The participation of core stakeholders in the design of, and challenges to, the US Clean Power Plan

We examine the participation of stakeholders in the rule-making process leading to the design of the US Clean Power Plan (CPP), which was the cornerstone regulation developed during the Obama administration to lower GHG emissions from power plants in the US. Using publicly available information, we identify the core stakeholders that participated in the different stages of the rulemaking process, from the early draft of the rule to its publication in final form, and examine variables that could help explain their decisions to litigate, either against or in favour of the final version of the rule. We show that the ‘pro-CPP’ stakeholders were (a) more likely to participate during the early stages of the rule-making process, attending meetings with the Environmental Protection Agency (EPA) staff to discuss rule content, and (b) less likely to get involved during the litigation process. ‘Anti-CPP’ stakeholders, on the other hand, did the opposite, being in general less active during the rulemaking stages, and more active during the litigation stage. However, we also find that the ‘anti-CPP’ stakeholders were more tightly organized as a coalition when compared to the ‘pro-CPP’ stakeholders throughout the process (even in the early stages when they participated less). Our results shed new light on the way advocacy coalitions operate in the climate policy subsystem in the US, and help inform debates about the likelihood of conflict and cooperation across a variety of environmental policy topics. <b>Key policy insights</b>The design of the Clean Power Plan was a long and contentious process in which ‘Pro’ and ‘Anti-CPP’ coalitions operated to support and undermine the rule, respectively.‘Pro-CPP’ stakeholders were more active in meetings organized to discuss the CPP with EPA staff, and in submitting written comments.‘Anti-CPP’ stakeholders were more active during litigation, in response to perceived EPA overreach in designing the rule and negative financial impacts on states’ economies.Joint participation by ‘Anti-CPP’ stakeholders in meetings conveyed by the EPA to discuss the potential content of the rule helps explain their joint litigation efforts, which hints at their considerable capacity to self-organize as a coalition throughout the process. The design of the Clean Power Plan was a long and contentious process in which ‘Pro’ and ‘Anti-CPP’ coalitions operated to support and undermine the rule, respectively. ‘Pro-CPP’ stakeholders were more active in meetings organized to discuss the CPP with EPA staff, and in submitting written comments. ‘Anti-CPP’ stakeholders were more active during litigation, in response to perceived EPA overreach in designing the rule and negative financial impacts on states’ economies. Joint participation by ‘Anti-CPP’ stakeholders in meetings conveyed by the EPA to discuss the potential content of the rule helps explain their joint litigation efforts, which hints at their considerable capacity to self-organize as a coalition throughout the process.

本研究考察美国《清洁电力计划》（Clean Power Plan, CPP）制定流程中的利益相关方参与情况。该计划是奥巴马政府时期推出的核心监管政策，旨在降低美国境内电厂的温室气体（Greenhouse Gas, GHG）排放。本研究依托公开可得的信息，识别出从规则初稿到最终定稿的各规则制定阶段中参与其中的核心利益相关方，并分析可用于解释其针对该规则最终版本提起诉讼（支持或反对）的决策的相关变量。

研究结果显示，支持CPP的利益相关方具备两大特征：其一，更倾向于参与规则制定早期阶段，主动与美国环境保护署（Environmental Protection Agency, EPA）工作人员开展会议以讨论规则内容；其二，在诉讼阶段的参与度相对较低。而反对CPP的利益相关方则呈现出完全相反的行为模式：整体而言，他们在规则制定阶段的参与度较低，却在诉讼阶段更为活跃。不过，本研究同时发现，在整个政策制定流程中（即便在参与度较低的早期阶段），反对CPP的利益相关方相较于支持方，作为联盟的组织紧密程度更高。

本研究结果为美国气候政策子系统中的倡导联盟运作模式提供了新的研究视角，同时可为各类环境政策议题下冲突与合作的可能性相关讨论提供参考依据。

**核心政策启示**
《清洁电力计划》的制定是一场漫长且充满争议的过程，支持CPP与反对CPP的两大联盟分别通过行动推动或削弱该规则的落地。支持CPP的利益相关方在与美国环境保护署工作人员开展的CPP研讨会议，以及提交书面意见等环节中表现得更为积极。反对CPP的利益相关方则在诉讼阶段更为活跃，此举源于他们认为美国环境保护署在规则制定过程中越权，以及该规则会对各州经济造成负面财务冲击。反对CPP的利益相关方共同参与美国环境保护署举办的规则潜在内容研讨会议的行为，可解释其后续联合诉讼的行动，这也体现出他们在整个政策流程中具备较强的自我组织为联盟的能力。
《清洁电力计划》的制定是一场漫长且充满争议的过程，支持CPP与反对CPP的两大联盟分别通过行动推动或削弱该规则的落地。支持CPP的利益相关方在与美国环境保护署工作人员开展的CPP研讨会议，以及提交书面意见等环节中表现得更为积极。反对CPP的利益相关方则在诉讼阶段更为活跃，此举源于他们认为美国环境保护署在规则制定过程中越权，以及该规则会对各州经济造成负面财务冲击。反对CPP的利益相关方共同参与美国环境保护署举办的规则潜在内容研讨会议的行为，可解释其后续联合诉讼的行动，这也体现出他们在整个政策流程中具备较强的自我组织为联盟的能力。