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Policymaking Under Pressure: The Perils of Incremental Responses to Climate Change

September 17, 2008

PHILADELPHIA (Sept. 17, 2008) -- Piecemeal approaches to fighting global warming--like the Regional Greenhouse Gas Initiative scheduled to go online next week--may be worse than taking no action at all, says University of Pennsylvania Law School Professor Cary Coglianese, who is director of the Penn Program on Regulation.


"There is good reason to doubt the appropriateness of the current ad hoc, state and local responses to climate change," Coglianese says. "At their most benign, incremental reforms will have little or no effect on climate change. At the worst, tighter restrictions in one area may lead to unintentional increases in pollutants in a neighboring area with less stringent or non-existent regulations."


The Regional Greenhouse Gas Initiative (RGGI) unites the efforts of 10 northeastern states--Maine, New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, Delaware, New York, New Jersey, and Maryland--to cap emissions for 233 power plants and charge utilities for the carbon dioxide that the plants emit.


Taking small steps based on accessible knowledge, or incrementalism, allows experimentation and insurance against large scale policy disaster, Coglianese acknowledges. But some so-called "green" alternatives can exacerbate climate change problems or create other public health problems. The promotion of biofuels, for example, led to clear-cutting rainforests; the wide use of compact fluorescent light bulbs creates greater potential for environmental contamination than do incandescent lighting.


In fact, he argues, disjointed experimentation can entrench special interests and lull the public into thinking progress is being made, making comprehensive policymaking more challenging to achieve.


"It appears better to wait to develop a comprehensive and effective climate change policy rather than to continue succumbing to pressure to adopt incremental options that will ultimately prove ineffective or otherwise problematic," he says.


It would be more effective to control pollutants upstream via national, or better yet, global, cap-and-trade policies that cover all greenhouse gases allowing energy companies to trade and bank fuel allowances. Such caps can be phased in over time to allow for planning and encourage innovation


"Climate change requires large-scale, comprehensive policy," he says.

A research paper on this topic by Professor Coglianese and 2008 Penn Law graduate Jocelyn D'Ambrosio can be found at