Comments on the EPA’s Clean Power Plan reveal both consensus and partisan divide

A new paper by Philip Wallach and Curtlyn Kramer looks directly at the entities responsible for implementing the EPA’s new Clean Power Plan (CPP)—the states.

Under the CPP, state governments are responsible for developing implementation strategies to meet emissions targets which the EPA sets. As such, state environmental agencies will play a key role in the success or failure of this new regulation. To get a handle on how states feel about the Clean Power Plan, Wallach and Kramer analyze comments submitted to the EPA from each state’s environmental agency (excluding Delaware and Utah, whose environmental agencies did not submit comments.)

This survey reveals an interesting pattern: on some issues, the comments split clearly along partisan lines (with states with Republican governors opposing the plan, and those with Democratic governors supportive), while other concerns were shared by states with governors of both parties.

There are three main issues for which concern was shared by both red and blue states: the fairness of the plan, the impact of CPP on grid reliability, and whether the plan’s many goals were attainable. As demonstrated by the map below, concerns about goal attainability shared the most bipartisan support. Three-quarters of state environmental agencies argued that at least one of the CPP goals could not be met, representing a majority of red (24 of 28) and blue (12 of 20) states. By contrast, the arguments that the Clean Power Plan is illegal, and the argument that is should be abandoned by the EPA, were made almost exclusively by states with Republican governors.


Ultimately, this study reveals two things. First, to characterize the states’ reception of the EPA’s proposed plan as political would be a vast oversimplification. While some aspects of the comments do suggest a partisan split, there are many concerns that are shared by governors across party lines. Second, designing a rule that is both environmentally and politically workable is no easy task for the EPA—as the authors note, the 4.3 million comments the plan received suggest a challenging road ahead for the final Clean Power Plan rule.

Read the full paper here.