect the collective advice of a unique coalition of environmental advocates and automakers. Public interest organizations that have joined NRDC in endorsing the CLEAR Act include the Union of Concerned Scientists, Environmental Defense, the American Council for an Energy-Efficient Economy, the Ecology Center of Ann Arbor, Michigan and the Michigan Environmental Council.

3. Establish Incentives to Promote Smart Growth Development Patterns

Gasoline use also can be reduced by directing real estate development away from urban sprawl and toward "smart growth." Smart-growth suburbs reduce the need to drive by 30 percent or more, cutting household expenditures on transportation.2 An important incentive for smart growth is to establish mortgage qualification rules that recognize the

Union of Concerned Scientists, Drilling in Detroit: Tapping Automaker Ingenuity to Build Safe and
Efficient Automobiles .(June 2001). Available from http://www.ucsusa.org/

David Goldstein, "Mortgages Can Remove the Incentive for Sprawl," Earthword: The Journal of

increased affordability of homes that have low transportation costs because they are located in areas with good access to public transportation.

4.

Modify the Ethanol Tax Credit to Make it Performance-Based

The largest incentive currently going to alternative fuels is the excise tax credit provided for ethanol. Unfortunately, the environmental benefits generated by this tax credit are limited because it does not currently incorporate performance criteria. Most ethanol is currently produced from corn and requires high levels of chemical and fossil fuel inputs that are almost as great as those for conventional gasoline over the full fuel cycle of production and use. The existing tax incentive for ethanol could be made much more effective by linking the amount of the credit to the net reduction in global warming pollution or fossil fuel consumption achieved by the ethanol producer. This would encourage ethanol producers to shift to less energy intensive feedstocks, such as agricultural wastes and perennial crops, and to improve the efficiency of their conversion processes.

C.

Benefits of a Comprehensive Policies to Promote Advanced Technology Vehicles and Alternative Fuels

The economic and environmental benefits of enacting the comprehensive set of policies described here would be profound. EPA estimates that the average light truck on the road today produces 164 pounds of smog-forming pollution (hydrocarbons plus nitrogen oxides) and 8.0 tons of global warming pollution in traveling 14,000 miles each year. This does not include upstream emissions associated with producing the fuel, which would add about 11 pounds of smog-forming pollution and 2 tons of global warming pollution, bring the totals to 175 pounds of smog-forming pollution and 10 tons of global warming pollution. Conventional new vehicles are substantially cleaner than this average with respect to smog-forming pollution, but have roughly the same fuel economy and therefore the same global warming pollution emissions as the vehicle existing vehicle it is likely to replace. For example, a vehicle meeting the National Low Emission Vehicle standard would emit only 12 pounds of smog-forming pollution from its tailpipe, but upstream emissions would still add 11 pounds, bringing its total impact to 23 pounds of smog-forming pollution and 10 tons of global warming pollution. In contrast, a hybrid vehicle qualifying for a $3000 tax credit under the CLEAR Act would emit less than 1 pound of smog-forming pollution from its tailpipe and would use only half as much fuel. As a result, its total impact would be only 6 pounds of smog-forming pollution and 5 tons of global warming pollution.

Aggregating from the vehicle level to the fleet level, the Union of Concerned Scientist (UCS) estimates that the combination of tax incentives and higher fuel economy standards advocated here would save 540 million barrels of oil in the year 2010, reduce upstream smog-forming pollution by 320 million pounds, and reduce global warming pollution by 273 million tons. By 2020 the savings would be even more dramatic: 1.8

billion barrels of oil, 1000 pounds of smog-forming pollution, and 890 million tons of global warming pollution. All of these benefits would be achieved while saving consumers billions of dollars: nearly $10 billion in 2010 and $28 billion in 2020 according to UCS.

D.

Sector

Legislation to Provide Energy-Efficiency Incentives for the Buildings

"The Energy-efficient Buildings Incentives Act" (S. 207), introduced by Sens. Robert Smith (R-N.H.) and Diane Feinstein (D-Calif.), would provide tax incentives for energy efficiency in buildings. Buildings are an often-overlooked source of energy waste. They consume over a third of U.S. energy use and account for about a third of total air pollution in the United States. S.207 would provide incentives for the construction of energy-efficient commercial buildings, schools, rental housing and new homes, cutting their energy needs by 30 percent to 50 percent. It also would provide tax incentives for the purchase of energy-efficient air conditioners, heating and cooling systems, and solar water heating and photovoltaic systems.

Energy use in buildings can be cut in half or better using cost-effective technologies that are available to those consumers that are willing to search them out. But in practice most of those technologies simply are not options for energy users, whether consumers or businesses, because they are too hard to find. Economic incentives can cause the entire chain of production and consumption, from the manufacturer to the contractor or vendor to the consumer, to accept new technologies rapidly. In the few cases where utility programs have been consistent enough across the country and long-lasting enough, new products have been introduced that have become or will become the most common product in the marketplace, with reductions in energy use of 30%-60%.

Examples include:

• Refrigerators, where, new products that are available this year consume less than a quarter of the energy of their smaller and less feature-laden counterparts 30 years ago. The last step forward, saving 30%, resulted from a coordinated incentive program, the Super Efficient Refrigerator Program (SERP), which was sponsored by utilities with the advice of the U.S. Environmental Protection Agency.

Clothes washers, where some 10% of the market now provides cleaner clothes at a reduction in energy use of 60% or more. This gain in efficiency resulted from a program organized by the Consortium for Energy Efficiency (CEE) and supported by Energy Star. New standards adopted by the Department of Energy - and supported by the manufacturers - will bring all of the market to this level by 2007.

Fluorescent lighting systems, where new technologies that also will be required by manufacturer-supported federal standards will reduce lighting energy

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