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(Note: This update was presented by WCI Partner jurisdictions on the August 20, 2009, call with stakeholders)
WCI Partner jurisdictions are continuing to work towards their objective of putting the WCI program in place to start on January 1, 2012. Toward that end, Partners are working on the materials in the 2009-2010 work plan (released last February), focusing primarily at this point on white papers that lay out issues and options. Recently released materials include:
The WCI Partners encourage stakeholder review and comment on these papers.
Developing the Program Design
WCI Partners are also continuing to develop the program design. Two recent milestones are:
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WCI Partners have released two RFPs to support program development:
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The WCI Partners have also initiated a study of leakage potential for the electricity system in the eastern Canadian provinces.
WCI Priorities in Light of Federal Activities in Canada and the U.S.
WCI Partners are mindful of the developments in both the Canadian and United States national governments. The WCI program design recommendations were developed to stand-alone as a regional program, to be a model for national action, to be integrated into national programs, or be implemented in conjunction with programs that might ultimately emerge from the federal governments of Canada and the United States. WCI Partners are working to influence the federal debate in several ways.
Comments on Federal Activities:
WCI Partners have commented and are continuing to comment on federal activities in both Canada and the U.S.:
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On June 9, WCI submitted oral and written comments on the U.S. EPA proposed mandatory reporting rule.
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On June 23, WCI submitted written comments on the Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act.
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On August 13, WCI submitted written comments on the Canadian Offsets System draft documents: Program Rules and Guidance for Project Proponents and Program Rules for Verification and Guidance for Verification Bodies.
Partners are working on comments to the U.S. Senate for its deliberations on the pending energy and climate bill. Regional Collaboration: As discussed at the Partner meeting in Portland in July, WCI Partner jurisdictions have initiated discussions with the other two regional programs in North America: the Regional Greenhouse Gas Initiative (RGGI) and the Midwestern Greenhouse Gas Reduction Accord. The three regions are proposing to collaborate in key areas, which will expand the footprint of each of the regional program designs, particularly in the area of offsets. Additionally, this collaboration helps influence developments in the national programs.
Development of a Mandatory Reporting Program: The WCI Partner jurisdictions also recognize that an initial point of intersection between federal efforts in the U.S. and the WCI program is the mandatory reporting program. On July 16, the WCI Partners released their final Essential Requirements for Mandatory Reporting. These Essential Requirements are needed to ensure a rigorous and consistent set of measurements, calculations, and reporting across the WCI Partner jurisdictions to support the cap-and-trade program.
The WCI Partner jurisdictions have advocated that U.S. EPA adopt these Essential Requirements. However, based on the draft reporting rules that EPA proposed for public comment, the WCI expects that the final U.S. EPA reporting rule will deviate in some respects from the WCI Essential Requirements. Consequently, WCI expects to harmonize some aspects of the WCI Essential Requirements with U.S. federal requirements once the EPA rules are final. The WCI is committed to doing so as quickly as possible after the EPA rules are final, and is equally committed to preventing double reporting burdens for entities that would potentially be required to report to both a state and U.S. EPA. The WCI expects that the states and U.S. EPA will share reporting data to support the needs of both the state and federal programs, and to ensure that reporters in the WCI states do not have an undue extra burden.
There are some aspects of reporting rules in WCI Partner jurisdictions that will be different from U.S. EPA rules, such as the threshold for reporting. Similarly, there are some states with different statutory requirements that will be reflected in their reporting programs. WCI asks that stakeholders recognize that it will take some time to work through achieving consistency between the individual state reporting rules, WCI Essential Requirements and U.S. EPA reporting rules. WCI is committed to doing this as quickly as possible.
Similarly in Canada, there is a dialogue underway between the four WCI provinces and the Canadian federal government to inform them about the WCI Essential Requirements. Discussions to date have stressed the need to ensure a rigorous and consistent set of measurements, calculations, and reporting to support a cap-and-trade program across the WCI Partner jurisdictions that can be linked to broader North American and international systems. As a first step, work is underway to develop a “one-window” reporting system to avoid duplication and WCI expects to achieve significant progress on that this fall.
Focusing Work to Influence the National Program:
WCI Partners are focusing current work on those areas with a high potential to influence the national programs. These areas include:
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Offsets, including the quantity and quality of offsets included in the program;
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Competitiveness Analysis, focusing on approaches for identifying risk of leakage and program design options to address the risks; and
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Complementary Policies, recognizing that states and provinces have been and will continue to be leaders in areas essential to a comprehensive climate change program.
In each of these areas, WCI work is timely and important for the national debate.
Reminders and Upcoming Events
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