With only 13 months left in the Bush-Cheney Administration, swing Democrats like John Conyers and Jerrold Nadler believe there simply isn't enough time to impeach George Bush or Dick Cheney.

As former Judiciary Committee member Elizabeth Holtzman wrote this week, the impeachment of Richard Nixon took less than 6 months, even though it was the first impeachment in 100 years and required the creation of entirely new procedures. Holtzman says, "Now the relevant legal spade work is done and a road map for proper impeachment proceedings exists, Congress could probably conduct them even faster than in 1974."

But there probably is not sufficient time for a sprawling investigation of broad and complex topics like all of the pre-war lies. So impeachment strategists should focus on charges that require a minimum of investigation. What are those?

1. Conspiring to out Valerie Plame and obstructing justice by commuting the sentence of Scooter Libby.

2. Refusing to comply with Congressional subpoenas.

3. Illegally wiretapping the calls and emails of virtually every American citizen.

4. Issuing Signing statements that led to illegal actions as documented by GAO.

Since Speaker Pelosi is adamantly opposed to impeachment hearings for President Bush, which of these are the strongest grounds for impeaching Vice President Cheney?

Behind the scenes, Cheney and his Chief of Staff David Addington are key players in all of these battles. But because they operate behind the scenes, it is hard to indict them specifically - with the exception of #1, conspiring to out Valerie Plame and obstructing justice by commuting the sentence of Scooter Libby.

Cheney's role in the outing of Valerie Plame was partially revealed through the Libby trial. Just before Scooter Libby outed Plame to Judith Miller of the New York Times, Libby met with Cheney about disclosing classified information. Libby claims Cheney authorized him to disclose favorable parts of the pre-war National Intelligence Estimate on Iraq, but that information was leaked to the press days earlier, and neither the Special Prosecutor nor the jurors believed Libby's story.

Beyond the trial record, there is testimony by Bush and Cheney that has not been published and can be subpoenaed. Also Special Prosecutor Patrick Fitzgerald could be asked to prepare a report on these questions. After reviewing all available evidence, Congress could put both Libby and Cheney under oath and ask whether they discussed outing Valerie Plame or not.

After Scooter Libby was convicted and sentenced to 30 months in prison, Bush's commutation was widely viewed as intended to keep him from finally telling the truth to Special Prosecutor Patrick Fitzgerald, and thereby protecting his boss, Dick Cheney. News reports said Cheney urged Bush to commute Libby's sentence. After collecting all available evidence, Congress could put Cheney and all other witnesses under oath to determine if Cheney urged Bush to commute Libby's sentence - and whether it was to protect himself.

Under this scenario, several things could happen:

• Libby and Cheney could refuse to testify, but since these would be impeachment hearings, Cheney's defiance of duly-issued subpoenas would itself be an impeachable Contempt of Congress. This was Article 3 of the Articles of Impeachment for President Nixon.
• Libby and Cheney could lie to Congress, but that would be very difficult because of all the testimony collected in the Libby trial and the exhaustive analysis of that evidence by bloggers like Marcy Wheeler (emptywheel).
• The White House could attack Congress for daring to hold such hearings, but public support for Bush (and especially Cheney) is so low that these attacks would have no political impact.

Of course the major obstacle to impeachment is the belief by Democratic leaders that any form of impeachment would backfire politically. Therefore there would have to be really powerful arguments for pursuing impeachment, and I would offer these:

1. Outing Valerie Plame was a devastating blow to our essential efforts to stop terrorists from acquiring WMD's, which is the single most important lesson of 9/11
2. Outing Valerie Plame may have cost the lives of Plame's spies
3. Lying to the FBI, and grand jury, and a Special Prosecutor is intolerable by any elected or appointed government official
4. No elected official, including the Vice President and the President, can be above the law
5. We cannot allow the Vice President and the President to spend their final year in office destroying evidence of numerous official crimes and pardoning those who committed them
6. As every primary poll shows, the American people still want change, just as they did in November 2006 when they swept Republicans out of power in Congress. Holding the Vice President accountable for one of his gravest crimes is a powerful way to begin real change.