DEP hearings: Peter Winslow

peterwinslowPeter Winslow is a PA IPL board member.  He testified at the PA DEP listening session in Philadelphia County on September 30, 2015.  His oral remarks are followed by a longer written submission.

My name is Peter Winslow.  I wish to express our appreciation to Gov. Wolf, Sec. Quigley, and the DEP staff for:

  • Embracing the Clean Power Plan rather than resisting the EPA’s rulemaking authority,
  • Working to develop a Pennsylvania Plan instead of waiting for imposition of a federal plan,
  • Endeavoring to submit our PA plan by September 9, 2016 without requesting an extension of time in which to comply with the Rule, and
  • Holding these listening sessions for the public to provide input on a timely basis.

Thank you for this opportunity to be heard by you.

I am the President of the Evolve Foundation, Inc. –  a Pennsylvania Nonprofit Corporation supporting initiatives for a more sustainable and just society.

I am also a Board Member of Pennsylvania Interfaith Power & Light – a chapter of a 40-state
national organization for communities of faith concerned about and responding to climate disruption as an urgent moral issue.

We depend upon your moral sense to guide the judgment and craftsmanship required of you to design for us policies equal to the challenges presented by the complex reality of climate disruption.

Pope Francis has called upon public officials such as you “for a courageous and responsible effort to ‘redirect our steps’1 and to avert the most serious effects of the environmental deterioration caused by human activity2.”  Pope Francis asks you to apply the Golden Rule.  We ask you to act as “responsible ancestors.”

Starting with the Clean Power Plan, we hope Pennsylvania will take national and international leadership in response to the challenges of climate disruption.

Specifically…

#1 – Consider the EPA target of 33% reduction a floor, not a ceiling: The EPA target is inadequate to correct the problems resulting from current reliance on hydrocarbons for electricity generation.  More can be accomplished, if adequate policies are implemented.  More must be achieved, if calamity is to be avoided.

#2 – Set an ultimate target in relationship to Pennsylvania’s fair share of the global atmospheric commons.  Our goal should be framed in terms of where we need to get to as well as where we are coming from:

  • Our state should be “carbon neutral” by 2030.
  • Our state should be “zero carbon” by 2050.
  • The CPP should achieve these goals with respect to electricity production.  So,

#3 – Move faster, target higher, extend further.  Within the framework of the EPA rulemaking:

  • Faster:  Submit the PA-CPP to the EPA next summer; don’t wait until September.
    Target implementation as soon as possible; don’t wait until 2020.
  • Higher:  Raise the bar; 1/3 reduction from the 2005 base is not enough.
    Target 45% reduction by 2030 instead of 33%.
  • Further:  Don’t cut the program off in 2030; continue improvement.
    Target 75% by 2040; 100% by 2050.

#4 – Target all six of the GHGs identified by the Kyoto Protocol, not just CO2.  The environment is a dynamic system; engage the problem in its entirety.  There are no “silver bullets” for dealing with the climate crisis.

#5 – Include all aspects of the power plant supply chain in the calculation of GHG emissions attributable to electricity production.  As good corporate citizens, all companies that generate electricity should be required to assure that vendors up their supply chains adhere to industry best practices to reduce GHG from their operations.

#6 – Do not include energy efficiency or reduced consumption in the electricity distribution channels in the calculation of GHG for the CPP.  Encourage energy efficiency and renewable energy through the Clean Energy Incentive Program and other measures.  But, focus the CPP specifically on the generation side.

#7 – Do not make an exception for the ARIPPA business model that uses legacy coal refuse piles as fuel for electricity production.  The disaster resulting from previous anthracite and bituminous mining operations must be cleaned up.  But, further fouling the air cannot be an answer.

When you find yourself trapped at the bottom of a pit you have dug, please stop digging.

#8 – Coordinate the PA Plan with other states and regional organizations:  The EPA has estimated that a regional approach will cost $2 billion less than a state-by-state implementation.

National IPL supports the RGGI cap-and-trade program.  I recommend that the RTO be mandated to prioritize acceptance of electricity into the grid based on the lowest rate of pollution per watt provided by suppliers.

Thank you for receiving my remarks, which are more extensive in my written submission.

