RGGI Testimony-Phyllis Blumberg, Advocate for Climate Justice and Supporter of PA IPL

 I care deeply about combating climate change and the evidence from other states indicates that RGGI will help us do that in PA also. I am  writing as a concerned citizen who has seen the effects of severe weather and increasing respiratory problems in my family and neighborhood. My Jewish faith also compels me to act.

As a concerned citizen who wants to a healthy and safe environment not only for my children and grandchild, but for all people who are living now and not yet born, I prioritize protecting the environment and averting the effects of climate change over my own personal comfort and the desire to pay less money.

I personally invested in clean energy in my own lifestyle. Over ten years ago I retrofitted my 90 year- old house that had natural gas heat  to have geothermal HVAC just at the time when fracking caused the price of natural gas to sink. Two years ago I had solar panels installed on my roof and last year I bought a totally electric car. I did not make these changes to save money, but rather to save the environment and to protect the health for future generations.  Even if every American were to invest in clean energy, and I realized that many cannot afford to do so, yet it still would not be enough.  We need strong leadership from the PA government to move us to transition to a renewable and healthy future.

Pennsylvania  is one of the dirtiest power sectors in the nation. We  must  change that course and start reducing our carbon pollution. Joining RGGI will make our Commonwealth cleaner, more prosperous, and offer a better future for all. In addition to its climate and public health benefits, estimates show that RGGI would generate a net increase of many clean energy jobs and it will add billions to the state’s economy by 2030.  These funds can be used to improve the living conditions in underserved communities and communities of color in Pennsylvania  that need the help the most. By putting a price tag on pollution, RGGI incentivizes energy producers to turn away from fossil fuels, cut carbon, and create investments in clean energy.

It is concerned citizens like me and 90% of the citizens of PA who want clean air and to protect the environment. Only profit-hungry, polluting industry insiders who want to keep things as they are now because they stand to benefit from doing so, at a cost to all of us.

Ten other states are already been reaping the benefits of joining RGGI, and Pennsylvania can’t get left behind.  It’s time for Pennsylvania to tap into this record of success, invest in sustainable jobs in our flourishing clean energy sector, and reduce our carbon pollution.

In conclusion, I am testifying to explicitly state my support  for Pennsylvania joining of the Regional Greenhouse Gas Initiative.  All the benefits I am advocating for are the direct result of PA joining RGGI! 

RGGI Testimony-Scott Laird, Advocate for Climate Justice and Supporter of PA IPL

Thank you for the privilege of submitting comments to the Environmental Quality Board (EQB) of the Commonwealth of Pennsylvania regarding the proposed rule for the Commonwealth to take part in the the Regional Greenhouse Gas Initiative (RGGI). I hereby urge the EQB to approve this proposal. I am a private citizen and do not submit these comments on behalf of any organization. I am an honorably retired, former professional geologist in Pennsylvania and Delaware, as well as a former licensed site remediation professional in the State of New Jersey. My comments reflect my personal opinion, informed by my education and experiences, about the gravity of our future climatic conditions for my adult children and my small grandchildren.  I believe we are facing an existential climatic crisis with long-term implications not seen since the Second World War. The decision of the EQB will have an important bearing on this Commonwealth’s part in responding to this crisis. I also offer comments based on technical information for which I have cited references in peer-reviewed government documents. The facts and data gathered, analyzed and evaluated by the best-trained scientists in the world must be recognized and factored into your decision. I have previously testified to my Tredyffrin Township Board of Supervisors in favor of going to 100% renewable power sources which the Board approved this year by a 6-1 vote.

The Fourth National Climate Assessment identified several critical climatic effects from a human-caused rise in the global annual average temperature (AAT) relative to pre-industrial times.[ Wuebbles, D.J et al., 2017. Executive Summary/ Client Science Special Report: Fourth National Climate Assessment, Volume I; In Wuebbles,D.J. et al., editors, U.S. Global Change Research Program, Wash. D.C., USA, pp.12-34.]

  • Global AAT has increased by about 1.0°C over the past 115 years (1901-2016). This period is now the warmest in the history of modern civilization. Recent years have also seen record-breaking weather extremes and the warmest years on record for the globe. These trends are expected to continue over climate timescales. Green house gas (GHG) emissions are the dominant cause of the observed warming since the mid-20th century. The largest observed changes in the U.S. have occurred in the Northeast.
  • Heavy rainfall is increasing in intensity and frequency across the U.S. and is expected to continue to increase. The largest observed changes in the U.S. have occurred in the Northeast.
  • Heat waves have become more frequent in the U.S. since the 1960’s, while extreme cold temperatures and cold waves are less frequent. Recent record-setting hot years are projected to become common in the near future for the U.S., as AATs continue to rise. Over the past 115 years, the AAT increased 1.0°C and is expected to increase 1.4°C.
  • The magnitude of climate change will depend primarily on the amount of GHGs (especially CO2) emitted globally. Without major reductions in emissions, the increase in global AAT relative to pre-industrial times could reach 5°C by the year 2100. With significant reductions in emissions, the increase in global AAT could be limited to 2°C or less.

