An analysis released earlier this month by the Rhodium Group, a nonpartisan data-analytics firm, found that the U.S. can still hit its 2030 environmental target if it takes a three-pronged approach to combating climate change: legislation from Congress to enact $300 billion in clean energy and electric vehicle tax credits, executive actions to curb pollution from the power sector, and state-level action to pass green-friendly energy laws. Should the U.S. fail to enact any new climate policies, greenhouse gas emissions would fall 1.7 to 2.3 billion tons short of what is needed to reach the goal outlined in the Paris Agreement.

“It is challenging without the CEPP, but it is possible,” said Ben King, a senior analyst at Rhodium and author of the report. “It requires that everything goes right.”

Speaking on Monday, Biden was optimistic that Democrats could reach a spending deal before the climate summit in Glasgow, which would bring the clean energy and EV tax credits closer to reality. And King said that convincing progressive states to enact clean energy laws is one of the White House’s “more achievable” ambitions. Indeed, 29 states already have their own versions of the clean electricity commitments that Biden wanted to make federally—and states like California have even more far-reaching standards. 

The key, according to King, will be for Biden to use executive action. That’s the only way to get, for example, the Environmental Protection Agency to implement new source performance standards requiring new fossil fuel-fired electric generators to have 90% of their power stations equipped with carbon capture technology starting in 2022. By enforcing that standard, Biden would, as Vox writer David Roberts pointed out last year, effectively nullify 99 percent of new natural gas plant construction. (Such action has been floated in policy circles before: It was actually a centerpiece of Mike Bloomberg’s presidential platform in 2020.) 

To be sure, executive actions carry their own risk, namely that they can be challenged in court, and could easily be rolled back by a future president. (The latter is exactly what happened with the Clean Power Plan: The Obama-era EPA policy was rescinded by Trump, only to be restored a few years later by Biden.) “There’s questions around EPA regulations of whether they can be structured to be ambitious enough, whether they withstand judicial scrutiny. There is a risk if a new administration who is less favorable to climate comes in,” said King.  

In addition, some critics say a three-pronged plan also ignores another key climate mitigation technique: carbon pricing. “If the US were to follow the example of the EU and set carbon pricing as the centerpiece of its climate mitigation program, given the sizes of the U.S. and the EU markets, it would be more likely that other countries would follow,” said Antonio Bento, an environmental policy professor at the University of Southern California. “If the US and the EU were to implement carbon pricing and a carbon border adjustment, other countries would have to pay this border fee in order to sell their products in the US and the EU markets. Such a move would likely force others to adopt similar policies.”Bento argues that, given the enormity of the stakes, the Biden administration needs to use every tool at its disposal. “It is absolutely critical that President Biden has a plan for meeting his target emissions reductions by 2030 and for the US to achieve climate neutrality by 2050, and that this plan is communicated clear and loud to the international community,” he said.

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