Written Remarks
My name is Peter Winslow.  In my capacity as President of the Evolve Foundation, Inc. – in addition to being a Board Member of Pennsylvania Interfaith Power & Light, and a citizen of Philadelphia and the Commonwealth – I address my remarks today to the PA/DEP concerning Pennsylvania’s plans to implement and enforce EPA’s Section 111(d) rulemaking to reduce greenhouse gas emissions from existing fossil fuel powered electricity generation facilities, the Pennsylvania Clean Power Plan (“CPP”).  Thank you for this opportunity to be heard by you.

I received a BA in Economics and an MBA in Finance from the University of Pennsylvania.  I have been a CPA and the CEO of a public corporation.  So, I understand the business and financial implications of the CPP.

I perform work in energy efficiency innovation for the Department of Defense under the ESTCP (Environmental Security Technology Certification Program) in collaboration with Carnegie Mellon University, Siemens, and others.  So, I am familiar with and a proponent for the potential of energy efficiency and renewable energy.

Evolve Foundation, Inc. is a Pennsylvania Nonprofit Corporation supporting initiatives for a more sustainable and just society.

Interfaith Power & Light (“IPL”) is a national organization for communities of faith concerned about and responding to climate disruption as an urgent moral issue.  Congregations of all denominations and individuals from all traditions are advocating for “climate justice” and rapid transition to a “clean energy economy” through 40 state and regional chapters of IPL.  The Pennsylvania Chapter of IPL is an independent entity – a Pennsylvania Nonprofit Corporation with IRC §501( c)(3) status.

My purpose today is to urge you to use a clear moral lens when viewing the issues before you.  But, I’m not here to preach.  I do, instead, appeal to your own sense of right and wrong.  We depend upon your moral sense to guide the judgment and craftsmanship required of you to design for us policies equal to the challenges presented by the complex reality of climate disruption.  Pope Francis has called upon public officials such as you “for a courageous and responsible effort to ‘redirect our steps’(Laudato Si §61) and to avert the most serious effects of the environmental deterioration caused by human activity.” (Address of Pope Francis to Joint Meeting of Congress 9/24/25)  Pope Francis asks you to apply the Golden Rule.

We ask you to act as responsible ancestors.

In this written version of the remarks I am making during my five-minute oral presentation to you, I am providing more extensive explanations of some specific ways such moral perspective may be applied to your decision-making processes for developing the PA Clean Power Plan.  These suggestions will be illustrative, not exhaustive.  Indeed, the broad scope of your ethical obligations includes promoting the welfare of our workers and their families, the health of the citizens and environment of our state, and the rights of everyone in our global community in the face of climate catastrophe.  You carry a lot of responsibility.

We appreciate that the EPA and the DEP are constrained by the limits of their legal authority, as provided by Congress and the PA Legislature respectively, regarding the rules and regulations that may be issued to protect environmental quality.  Therefore, the framework for our state’s Clean Power Plan provided by the EPA necessarily represents a balancing of factors within its mandate.  Despite and because of such political considerations, however, the resulting targets that EPA has set are inadequate to address the problems facing us as a society currently reliant on hydrocarbons for energy.

Viewed from the perspective of what’s needed, rather than what action the Obama Administration can take without Congressional support, we are already “a day late and a dollar short.”  Consequently, we need to play catch-up.  The United States is by far the largest cumulative emitter of CO2 historically.  The United States and China are the largest emitters of CO2 currently.  Pennsylvania is the 3rd largest emitter of CO2 in the country.  Although we’re pleased by progress made, we’re chagrined by the damage done and the harm that continues.  So, let’s take responsibility.

We recognize and applaud the ambition and historic significance of limiting carbon emissions from existing power plants.  I understand the technical, political, and economic considerations that influence policy and make planning and execution of a Clean Power Plan difficult.  But, I know – and I’m sure you know – that the goals of the EPA program are modest relative to the results that can be achieved, if sufficient priority is given to reducing CO2 emissions.  So, let’s step up to the challenge.

We urge the DEP and the elected officials of the State of Pennsylvania to take national and international leadership in response to the challenges of climate disruption. Anticipate and act to prevent the negative impacts of climate disruption, mitigate the damage that can’t be avoided in time, compensate those who are being injured, help especially those who are most vulnerable, adapt to changing circumstances, remediate the legacy of irresponsible stewardship, and make reparations for past and continuing climate injustice.

In particular, the state – and, to the extent possible, the companies responsible for the degradation of our environment – should provide retraining for unemployed workers, health care for those injured by “black lung” and other work related diseases, improved air quality for those suffering from asthma and other respiratory diseases, and economic assistance for communities impacted by transition to non-polluting electricity production.