The Intergovernmental Panel on Climate Change (IPCC) reports that the increase in global AAT has increased the the frequency and magnitude, strengthening evidence of how an increase in global AAT of 1.5°C or more could impact natural and human systems. Their climate models project robust differences in regional climate between present-day and global warming up to 1.5°C, especially for temperature extremes including eastern North America. [IPCC, 2018: Global Warming of 1.5°C Above Pre-industrial Levels and Related Global GHG Emission Pathways, in the Context of Strengthening the Global Response to the Threat of Climate Change, Sustainable Development, and Efforts to Eradicate Poverty, p.177.]The report concludes that limiting global warming to 1.5°C would limit globally risks and reduce the probability of heavy precipitation events, extreme drought, precipitation deficits, and water availability. More germane to the proposed RGGI, the report concludes:

“Though CO2 dominates long-term warming, the reduction of warming short-lived climate enforcers, such as methane and black carbon, can in the short-term contribute significantly to limiting warming  to 1.5°C above pre-industrial levels. Reductions of black carbon and methane would have substantial co-benefits, including improved health due to reduced air pollution. This, in turn, enhances the institutional and socio-cultural feasibility of such actions.” [IPCC, 2018, Op. cit., p.316]

Particulate emissions have contributed to soil quality impacts at locations where they are “consistently present in the environment of the region of the site and which has not been influenced by localized human activities”, i.e., not point source of pollution involved.  Joining the RGGI would provide a co-benefit as mentioned in the IPCC report. Research conducted by The New Jersey Department of Environmental Protection revealed that regulated toxic metal compounds were found to exceed natural background concentrations, and residential health-based soil standards due to “ambient deposition”. [Sanders, P.F.,2003, “Ambient Levels of Metals in New Jersey Soils”, NJDEP Division of Science Research and Technology, Environmental Assessment and Risk Analysis Element, Research Project Summary]. The westerly-prevailing wind direction from PA toward NJ has the potential to carry such particulate constituents, and over many years may have contributed to ambient deposition concentrations up to undesirable levels.  Efforts to reduce GHG emissions through the RGGI will increase the potential to reduce particulate emissions containing metals or other chemical constituents which may be deleterious to human health.

In closing, where I live at the junction of Delaware, Montgomery and Chester Counties, the number of air quality health alerts, due to exceeding the CAA attainment levels,  is too high during the warmest months. My children like to run for exercise when visiting me, and they are jeopardizing the health of their lungs from microscopic particles of soot and elevated ozone, especially when jogging.Accordingly, I favor joining the RGGI as a critical step forward to restoring our climate regionally as well as internationally.

Very truly,

H. Scott Laird, M.S.

RGGI Testimony-Chuck Marshall, Advocate for Climate Justice and Supporter of PA IPL

My name is Charles Marshall. I live in Paoli, PA. I was an environmental consultant for 26 years working for a small PA-based consulting firm.  Over the years our company had many contracts with U.S. EPA and OSHA performing regulatory impact analyses for air, water, safety, and hazardous workplace rules. Over the past 10 years I have been active in energy conservation and GHG emission reductions as a board member of PA IPL and as chair of the Ecology Faith in Action Team at Central Baptist Church in Wayne, PA where I obtained a PA DEP Energy Harvest Grant and installed 48 panels on the roof of our church.

Although I didn’t work on the acid precipitation rules as a consultant I followed the rulemaking for and development of the allowances program and market events as utilities reduced their acid emissions in a very successful compliance program.

My first comment pertaining to RGGI is that designing a program for GHG emissions using the acid precipitation program is wise and logical.

I have both a Masters in Environmental Science as well as an MBA (both from Drexel) and I can say that I am an environmentalist and someone interested in achieving environmental goals in a least-cost fashion.  I think that properly designed cap and trade programs can reduce large quantities of GHG in a least-cost manner while effecting a large quantity of GHG emissions. Getting a 30 % reduction by 2030 will be a major achievement. And my reading of the rulemaking for RGGI shows a very carefully designed program that takes into account some of the features of PA’s situation such as combustion of waste coal-fired units, highly impacted communities and individuals, and methods of sequestering CO2.

