At the core of Obama's plan to control greenhouse gas emissions from more than 1,000 power plants is a strategy resembling that of a presidential campaign in search of electoral votes.
The administration wants to get enough states on board to color the map mostly low-carbon green, instead of coal black.
To that end, it has designed a policy that seems intended to isolate the fiercest pockets of resistance, winning over as many fence-sitting states as possible.
That would make it harder for his opponents to paint this regulation of carbon dioxide under the Clean Air Act as a heavy-handed federal intrusion.
"It is going to be important to have a critical mass of states being supportive," said Travis Madsen, a global warming campaigner at Environment America, a federation of state-based advocacy groups. "If too many states decide they will not cooperate, it's hard to say what might happen. The more states cooperate or act supportively, the more likely we will succeed."
The greenest states would be California and most of those in the Northeast. With their cap-and-trade markets already up and running, these are the poster children for the highly flexible regulatory approach the EPA is pushing.
Leaning their way are states like Oregon and Washington, which are already planning to join forces with California (and British Columbia) in a regional alliance of the kind the EPA is encouraging.
Even states like Pennsylvania or Ohio might not balk if, together with their big power companies, they can figure out an advantageous path. A Kansas or an Iowa, where wind power is pushing ahead, or a place like sunny Nevada, where solar is making strides, could take on a greener tinge.
The blackest states would be places like West Virginia, Kentucky, North Dakota and Wyoming, where dependence on coal is highest, alternatives are fewer and political opposition is red hot.
With coal-state members of Congress threatening to repeal the rule—plus a dozen or so legislatures passing resolutions to resist it and coal-state attorneys general threatening to sue—it might seem hard to penetrate enough states to gain momentum.
But it's hardly impossible.
Some of these states have already been achieving impressive results in reducing carbon emissions—not just through a shift to natural gas, but also through renewable sources of power. According to a new report from the American Wind Energy Association the top ten states where wind is replacing carbon energy are Texas, Illinois, California, Colorado, Iowa, Missouri, Oklahoma, Wisconsin, Minnesota and Wyoming.
Some analysts looking closely at the intricate approach the EPA is proposing say the regulation's targets are neither overly ambitious nor unduly burdensome.
"From what our initial analysis shows, the targets EPA has set out will be very much achievable," said Michael Obeiter of the World Resources Institute. "There are states that can achieve the 2030 targets a full decade earlier."
Still, as Bloomberg New Energy Finance said in a new report, "the variation among states is stark: some states face substantially stiffer reduction targets than others."
That's because the EPA did not set a one-size-fits-all flat rate for the cuts each state is supposed to make.
Instead, it reviewed the carbon intensity of each state's electric supplies—the statewide emissions per unit of power produced in 2012—and tried to figure out how big a reduction would be reasonable to demand by 2030, considering each state's unique situation.
The answer depended not just on how much coal a given state uses, but on how efficiently its coal plants were being used, how much of its gas-fired capacity was sitting unused from day to day, how much wind and solar potential the breezes and skies allowed, and whether energy-conservation incentives might help hold down demand for dirty power.
"To craft state goals," explained EPA Administrator Gina McCarthy, "we looked at where states are today, and we followed where they're going. Each state is different, so each goal, and each path, can be different."
Widely Varying Targets
In a political campaign, the map turns red or blue depending on who wins a state's electoral votes. But on this map, the tally that counts is pounds of carbon dioxide per megawatt-hour, the measurement of the electricity sector's carbon intensity.
Those are the units EPA is using to impose cuts on the states: not total emissions, but pollution per unit of power delivered.
And the state-by-state targets have turned out to vary widely, somewhat unpredictably.
In 2012, the state of Washington emitted only 763 pounds of CO2 per megawatt-hour, but it is being asked to cut that by 72 percent. Vermont has so little fossil fuel generation that it wasn't given a target at all.
Massachusetts, McCarthy's home and a birthplace of this rule since it was among the original states that sued EPA demanding controls on carbon, is now being asked to shed 38 percent of its 925 pound footprint. It's wicked willing.
Kentucky, the home of Senate Majority Leader Mitch McConnell, who wants to kill the rule in its cradle, is being asked to shave off just 18 percent, from a carbon intensity of 2,158 pounds. It will kick like a coal-mine mule.
Rhode Island, next door to Massachusetts and with just about the same carbon intensity (907), faces the same reduction target as Kentucky (18 percent). Rhode Island's carbon intensity in 2030 would end up at 782—about the same as Texas, 791, which has to cut 39 percent to get there from 1,298.
North Dakota, weighing in at 1,994 pounds, need only reduce by 11 percent.
Hawaii's carbon intensity, at 1,540, closely matches Georgia's at 1,500. But the states are as different as pineapples and peaches, and Hawaii is only being asked to cut 15 percent, barely a third as much as Georgia's 44 percent.
This all might make sense, to the extent EPA has done its job precisely right. The rule demands performance from each state according to its ability, and provides flexibility to each state according to its needs.
As Dave Hawkins of the Natural Resources Defense Council noted in a blog post on Thursday, the numbers can be deceptive when stated as percentages: One state might find it more difficult to achieve a 15 percent cut than another would find it to make a 30 percent reduction. And "EPA's targets are based on such modest improvements from today that no state will have to struggle to meet its target," he wrote.
The EPA has published an interactive map here that describes each state's fuels and carbon footprint, and gives details of the state's pollution targets, along with descriptions of controls that might be chosen. A complete ranking of the states with their emissions targets, and the percentage reduction sought from each state, is here.
Nationwide, the proposed rule aims to cut the power sector's emissions of carbon dioxide 30 percent below the 2005 benchmark by 2030 (and 25 percent by 2020). That's not as much as it sounds, because emissions had been going down in recent years anyway, and are already down about 13 percent since 2005.
Environmental advocates in Washington say they'll present information to the EPA showing why the state-by-state reductions ought to be even steeper.
Meanwhile, grassroots groups in the states, said Madsen of Environment America, will focus partly on drumming up support in Congress, and partly on beating back attempts in state legislatures to throw up roadblocks and forcing delays.
Conservative pro-coal groups are eager for that fight. Last month, Suzanne Goldenberg of the Guardian disclosed how the American Legislative Exchange Council, or ALEC, funded in part by fossil fuel companies like Peabody Coal and Koch Industries, was orchestrating a broad effort to defeat the EPA in the states.
The latest poll looks favorable for the EPA. According to the Washington Post and ABC News, 70 percent of the public favors controlling greenhouse gases from existing plants. Despite the sharp partisan divide on the issue in Congress, the numbers were not much different in red states or blue states.
After four months of public comment, the EPA will spend until next June refining its proposal before publishing a final rule. State implementation plans are due in June 2016, an ambitious schedule; states that decide to join multi-state compacts will get an additional year. EPA then has a year to decide whether to approve or disapprove the plans.
So for states that are not yet satisfied with EPA's proposal, there is a lot of time left for horse-trading.