The WCI plan could impose significant new costs on consumers and retard job creation
in the Western U.S. over the coming decade while delivering no scientifically measurable
benefit in terms of reduced global climate temperatures as far out as the year 2100.
This “benefit” calculation is based entirely on the scientific findings, assumptions
and formulas of the United Nations’ Intergovernmental Panel on Climate Change.2
The WCI plan is based on an economic model which uses assumptions that, if implemented
as policy, would largely preclude the installation of virtually all new electric
generation capacity in the region except for highly intermittent wind and solar resources.
The WCI plan’s economic model does not take into account the fact that additional
hydropower, nuclear and advanced fossil baseload power plants could be deployed,
almost immediately and prior to 2020, that can meet expected growth in electricity
demand while dramatically reducing GHG emissions.
If the WCI economic model’s assumptions reflect actual policy recommendations by
Western governors, it sends a signal to industry and the investment community that
will almost certainly chill the very investment in low-carbon generation and carbon
sequestration (CCS) technologies that nearly all Western governors desire.
If the WCI economic model’s assumptions are implemented as policy, the plan could
further weaken the West’s already over-burdened high voltage transmission grid. Reserve
capacity margins in the Western Electricity Coordinating Council (WECC) are already
expected to drop below the minimum recommended levels as early as the winter of 2009.
Rapid introduction of massive amounts of highly intermittent generation from large
wind farms, as envisioned by the WCI plan, could easily destabilize the West’s grid
if appropriate technology upgrades are not made quickly enough.
The WCI plan could increase energy costs to consumers and, thus, disproportionately
harm low-income and minority families. In essence, it may unintentionally have the
effect of a discriminatory tax based on economic status and race.
The WCI’s plan to establish and monitor emissions caps would require the establishment
of a large and powerful new government bureaucracy. This could trigger the type of
influence-peddling and system “gaming” that has plagued European GHG mitigation regimes.
The laws, regulations, mandates and bureaucracy the WCI is proposing go so far as
to give WCI climate officials authority over even private
companies’ organization and reorganization functions.