This piece was originally published on December 17 and has been lightly updated.

Billionaire Mike Bloomberg is a problematic presidential candidate for all sorts of reasons. Progressives are irritated that he is attempting to brute-force his way into the Democratic primary by spending more on ad campaigns than the rest of the primary field combined.

Then there’s his lamentable record on civil liberties and race relations. And the fact that he was a Republican as New York City mayor, he endorsed George W. Bush’s 2004 reelection, and he has given money to and hosted fundraisers for Republicans as recently as 2018.

When it comes to climate change, however, Bloomberg’s record is almost entirely positive. He was instrumental in standing up and funding the Sierra Club’s Beyond Coal campaign, which has been one of the most ruthlessly effective activist campaigns of my lifetime. Recently, the Associated Press, in a “fact check,” rebutted the notion that Bloomberg is single-handedly responsible for all recent coal-plant closures — and it’s true, market forces helped, as did government policy. But everyone who has paid attention to the power sector knows that the kind of activist pressure he has supported frequently makes the difference at the margin.

More recently, Bloomberg pledged $500 million to an expanded Beyond Carbon campaign, which will shoot for a 100 percent clean-energy economy, taking on not only coal but also natural gas, the next key battle in US decarbonization.

This fact has not received enough attention: If Bloomberg brings the same discipline and credibility to the anti-natural gas fight that he brought to the anti-coal fight, it could help shift the national landscape.

Which brings us to the Bloomberg presidential campaign’s first policy proposal on climate change, released in December. (In January, he released a second plan to make buildings zero carbon by 2025.) The first plan is worth noting for just this reason: It explicitly targets natural gas.

We’ll also replace existing gas plants – and stop the construction of new ones. This is critical to stopping the worst effects of climate change because gas is now a bigger source of climate pollution than coal, and emissions from gas are growing. https://t.co/9XCU1xBFYJ pic.twitter.com/IweS27Etsk — Mike Bloomberg (@MikeBloomberg) December 13, 2019

The premise of Bloomberg’s campaign is that he is an experienced, level-headed executive, ready to run things with a steady hand. In keeping with that theme, his plan for clean electricity — which targets 80 percent greenhouse gas emission reductions in the power sector by 2028 “moving toward 100% as soon as possible thereafter” — focuses entirely on executive powers. It presumes no legislative help.

It contains only achievable promises, consistent with what can be done by a president, acting alone, within a president’s term. That is somewhat in contrast to the sweeping, speculative plans from the other candidates, and likely to make the plan unpopular among activists, but it is nonetheless a good perspective into what any Democratic president could do if Congress goes the wrong way.

Let’s take a look.

Bloomberg would supercharge the EPA to get rid of coal and block new natural gas

There are several pieces to the plan, including financial support for clean energy technologies, removing fossil fuel subsidies from the tax code, a moratorium on new fossil fuel leases on public land, restoring scientific integrity at the EPA, and putting frontline communities and environmental justice at the heart of federal planning. But the two pieces I want to focus on have to do with coal and natural gas.

Specifically, Bloomberg promises to shut down the remaining 251 US coal plants and replace them with clean energy. And he promises to “stop the rush to build all proposed gas plants.”

Coal plants will be shut down by “increasingly stringent emissions and pollution limits.” Elsewhere, he promises to restore and strengthen all the rules that Trump has been rolling back, so presumably those limits will include tightened regulations on mercury and air toxics, coal ash, SO2 and NOx, and other air and water pollutants.

But the centerpiece, according to campaign advisers, will be a version 2.0 of Obama’s Clean Power Plan (which Trump has also rolled back), targeting 80 percent power-sector carbon reductions by 2028, as well as sharp reductions in local pollutants like SO2 and NOx.

As part of our Beyond Coal campaign, we’ve closed more than half of the coal plants in the country - even with President Trump working against us.



We’ve set a goal of retiring all of them and replacing coal with clean energy sources. https://t.co/9CyzVPQlgg pic.twitter.com/4bfjafrmPi — Mike Bloomberg (@MikeBloomberg) December 13, 2019

A new CPP that stringent, focused primarily on public health, would wipe out coal power plants. But it would also hit natural gas plants.

In addition, to head off the current incoming rush of new natural gas plants, Bloomberg’s EPA would issue a draft New Source Performance Standard (something else Obama did that Trump rolled back), which would require all new power plants to use the best available technology — namely, carbon capture and sequestration (CCS) — to reduce GHG emissions (along with NOx, etc.).

