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Hastings Environmental Law Journal

Abstract

Policy analysis primarily looks backward to solve problems of individual and public choice. Analysts often seek to derive and draw marginal curves from existing data to extrapolate observed relationships into the future. Indeed, the White House Council on Environmental Quality recently issued a proposed rule that would, among other things, codify the concepts underlying these tools for environmental matters, i.e., requiring the considered effects of a proposed action to be “reasonably foreseeable” and meet a “reasonably close causal relationship.” That proposal expresses a perspective with a long tradition, yet it presents a curious circumstance. Although marginal and statistical regression tools are among the most powerful methods for understanding past continuous change, their power and efficacy diminish when applied to discontinuous change, meaning disjointed or abrupt.

This article discusses the discontinuity problem that is inherent in reducing atmospheric greenhouse gas emissions (decarbonization). It suggests that combinatorics (i.e., mathematical analysis by counting and ordering) offers a useful methodology for evaluating that discontinuous change. Here, a simple counting approach (viz. Equivalent Substitution Analysis) considers, as two corresponding sets, the discrete number and combination of technological substitutions that are required for decarbonization. One implication of the analysis is that decarbonization need not be analyzed solely as a collective action problem. The article proceeds by exploring decarbonization conceptually and against archetypal modern analysis. The article concludes with a detailed case study of an electric utility, the nexus of decarbonization in the United States (“U.S.”).

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