The Clean Power Plan requires each state government to consider low-income communities of color, who are disproportionately affected by power plant pollution, in creating their implementation plans. IPL will be working to ensure our congregations in those communities are participating.

People of faith have a moral obligation to care for and protect our nation’s children and future generations by addressing the effects of climate change and carbon pollution, especially as they wreak havoc on the poorest and most vulnerable among us.

Although all are affected, the increased frequency and severity of catastrophic floods, lengthy droughts, wildfires and other extreme weather events is disproportionately challenging low income families who do not have the resources to adequately prepare and recover. Lower income families and people of color are already predisposed to higher health risks, such as asthma, and often live near sources of carbon pollution.

Seize the PA Clean Power Plan as an opportunity for Pennsylvania to provide leadership.

#1 – Consider the EPA target of 33% reduction a floor, not a ceiling for Pennsylvania’s Clean Power Plan.

Pennsylvania is not constrained by the limits of the EPA’s legal authority.  Pennsylvania can set targets that are more adequate to correct the problems resulting from current reliance on hydrocarbons for electricity generation.  Please set the bar for achievement as high as possible.

#2 – Set an ultimate target in relationship to Pennsylvania’s fair share of the global atmospheric commons.

Emissions in Pennsylvania affect people everywhere.  People in immediate proximity to power plants are most directly impacted; those downwind are also subjected to air pollution.  But, furthermore, through different chemistry, the climate of the entire globe is harmed by the cumulative greenhouse effects of emissions emanating from Pennsylvania.

Our goal should identify where we need to get to as well as where we are coming from.

  • Our state should be “carbon neutral” by 2030.
  • Our state should be “zero carbon” by 2050.
  • The CPP should achieve these goals with respect to electricity production.

#3 – Move faster, target higher, extend further.

Within the framework of the EPA rulemaking:

  • Faster:  Submit the PA-CPP to the EPA next summer; don’t wait until September.
    Target implementation as soon as possible; don’t wait until 2020.
  • Higher:  Raise the bar; 1/3 reduction from the 2005 base is not enough.
    Target 45% reduction by 2030 instead of 33%.
  • Further:  Don’t cut the program off in 2030; continue improvement.
    Target 75% by 2040; 100% by 2050.

#4 – Target all six of the GHGs identified by the Kyoto Protocol.

CO2 is not the only GHG emitted by electric power generation plants.  The PA Clean Power Plan should contain and reduce carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydro-fluorocarbons (HFCs), per-fluorocarbons (PFCs), and sulphur hexafluoride (SF6). (The Greenhouse Gas Protocol, World Resources Institute)

Because the environment is a dynamic system, solutions to the problem must be as comprehensive as possible.  There are no “silver bullets” for dealing with the climate crisis.

#5 – Include within the purview of the Plan all aspects of the supply chains to power plants located in Pennsylvania for calculation of GHG emissions attributable to electricity production.

Electricity generation companies should be good corporate citizens who take responsibility to assure that their vendors follow industry best practices for preventing emissions and protecting the environment.  As such, they should assure that vendors up their supply chains adhere to industry best practices to reduce GHG from their operations.  If these companies don’t accept such responsibility voluntarily, they should be required to do so.

If, for example, PA power plants become cleaner because the fuel they burn has become less toxic due to improved extraction, processing, and transport technology, then our goal may seem to have been achieved.  Vendors of fuel should compete to deliver products that burn as cleanly as possible, and electricity generators should base their purchasing decisions on obtaining those products.  However, if the methods employed to provide cleaner fuel are themselves detrimental to the environment, we have merely moved the site of emissions from the point of generation upstream in the supply chain.  Therefore, the supply chain as a whole must be managed.

#6 – Do not include energy efficiency or reduced consumption in the electricity distribution channels in the calculation of GHG.

Encourage energy efficiency and renewable energy through the Clean Energy Incentive Program and other measures.  But, focus the CPP specifically on the generation side.

Energy efficiency has great potential to reduce electricity consumption.  Transmission efficiency, peak power management, reduction in consumption, distributed supply, and other approaches can reduce emissions of GHG substantially.  All of these methods should be encouraged and implemented.  But, progress in these areas should augment rather than offset the improvement required from electricity generators.

In contrast, the CPP should consider renewable energy as an integral part of the total electricity generation infrastructure of Pennsylvania.  Each kWh of electricity generated by PV solar panels or wind turbines should increase the denominator of the CPP calculation without increasing the numerator.

