Robert Sussman, former EPA Deputy Administrator under Bill Clinton, wrote an article last week that raised concerns with draft climate change legislation written by Reps. Dingell and Boucher. Sussman writes that “the absence of allowance auctioning in the cap-and-trade program and weak emission reduction targets for 2020” raises serious concerns, and that the bill should not be used as the starting point for legislation starting next year.

Despite raising these issues, Sussman also applauds Dingell and Boucher for a number of policies included in the bill. He likes the fact that the bill is economy wide, covers 87 percent of greenhouse gases, and sets good long-term goals for emissions levels. Sussman also believes that the bill contains strong energy efficiency programs and “uses the allowance allocation process both to stimulate low-carbon energy technologies and provide consumers relief from high energy prices.”

Sussman also addresses carbon capture and storage technology in his article. He says, “This combination of carrots and sticks [in the bill] is a step in the right direction, but the drivers for CCS deployment could be strengthened.” He states that, to meet certain goals for CCS,

CCS would have to be deployed for 74.5 percent of the country’s existing coal plant fleet, which now has a capacity of 336 gigawatts of electricity. Near-universal CCS retrofitting of the U.S. coal plant fleet is a desirable long-term outcome, but the odds of it happening in under 10 years are not high.

He concludes by saying that, while he thinks many aspects of the Dingell-Boucher legislation should be considered, a better starting point for legislation would be Rep. Markey’s HR 6186.