Subnational climate action means everything that happens below the federal level. Cities, counties, regional agencies, states, multi state coalitions, and interstate institutions set rules and invest public dollars.
Subnational policy shapes markets, unlocks private capital, and builds the record that supports durable national standards. It spreads a few ways.
First, it creates working examples. A city or state proves a rule or program can work, then peers copy it and vendors standardize around it.
Second, it builds markets that lower costs. Public procurement and utility programs create steady demand that pulls in manufacturing and finance.
Third, it uses planning and permitting authority to direct dollars and projects.
Fourth, it establishes a technical and legal record that supports stronger federal standards later. The result is a set of local and regional moves that add up to national behavior long before a federal rule arrives.
Cities and counties
Cities and counties control land use, zoning, building codes, building performance standards, and permitting. Building performance standards, often shortened to BPS, set energy or emissions limits for large buildings and drive demand for heat pumps, smart controls, and retrofits. Local governments run fleets and buy buses, trucks, and construction materials. Electrification ready codes and streamlined permits reduce soft costs and speed adoption.
Local action can also advance national practice when done together. Cities can adopt common templates for electric vehicle ready requirements, clean construction, and benchmarking. They can pool purchases of buses and trucks, share compliance tools and data, and align timelines. When many cities move in concert, vendors face one clear set of expectations, which speeds product development and lowers costs across the country.
Intrastate (or “sub-state”) regional agencies
Metropolitan Planning Organizations, known as MPOs, program federal transportation dollars through long range plans and a Transportation Improvement Program, called a TIP. Plans must conform to the emissions budget in the State Implementation Plan, or SIP. Some states also set greenhouse gas targets for MPOs. When MPOs shift funds toward transit, maintenance, safe streets, managed lanes, and charging depots, vehicle miles traveled, or VMT, grows more slowly and fleets electrify faster.
Transit agencies operate bus and rail systems and manage large depots and right of way. They plan service, buy vehicles, install chargers and grid upgrades, and coordinate street design with cities and MPOs. Major procurements of zero emission buses and charging equipment create predictable demand that manufacturers serve nationwide. Service that is frequent, reliable, and safe also reduces driving, which cuts emissions and improves local air quality.
Air quality management districts write rules and permits that feed into the SIP under the federal Clean Air Act. They target nitrogen oxides, called NOx, and volatile organic compounds, called VOCs, to meet health standards. Many regulate pollution from freight hubs through indirect source rules for warehouses, ports, and airports, and through tighter limits on combustion equipment. Because logistics networks operate across state lines, strong rules in major hubs push markets for zero emission trucks, cargo handling equipment, and cleaner industrial heat across the country. These rules also generate data and legal precedent that support stronger Environmental Protection Agency standards later.
States and utility regulators
States set greenhouse gas targets and pass laws that require cleaner electricity such as a Renewable Portfolio Standard or a Clean Electricity Standard. They update building codes and BPS, adopt appliance standards, regulate methane and industrial emissions, and manage siting for energy projects. States deploy funding from the Infrastructure Investment and Jobs Act and the Inflation Reduction Act, often written as IIJA and IRA. Many run green banks and use public purchasing through Buy Clean programs that prefer lower carbon materials.
Public Utility Commissions and Public Service Commissions, often shortened to PUCs and PSCs, regulate utilities. They approve resource plans, transmission and distribution upgrades, interconnection reforms, demand side programs, and rates. Early state action proves feasibility and lowers costs. PUC decisions unlock large clean power builds and improve reliability, which reduces national prices and risk for private investors.
Multistate coalitions and agreements
Governor led coalitions such as the United States Climate Alliance and sector agreements on zero emission cars and trucks align targets, timelines, and model policies. Harmonized rules reduce compliance friction, speed replication across states, and signal a stable market to investors and manufacturers.
Interstate regional agencies
Regional Transmission Organizations and Independent System Operators, known as RTOs and ISOs, operate wholesale power markets and plan transmission under the Federal Energy Regulatory Commission, or FERC. They manage interconnection queues and resource adequacy. Stronger regional transmission, better queue management, and fair rules for storage and demand response enable gigawatt scale clean energy additions across multiple states. These changes lower costs for wide areas and make federal standards easier to implement.
Interstate carbon and fuel markets also create durable price signals. The Regional Greenhouse Gas Initiative, or RGGI, caps power sector carbon dioxide across several Northeast and Mid Atlantic states and invests allowance revenue in clean energy and efficiency. The Western Climate Initiative links California and Qu├ębec in a cap and trade system that covers multiple sectors. Low Carbon Fuel Standard programs, or LCFS, in California, Oregon, and Washington create credits for lower carbon fuels and for electricity used in transportation. Shared methods for measuring emissions and credits let firms operate at multi state scale and provide evidence that informs future federal rules.
Coalition of “Section 177” states
Under Section 177 of the Clean Air Act, states can adopt California vehicle emission standards after the Environmental Protection Agency grants California a waiver. These programs include Advanced Clean Cars II for light duty zero emission vehicle sales and Advanced Clean Trucks for medium and heavy duty sales. When many states adopt these programs without change, their combined market share creates a national trajectory for zero emission vehicles in practice. Automakers and fleet operators then plan and invest on a national basis, which supports stronger Environmental Protection Agency standards later.
Why subnational action matters
It accelerates scale and speed because local, regional, and state programs can move before federal rules arrive. It lowers costs because public procurement, utility programs, and regional power markets create steady demand that pulls down prices for vehicles, chargers, heat pumps, storage, and clean power. It protects public health because air and transportation actions reduce NOx and fine particles where burdens are highest. It builds the technical and legal record that federal agencies need to issue durable nationwide standards. It strengthens economic competitiveness because coordinated subnational demand anchors domestic supply chains and skilled jobs. It also preserves momentum if federal policy pauses because state and local action keeps progress moving.
Local codes and BPS spark demand for clean buildings and fleets. Intrastate regional agencies focus that demand at freight hubs and along major corridors and translate it into real projects and service. State laws and PUC decisions scale clean power and building electrification while deploying IIJA and IRA funds. Interstate agencies unlock transmission, fair market access, and consistent carbon and fuel signals, which lowers costs across many states. Multi state coalitions and Section 177 adoption align methods and timelines so companies face consistent expectations across very large markets. Federal agencies can then lift and lock in these proven approaches through nationwide standards.
Subnational action is the engine that turns goals into markets, turns markets into standards, and turns standards into durable national progress.
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