(skip to summary points at end)Like the acid precipitation program, a program that includes emitting sources over a large geographic area such as RGGI allows least-cost compliance not just within PA but in the larger RGGI area. I think it is good feature in the design of the allowance program of RGGI that “CO2 emissions from this Commonwealth’s power sector are not ”capped” by the CO2 emissions budget, meaning they are not limited to strictly the amount of this Commonwealth’s CO2 allowances

Cap and trade programs allow agencies to get away from the less flexible command and control strategies. By using a market-based trading mechanism it achieves least-cost means that promotes creativity for each source to comply in a way that is best for them.  

I like the feature of the proposed program to invest the proceeds resulting from the auction of CO2 allowances to further reduce CO2 emissions. There are a lot of opportunities in PA to implement solar electricity projects as witnessed in the DEP’s Office of Pollution Prevention goal to increase the % solar generation in PA from 1.0% to 10% by 2030.

I think cap and trade programs with a declining amount of allowances are more greatly accepted by this regulated community than other types of command and control strategies. The pathway for compliance is laid out, the number of compliance methods are multiple and flexible.

The rulemaking is also designed to qualify “three offset categories of landfill methane capture and destruction projects, projects that sequester carbon due to reforestation, improved forest management or avoided conversion, and projects that avoid methane emissions from agricultural manure management operations.”

The reduction of CO2 will also coincidentally reduce SO2 and NOx reductions with their related health benefits. “The public health benefits to this Commonwealth of these avoided SO2 and NOx emissions range between $2.8 billion to $6.3 billion by 2030, averaging between $232 million to $525 million per year

“For communities and employees impacted by this rulemakings and employees, auction proceeds can be used to mitigate those impacts and assist communities and families through the energy transition. This could include repowering of the existing coal-fired power plants to natural gas and investments in worker training or other community-based support programs.” This is a very good and appropriate design feature of this program.

“The modeling estimates that from 2022 to 2030, this proposed rulemaking would lead to an increase in Gross State Product of $1.9 billion and a net increase of 27,752 jobs in this Commonwealth. The Department’s modeling also indicates that investments from this proposed rulemaking would spur an addition of 9.4 gigawatts of renewable energy and result in a load reduction of 29 terawatt hours of electricity from energy efficiency projects.

The EPA also noted in the guide that banking of allowances, which this proposed rulemaking allows, provides an additional incentive to reduce emissions earlier than required. Banking provides flexibility by allowing sources to save unused allowances for use in a later compliance period when the emissions budget is lower and the costs to reduce emissions may be higher.

“residential electric consumer bills will increase by an estimated 1.5% in the short-term. This amounts to an additional $1.46 to $2.05 per month depending on the home heating source. However, the Department’s modeling shows that this minor increase is temporary. As a result of the revenue reinvestments from the auction proceeds, by 2030, energy prices will fall below business–as-usual prices resulting in future consumer electricity cost savings.

To Sum it Up the beneficial; aspects of this rule are:

  1.  Control costs for the power sector are reasonable
  2. As these costs are passed on by the power sector, the economic impact on Pennsylvanians is reasonable
  3. There will be an overall positive cost: benefit relationship for this rule assuming the allowances revenues can be invested in the ways suggested by the proposed rule  
  4. Funds can be used to aid highly impacted communities and individuals 
  5. Compliance is flexible and not command-and-control
  6. Co-control of other air pollutants like SO2 and NOX creates coincidental benefits
  7. Help provided to coal waste-fired units
  8. Banking of emissions to the future is possible under the rule
  9. Positive impact of using revenues to stimulate renewable energy
  10. Real, permanent and verifiable carbon sequestration methods of controlling CO2 emissions are built into the program as credits and positively affect other industrial sectors

Regional Greenhouse Gas Initiative

This week marks the end of the period for public comment on the Regional Greenhouse Gas Initiative (RGGI) for the PA Department of Environmental Protection. 

PA IPL members, faith leaders, and advocates of climate justice from across the state have already taken a stance and testified, written in our local papers, and signed petitions. If you would like to speak up for the CO2 Budget Trading Program there is still time. You have until Thursday, January 14th to submit your public comment.  You can find more information about RGGI at this Environmental Defense Fund website post.

You can also sign PennEnvironment’s petition here.

If you are a PA elected official, know someone who is, or you are just motivated to contact one, please consider submitting the RGGI petition for elected officials organized by the Clean Power PA Coalition. This petition needs to be signed TODAY so it can be submitted Thursday, January 14th. Please act now!

If you testified and are willing to share your testimony with our network please email it to us.

You can find the public testimonies from PA IPL’s Executive Director and other advocates of climate justice here.

If you have questions or need help speaking with elected officials please reach out to us ,or PA IPL friend and ally, Joy Bergey.

