Highlights from A&WMA’s Conference: “Addressing Climate Change”

Last week I attended A&WMA Conference “Addressing Climate Change: Emerging Policies, Strategies, & Technological Solutions,” which was attended by about 100 participants, including experienced regulators, utility executives, industry representatives, academics, and consultants from the U.S., Canada, and Mexico. As a speaker, I contributed to the panel entitled “Evolving Climate Change Standards,” which summarized the latest IPCC climate data, current efforts to develop international standards for climate change adaptation, and ways for agencies to implement a risk-based approach to adaptation efforts. (Check out the full presentation here.)


Most of the plenary sessions at the event addressed EPA’s new Clean Power Plan. The proposed plan released last year was considered by most as unworkable (at one point called “a train wreck”). EPA made an unprecedented effort in listening to stakeholders and systematically addressing their concerns. The final rule released in August is considered by almost everyone as a major improvement. Although not perfect, most feel it is workable and much fairer. Major improvements include:

  • Significant extensions to planning and implementation, with a much more phased-in approach. Initial plans are due in 2016 with the ability to file for a two-year extension. The actual program implementation does not start until 2020, with no real enforcement until 2022. The implementation will be broken into three phases between 2020 through 2030, allowing for a majority of coal-based power generation to be economically phased out.
  • More of an emphasis on a mass-based approach vs. rate-based approach. This will be much more practical and simpler to implement.
  • Added liabilities protections, giving cover for program experimentation.
  • Fairer emission reduction allocations
  • Ability of individual facilities to be “trading ready” and for individual power plants to use out-of-state reductions (in the form of credits or allowances depending on the plan type) to achieve required CO2 reductions without the need for up-front interstate agreements.
  • Ability of states to leverage regional infrastructure (i.e., grid) improvements to cost-optimize individual programs.

Even with these improvements, some believe the new rule essentially forces states to phase out coal and switch to natural gas and—eventually—alternative energy and/or nuclear. There are major incentives, however, for demand side management (e.g., energy efficiency improvements). Ironically, this could be harmful to some low-carbon products such as nuclear energy, which cannot economically adjust to major drops in base-load demand.


The final plan can be very complex (4,000+ pages) depending on which approach states choose, and will require multi-billion dollar buildouts. Nonetheless, states will have a lot of flexibility over a much longer time frame. Some of the speakers voiced a long-standing concern that the Clean Air Act was never designed to manage greenhouse gas emissions. One small provision of the law was used to develop a very large and far reaching program. Since the U.S. Congress has failed to develop any regulatory alternatives, these experts believe the EPA had no other regulatory option to address climate change.


In addition, A&WMA’s lunchtime keynote speaker—Daniel Kreeger, Executive Director of the Association of Climate Change Officers (ACCO)—spoke of ACCO’s development of curriculum for various professions including civil servants (G15+). Under Executive Order 13693, any civil servant with at a G15 level or higher must have training in climate change fundamentals that can be applied to their government function and responsibilities. ACCO is working with the U.S. Department of Energy to provide such training and is gearing up to provide accreditation to organizations interested in providing certification training that could be customized for a given government organization.


Overall, the event provided a venue for experts in the areas of climate change to share the latest regulatory developments and highlight key technological advancements across North America, and we appreciate the opportunity to contribute to the discussion. View First Environment’s complete presentation, “Climate Change Today: The Latest Data on Global Warming and International Standards Development”.


Phil Ludvigsen, PhD

Senior Associate

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Phil is a senior level business director experienced in climate change and carbon consulting services, including the development of greenhouse gas emission reports, assessment of carbon accounting systems/controls, emission baseline reductions, verification of carbon inventories and offsets, and environmental financing approaches such as green bonds. He has a proven track record of climate program development with a successful history of directing technical and financial aspects of multi-million dollar projects. Notably, Phil helped manage a $25 million strategic investment fund for American Reinsurance (now part of Munich American Reinsurance) focused on strategic environmental, health, and social loss prevention as well as cost control. In addition, he has signed off as lead greenhouse gas verifier on nearly six megatons in carbon emissions reductions under the U.S. EPA Climate Leaders program to ISO 14064-3 standards. He has also verified more than 100 facility inventories and reduction projects throughout U.S. and Canada to ISO 14064 standards, totaling more than 10 megatons of CO2e emissions. With regard to environmental financing, Phil co-developed environmental, social, and governance due diligence work stream frameworks for some of the largest pension funds in North America. Notably, he was also the first Certified Responsible Investment Professional in North America certified via the Responsible Investment Association and recognized by Investment Industry Association of Canada. Phil also sits on the Climate Bond Standards verification work group and has co-authored thought leadership on the area of Green Bonds.