#7 – Do not make an exception for the ARIPPA business model that uses legacy coal refuse piles as fuel for electricity production.

Although I agree that Pennsylvania needs to minimize and repair the devastation from the past that continues to imperil our environment, a method for dealing with the problem that results in further fouling the air cannot be acceptable.

At the September 25, 2014 Listening Session related to this EPA rulemaking, John Olebracht, a Member of the Board of ARIPPA (Anthracite Region Independent Power Producers Association), described the potential impact of the Clean Power Plan on the business model that uses the legacy coal refuse piles left from previous anthracite and bituminous mining operations.  Historical extraction practices resulted in the abandonment of thousands of acres of ravaged landscape and stockpiles of low-quality, high-ash, low-BTU, non-marketable coal refuse exposed to the weather.  This toxic residue has poisoned Pennsylvania land and water, making sacrifice zones that are unsuitable for vegetation, fish and game, or people.  The poisoning continues as uncontrolled abandoned mines and stockpiles catch fire and Mr. Olebracht estimated that elimination of this environmental legacy will cost nearly $15 billion and take 500 years.

When you find yourself trapped at the bottom of a pit you have dug, please stop digging.

#8 – Coordinate the PA Plan with other states and regional organizations.

We applaud the determination of Pennsylvania to craft its Clean Power Plan to address the specific needs of our state.  Yet, reduction of GHG requires concerted and coordinated action at the regional, national and global levels.  Recognizing the value of regional planning and coordination, the EPA has estimated that a regional approach will cost $2 billion less than a state-by-state implementation.  Accordingly, IPL supports the cap-and-trade program of RGGI, the Regional Greenhouse Gas Initiative that was established in 2005 to conduct auctions of emissions allowances for interstate power plants with output capacity in excess of 25 megawatts.  IPL therefore urges Pennsylvania to join the nine Northeastern and Mid-Atlantic states currently participating in RGGI.

I support market-based approaches to address aspects of the problem.  Nevertheless, a cap-and-trade approach reduces but fails to minimize pollution.  Such systems have the perverse effect of rewarding current polluters by awarding baseline caps with value that allows them to continue emitting CO2 and/or profit by reducing emissions.  Furthermore, such market-driven mechanisms encourage a speculative secondary market instead of direct industry collaboration.

Therefore, in addition, I recommend that the Regional Transmission Organization (“RTO”) be mandated to prioritize acceptance of electricity into the grid based on the lowest rate of pollution per watt provided by suppliers.  The grid should take electricity first from those generation sources that produce the cleanest power.  Thereby, the RTO would assure that consumers would receive electricity at the lowest cost consistent with the least pollution that the system can provide.

These goals can be achieved while assuring the reliability of electricity supply and without unduly raising the cost of such service to individuals and businesses.

But, even if additional costs or inconveniences should result from implementation of a more robust plan, we owe our best efforts to adopt best practices for the benefit of our children and future generations in Pennsylvania and throughout the world.  Sacrificing the health, safety, and lives of others for the gain and comfort of a few is unconscionable.

Our society needs to reduce the effects of fossil fuel use on climate as much and as fast as possible.  The Clean Power Plan is one important part of the means to achieve that end.

We cannot continue to ignore climate disruption – as well as health, safety, and environmental considerations – as externalities in our economic analysis.  The cost of releasing CO2 emissions into the atmosphere at a rate and level above the carrying capacity of the environment should be made prohibitively expensive.  The prospect of stranded assets should serve as deterrent to new investment in polluting infrastructure, and competitive advantage should provide incentive for maintenance of existing facilities.  Let’s employ policies that consistently drive a race to the top rather than the bottom.

We wish to express our appreciation to Gov. Wolf, Sec. Quigley, and the DEP staff for:

  • Embracing the Clean Power Plan rather than resisting the EPA’s rulemaking authority,
  • Working to develop a Pennsylvania Plan instead of waiting for imposition of a federal plan,
  • Endeavoring to submit the PA plan by September 9, 2016 without requesting from the EPA an extension of time with which to comply with the Rule, and
  • Holding these listening sessions for the public to provide input on a timely basis.

References:

1 – (Laudato Si §61)

2 – Address of Pope Francis to Joint Meeting of Congress 9/24/25

3 – The Greenhouse Gas Protocol, World Resources Institute