NEW YORK ( TheStreet) - The big win by West Virginia Democratic Governor Joe Manchin for a Senate seat was being seen as a saving grace for Democrats amid the big Republican mid-term election victory, but what it means for green energy policy is less certain.

Energy policy, in general, has been a market focus for this mid-term election. California's Proposition 23, which seeks to eliminate the state's clean air mandate, has received most of the headline play. More generally, a Republican victory is expected by market prognosticators to be a boon to the energy industry and energy stocks, with less stringent regulation sought on Capitol Hill.

Manchin's win poses a clean energy dilemma of another order. Manchin's win was firmly in the Democratic column, at least on paper, and will keep President Obama's party from losing control of the Senate. Yet Manchin is far from a lock 'vote' for the Democrats by any stretch of the imagination, on any issue and in particular as it related to clean energy. Energy legislation with a focus on clean energy has already stalled in the Senate several times this year.

Manchin famously took aim at a representation of the carbon cap-and-trade bill in a recent campaign commercial. The ad received a lot of attention, and provoked questions as to whether the West Virginia Governor was really a Democrat. John Stewart even played the ad while interviewing President Obama on The Daily Show last week.

It can be argued that the ad was overhyped. Manchin ran hard against President Obama, and that deserved attention as a mid-term election theme. However, West Virginia is and has always been a coal state, and West Virginia Democrats have always had to tow a delicate line in supporting clean energy, while recognizing the role coal plays in the West Virginia economy.

In fact, the Senate seat that Manchin is set to take became open with the passing of long-time Senator Robert Byrd. The big difference between Manchin and Byrd made be that Byrd was considered a stalwart of the Democratic Party on most votes. Yet when it came to energy legislation specifically, that wasn't always the case with Byrd.

The key difference between Byrd and Manchin when it comes to climate change legislation, specifically, may be that Byrd was a late convert to capping carbon emissions. Byrd helped to draft legislation that would protect coal interests even while embracing a carbon cap. Byrd's willingness to see that coal and clean energy could reside within the same legislation isn't a sure thing with Manchin.

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