Last week PEC joined the Environmental Defense Fund in submitting comments to the Environmental Quality Board in support of the Pennsylvania Department of Environmental Protection’s (DEP) proposal to set a declining limit on carbon pollution emitted by in-state fossil fuel generating units by linking to the Regional Greenhouse Gas Initiative (RGGI).
PEC has long identified RGGI as a market-friendly, flexible platform to address CO2 emissions in the electricity sector. With a track record of success, RGGI has proven to reduce emissions, not adversely impact consumer prices, and return significant investment-ready proceeds to participating states.
A link to our complete comments is included at the end of this post, but a few highlights are called out here:
An environmental, economic, and public health imperative
Increasing heat and flooding from climate change threatens infrastructure, agriculture, recreation, natural resources, and public health throughout Pennsylvania. For a more complete picture, please see the most recent state Climate Change Impacts Assessment Report and Story Map.
Recognition of these adverse impacts and their seriousness – now and in the future – is nothing new, and our state policies have failed to keep pace with the changes needed to avert them. DEP’s proposed rulemaking is one of many needed steps, but it is a critical one.
The clean energy transition won’t wait for Pennsylvania
Market dynamics continue to shift towards cost-effective cleaner energy, making Pennsylvania’s potential linkage with RGGI particularly timely.
Major electric generators and distributors in Pennsylvania have already committed to action in line with RGGI’s emission reduction design. In fact, the vast majority of customers in Pennsylvania are served by utilities that have made emission reduction commitments. RGGI helps provide the means to beneficially reach these goals. There is a growing consensus among industry, investors, and businesses of the importance of implementing decarbonization strategies and propelling clean energy investment. Those same interests support the market-based advantages of programs like RGGI to provide flexibility and certainty in those efforts.
The looming decline of fossil-fuel-based generation across the country, including facilities here in Pennsylvania as well as neighboring states like Ohio, signals that we must take action to meet this demand and the new reality it represents. Putting in place a program that limits the overall allowable level of pollution can also ensure that the value of existing zero-emissions capacity in the state is maintained and appropriately reflected in the energy market.
With a track record of success, RGGI has proven to reduce emissions, not adversely impact consumer prices, and return significant investment-ready proceeds to participating states.
There are also viable options in place to address the potential issue of emissions leakage. Currently PJM, the regional transmission organization that coordinates the movement of wholesale electricity in all or parts of 13 states (including Pennsylvania), has a Carbon Pricing Senior Task Force examining opportunities to address this issue. As more and more states in PJM join RGGI and augment their clean energy policies, the need for regional consistency will become paramount. In addition, DEP has its own options pursuant to the state Air Pollution Control Act to account for imported power in its emission budgeting in future implementation of the proposed program.
There is more that can be done
The burdens of energy development and generation fall disproportionately to disadvantaged communities; the proposed rulemaking can lay the groundwork for several efforts to redress those inequities. These include better monitoring of local air quality, including enhanced public reporting of site- and region-specific data; and, in partnership with Department of Community and Economic Development and other appropriate agencies, identifying communities that will be impacted by the clean energy transition and implementing strategies to support workforce and regional development.
In addition, the RGGI Equity Principles developed by DEP’s Environmental Justice Advisory Board offer numerous recommendations that should be pursued, including the establishment of an inter-agency group, as feasible, to maximize coordination around RGGI and the consideration of policies and programs outside of RGGI that can be deployed to reduce air pollution and further protections for public health.
Waste coal: the good, and the not-so-good
While we recognize the remediation benefits provided by the waste coal industry in Pennsylvania, using waste coal as an energy source still produces carbon dioxide emissions and other pollutants. Our recommendations to DEP on the proposed set-aside for waste coal generation include limiting the amount of the set-aside to actual emissions; ensuring the set-aside is appropriately tailored for facilities that truly utilize legacy (pre-1982) waste coal; and phasing out the set-aside by 2030 unless DEP determines, in subsequent rulemaking, that remediation benefits are still being realized in the most environmentally and economically efficient way.
With the public comment period now closed, DEP will review the proposed rulemaking in light of information received, and issue a proposed final rulemaking by mid-summer.
The full text of PEC’s formal comments on RGGI is available here. Follow current legislation, policy proposals, and upcoming meeting dates via the PEC Bill Tracker.