What We Do

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.

RGGI Testimony-David Heayn-Menendez, Executive Director, PA IPL

Good afternoon. My name is David Heayn-Menendez I am from Lewisburg and I am testifying as Executive Director of Pennsylvania Interfaith Power and Light, a statewide climate justice organization which takes climate change to be the moral and ethical issue of our time. I am here to tell you today that faith communities across PA believe we have a responsibility to each other and must take action where and when we can against climate change. Responsible planning and investment in our future is the moral expectation all citizens. Therefore, we must move forward in favor of RGGI to live our moral responsibility to truly be stewards of creation.

Every tradition teaches us to care for the earth. I believe that we are not only accountable to each other but also to God for our actions. One needs to look no further scripture for guidance. Hundreds of verses concern the environment as we are taught over and over that greater even than the creation of mankind is the creation of the heavens and the earth. 

Pennsylvania is the third-largest energy-producing state and one of the largest greenhouse gas polluter in the US. We more than any state already in RGGI have the most to gain and the greatest potential impact on climate change by joining the Initiative. The future of our state and the planet is in fair and collaborative agreements which lead to growth, a healthier environment, and a future which benefits all Pennsylvanians through better stable jobs, lower energy costs, and improved air quality. That is not to speak even of the larger effects such efforts would have on mitigating the catastrophic effects of climate change on weather events. 

My community, a river valley community, Lewisburg, sits on the banks of the Susquehanna River. We have been devastated by flooding in the past and as a member of Borough Council I am acutely aware of the edge of a knife up on which my community and countless others along the river sit waiting for the next flood, as we continue to ignore the obvious and morally right choices which our neighbors have taken to mitigate climate change. 

RGGI is a simple, cost effective, flexible and proven cap-and-invest program. Without a program like RGGI in place Pennsylvania’s carbon emissions will simply rise and continue to choke our cities and pollute our natural areas. This is not a fantasy or a radical initiative. It is one backed by data, supported by science, and one which keeps up with evident economic trends.

We can no long rely on our coal mines and steel plants. The jobs such an initiative will bring will lift thousands out of poverty, increasing the tax base, improving schools and infrastructure, and giving hard working families a better future. The States that participate in RGGI have already seen more than $2 billion in proceeds, allowing for vital and necessary reinvestment. We have a fundamental responsibility, a moral imperative, to our fellow human beings to improve our world and protect our communities and the generations to come. 

Lastly, the health costs of the fossil fuel industry have weighed heavily on Pennsylvania families and when those jobs went away towns were slowly suffocated by debt, health issues, and the lack of opportunities. 

During COVID is has become even more evident to anyone paying attention that Frontline and in particular BIPOC communities across America have suffered the most during the pandemic, and not least of all because of the air pollutants which concentrate in the areas least served by our healthcare industry. People are dying disproportionately in these communities, not because they are taking the virus any less seriously, but because the pollution we continue to pump into the air contributes to asthma, respiratory illnesses, and many other major factors in the comorbidities we have seen ravage communities this year. RGGI is one step towards addressing the systemic racial and socio-economic injustices that millions of Pennsylvanians face every day. 

A future with good jobs opportunities, thriving communities supported by a responsible government, and breathable air which doesn’t poison our lungs is what I want for my two young boys and the world they will inherit. 

The saints and the prophets of mankind have demonstrated for us throughout history the kindness, care and moral responsibility we must have for creation and for one another. The majority of Pennsylvanians are committed to becoming guardians of the earth once more and I hope the testimony you hear will guide and direct your moral compass to accept RGGI and to create a better future for us all. 


PA IPL Intern-Asteri Aliaj

This Winter Pennsylvania Interfaith Power & Light welcomed an intern into our community to help us in our work for Climate Justice. Asteri Aliaj, is a student at Bucknell University studying environmental engineering. She has been involved in faith and climate organizations including Sunrise and Bread for the World. Asteri is an advocate for food, climate and social justice!

The work she has done for PA IPL will help us launch several initiatives in 2021 and reach out to new congregations and communities. Next semester she will be be missed while she is away studying at Duke University but we look forward to her return to PA soon.

This Spring and Fall we hope to connect with new interns to carry on her work and support the growth of local chapters. You can find the Google Form to apply for an internship here and on our Facebook page.