ARTICLE
Implementing Greenhouse Gas Emissions Caps: A Case Study of the Los Angeles Department of Water and Power
Ann E. Carlson* 
55 UCLA L. Rev. 1479

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Abstract

Our almost forty-year experience with landmark federal environmental statutes, demonstrates unequivocally that implementing grand and noble environmental goals is an arduous and difficult experience. California is now embarking on a similar project: implementing the country’s most ambitious greenhouse gas emissions limitations, including rolling back the state’s emissions to 1990 levels by 2020. The state’s leadership on climate change legislation deserves significant praise. But the hard work in actually achieving emissions limits is just beginning. In this Essay, Professor Ann Carlson provides a case study of the country’s largest municipally owned utility—the Los Angeles Department of Water and Power (DWP)—and the challenges it will face in holding its emissions to 1990 levels by 2020. The case study is particularly useful to anticipate challenges utilities across the country will face if the federal government also mandates greenhouse gas emissions reductions. The DWP’s energy mix, with its heavy reliance on coal, looks quite similar to the energy mix of the country as a whole (and quite different from the rest of California’s electricity market). The challenges are daunting. They include shifting rapidly to renewable energy sources in the face of labor pressures to have DWP own its own sources; building miles of transmission lines to bring the renewable energy to DWP’s customer base; repowering natural gas facilities while attempting to comply with stringent Clean Water Act requirements; and eliminating the utility’s reliance on coal over the next two decades. These efforts will raise complex environmental and other value clashes, pitting those concerned about jobs, water pollution, species protection, and aesthetic harms against a utility admirably committed to cutting its greenhouse gas emissions significantly. Whether and how we resolve these clashes remains an open and contested question.


* Professor of Law, UCLA School of Law, and Faculty Director, Emmett Center on Climate Change and the Environment.

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