So the Clean Power Plan is out.  It’s difficult to be pithy about such a big, sprawling, mess, other than to say that it’s probably about as good as it could be, though that may not be enough.  Here are a few items that have caught my eye so far:

• Although the initial deadlines have been eased, the goal of 32% reduction over 2005 emissions by 2030 is a slight increase over the 30% in the draft.

• The CPP appears to have deemphasized natural gas in favor of renewables. The plan assumes 28% of generation will be renewable by 2030, rather than the 22% assumed in the draft rule.

• Building Block 4 – energy efficiency programs – is no more. EPA seems to have concluded that such programs are just too far outside the fence line to survive judicial review.  Whether this will be enough to get five Supreme Court votes in favor won’t be known before the end of the 2016-17 term, at the earliest.  I will note now that Building Block 4 is an obvious casualty of Congress’s unwillingness to legislate, since it’s pretty clear that energy efficiency is one of the most cost-effective ways to reduce carbon emissions.

• EPA is poking a stick in the eye of states that are “just saying no” to the CPP. The draft Federal Implementation Plan will likely include a cap-and-trade component, which is anathema to these states.  God forbid the states should be forced to use the most cost-effective, market-friendly, approach towards compliance.

In short, ironies abound.  Notwithstanding the Pope’s Encyclical, it’s nuts to try to undertake something as massive as shifting our economy away from fossil fuels without using market-based approaches.  Someday this madness will end.  Until then, we have the Clean Power Plan.