That would, at a stroke, cancel 99 percent of those new natural gas plants. (Who knows, maybe a plant or two will figure out how to make CCS feasible.) And because of a quirk of the Clean Air Act, a draft New Source Performance Standards (NSPS) has the force of law as soon as it is issued, but it can’t be challenged in court until it is finalized, which is one reason industry loathes the NSPS provision. (Coal baron Robert Murray took this to the Supreme Court and lost.) Companies will have to begin aligning their future plans around the NSPS the moment a draft is issued.

There are also other tools in the executive toolbox with which to go after natural gas, including national ambient air quality standards (NAAQS) for NOx, soot, and ozone, but it is mainly the combination of the CPP 2.0 and the NSPS that would take out coal and natural gas.

This is a targeted approach, going after the polluters in the sector, putting public health out front. It lacks a certain inspiration factor, but it has the considerable virtue of being something that a president — at least a president willing to hire good people and invest political capital — has a high probability of being able to accomplish.

All executive actions will face court challenge

Of course any new rules from a Bloomberg EPA would immediately face legal challenge, many of them would end up in the Supreme Court, and the Supreme Court shows every sign of being hostile to environmental and climate change rules. There is a decent chance a Roberts Court would kill some or all of any activist EPA’s efforts.

However, there are some countervailing considerations.

First, what the hell else is a president going to do? While Congress mucks around, or just as likely does nothing, a president has to act on the priorities that got him or her elected. Using the powers of the presidency entails court review. The rules can be thoughtful and legally solid, but there’s ultimately not much the president can do if federal or Supreme Court judges choose to act as a partisan enforcers. (There’s no word on whether Bloomberg would support more radical measures like packing the Supreme Court or the federal courts.)

Second, if there’s one thing to learn from Obama’s experience, it’s that deliberate, careful sequencing gets you nowhere. Obama didn’t pull the trigger on EPA carbon regulations until it was beyond clear that there would be no climate change legislation. Many carbon-related rules didn’t have time to go into effect or be upheld in court. In retrospect, Obama should have done what Trump has done: blitzed. Do everything at once. Overwhelm the capacity of opponents to focus.

For Bloomberg, that could mean a whole suite of new agency rules, all at once, alongside whatever may be going on legislatively. The Supreme Court simply doesn’t have the capacity to hear more than a fraction of the resulting lawsuits, and in federal courts, despite the hack judges McConnell is churning out, the legal defenders of Obama regulations have racked up a solid record. Campaign advisers also note that rules premised on public health have a longer and more robust record than carbon-focused rules.

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Third, even as cases wind their way through the courts, companies will be realigning around the new targets. That’s what happened around Obama’s CPP, and although that rule ultimately never received a decisive court judgment, companies began shifting their business plans in response. Consequently, next year the US will reach the initial CPP goal — 32 percent power-sector carbon reductions from 2005 levels by 2030 — a decade early.

The same would happen in response to a CPP 2.0 targeting 80 percent reductions by 2028, issued early in the next president’s term. By 2024, or whenever the case finally reached the Supreme Court, companies will have realigned around the new direction (which will be reinforced by renewed international climate efforts).

What to take away from Bloomberg’s plan

I don’t personally think much of the idea of Bloomberg as president. But on climate policy, perhaps uniquely among policy issues (save gun control), it is worth listening to what he proposes. He is an unconventional face for an environmental campaign and has, for better or worse, brought attention and credibility to the fight against fossil fuels among audiences environmentalists can’t always reach.

Having followed politics for years, I am intensely skeptical of claims that executive experience is any special preparation for the presidency. (Both George W. Bush and Donald Trump promised to “run the government like a business,” so ...) But Bloomberg’s executive experience really does seem to have helped the Beyond Coal campaign. As its leaders were the first to say, Bloomberg helped focus the campaign relentlessly on data and accountability, imposing a discipline that is, ahem, not always present in the nonprofit advocacy world. And it paid off: Almost 300 plants, more than half the US fleet, have shut down.

The Bloomberg plan promises “incentives for innovations in data and technology to monitor and analyze sources of pollution, enabling stronger enforcement against polluters.” This suggests he wants to bring that same data-focused accountability back to the EPA. If he, or any president, can do that successfully, it would make a huge difference.

Bloomberg has more climate policy on the way. The campaign has also pledged to target 50 percent economy-wide emission reductions by 2030, a more ambitious goal that will certainly require some help from Congress, especially in hard-to-reach sectors like industry and agriculture, but it hasn’t released any policy details on that stuff yet.

Still, a practical but ambitious plan to use the EPA — to prevent a rush to natural gas plants, to drive coal underground for good, and to accelerate a clean-energy transition in the power sector — should be on the agenda of any new Democratic president. And it should get underway on day one, whatever broader legislative efforts may unfold alongside it.