Regional Greenhouse Gas Initiative: Public Testimonies

How RGGI and Pennsylvania’s Carbon Budget Program work to reduce carbon pollutants that contribute to climate change:

  • RGGI is a multi-state, market-driven program for CO2 emissions from the electric power sector, implemented by a bipartisan group of governors.  It stretches across 10 states from Maine to Maryland, with Virginia and Pennsylvania now getting on board.
  • Under RGGI, the participating states agree on a regional limit on the carbon pollution that power plants can emit. Each state creates its own program for implementing the agreement.
  • Large carbon-emitting power plants purchase allowances equal to their CO2 emissions and can buy, sell, or trade carbon allowances within the overall cap.

In other words, power plants must pay for the dirty carbon pollution they cause, so they have an incentive to lower their emissions. If power plants reduce their emissions below their allowance, they can bank those allowances for use in the future, or sell allowances to other power plants, which creates more incentive for power plants to invest in ways to reduce their carbon emissions further.

The purchase of the allowances generates funds – as high as $300 million in a year – that could be used to support energy efficiency and renewable energy to further reduce air pollution in the state, and to help low-income consumers as well as communities that are transitioning away from fossil fuels.

PA IPL members, faith leaders, and advocates of climate justice from across the state have already taken a stance and testified, written in our local papers, and signed petitions.

Read the public testimonies of PA IPL’s Executive Director and advocates of climate justice. As we receive more testimonies, we will continue adding them to our website. If you or anyone you know would like to submit their public testimony, please email us.

RGGI Testimony-Mark Smith, Advocate for Climate Justice and Supporter of PA IPL

Good evening. My name is Mark Smith. I live in Philadelphia and am speaking to you as a citizen in support of our commonwealth becoming the eleventh state to join the Regional Greenhouse Gas Initiative.

RGGI is already a resounding success in the 10 states currently enrolled in the program reducing greenhouse gas emissions by over a third, raising $3 billion for clean energy re-investments and outpacing states not participating in the program by over 90% in emissions reductions! An analysis by Pennsylvania’s Department of Environmental Protection indicates that PA will have a similar benefit creating over 27,000 jobs and adding $1.9 billion to the state’s economy.  

The climate is changing dramatically from the burning of fossil fuels but the pollution they cause has another, more immediate effect on public health, especially for disadvantaged and people of color who tend to live in closest proximity to power plants. As a major electricity producer Pennsylvania can transform from one of the most polluting states to one that experiences a $6 billion savings in health benefits by 2030 that would include a reduction in tens of thousands of asthma attacks and fewer cases of childhood bronchitis. 

The average temperature is expected to rise by 5.4 degrees by 2050 and the number of days with a heat index above 90 degrees will increase from 8 to 40 per year. Extreme summer heat will effect urban poor and people of color inordinately, not only because they have less resources to respond, but because the heat island effect in many urban areas with higher amounts of heat absorbing concrete and asphalt can have daily temperature differences of 10 to 20 degrees compared to suburban and rural areas. The forecast increases in temperatures and changes in climate without taking action will have a major impact on Pennsylvania’s agriculture economy, as well.

RGGI will be a positive catalyst for the market forces already in action as the country transforms to sustainable methods of power generation that do not include the burning of fossil fuels. Even though the jobs created in the new energy economy will grow Pennsylvania’s overall employment numbers, it will be important to use income from RGGI to specifically address people employed in industries directly effected in the transition. Lower income groups that will be inordinately disadvantaged by climate change should have a significant portion of RGGI income made available for home repair, weatherization and relief from RGGI related rate increases.

Changes in economy and employment for Pennsylvania and the country have been constantly transforming since the early days of the nation and our ability to change along with it is part of our success. As an example, I have lived in Pennsylvania for 34 years but grew up in Ohio. Most of my ancestors arrived from Europe through the port of Philadelphia and farmed for several generations in various parts of Pennsylvania before moving to Ohio to continue farming.  My parents were the last generation to grow up on farms. As an adult, my father was employed by the local electric utility and worked with farmers in making the transition to electricity and automation in their dairy operations.

So, agriculture, industry, and the ways in which we obtain energy will continue to change. However, this is an exceptional time that requires foresight into a future that will have catastrophic results if the crisis of climate change is not met head on. Systemic changes are needed to work more effectively together as a country and support the sustainable market forces that are shaping our future. RGGI’s already proven record of success demonstrates support for business and families while dramatically curbing CO2 emissions.

I urge the Environmental Quality Board to make the adjustments recommended, affirm the Regional Greenhouse Gas Initiative, and pass it on to the Governor for implementation. Thank you for your time.