Testimony to DEP on Carbon Regulations under Section 111(d)

Tom Schuster, Sierra Club

12/9/2013

Good afternoon, my name is Tom Schuster and I represent the Sierra Club, which 

has nearly 24,000 members in Pennsylvania.

Contrary to recent comments by incoming Secretary Abruzzo, climate disruption 

clearly poses a threat to Pennsylvania. According to the Intergovernmental Panel 

on Climate Change, Pennsylvania is projected to see an increase in average 

temperature over the next century of between 3.5 and 12.5 degrees F, and an 

increase in precipitation of roughly 7%. This is expected to result in more extreme 

weather events, which will negatively impact public health and safety, 

infrastructure, and agriculture. As examples of the potential economic costs of 

this type of climate disruption, damages from 10-year floods in Allegheny County 

alone could increase to nearly $10 billion per event,1and losses due to decreased 

production in the dairy sector alone could cost the state 5,300 jobs and nearly 

$500 million per year.2 These are just two of the many issues we face; others 

include an increase in respiratory diseases and premature death due to the 

interaction of heat waves and ozone formation, introduction of new diseases, loss 

of ecological diversity and species extinction.

 

1

Choi Onelack and A. Fisher, “The Impacts of Socio- economic Development and Climate Change on Severe 

Weather Catastrophe Losses: Mid-Atlantic Region (MAR) and the US,” Climatic Change 58 (2003): 149-170.

2

Regional Economic Studies Institute, Calculations using modified IMPLANTM economic model from the Regional 

Eco- nomic Studies Institute, Towson University (PLACE: RESI, 2008).
Pennsylvania is a disproportionately large contributor to the problem. According 

to the DEP’s own 2009 climate change action plan, the Commonwealth is 

responsible for a full 1% of global carbon pollution, despite being home to less 

than 0.2% of the world’s population. President Obama has committed the United 

States to a 17% reduction in CO2 emissions by 2020 compared to 2005 levels. It is 

unknown at this time what the EPA will require from each state in terms of 

emissions reduction from existing power plants, but the Sierra Club has concluded 

that in order to meet this target for the overall economy, the electric power 

sector will have to reduce emissions by approximately 35%-40% in this timeframe. 

These reductions are consistent with scientific consensus regarding emissions 

reductions necessary to avoid the most catastrophic global temperature 

increases. 

Pennsylvania is already making progress toward this target. Between 2005 and 

2011, power sector emissions of carbon dioxide declined about 10%, due to a 

combination of factors including Act 129 requirements to increase efficiency, 

federal appliance and lighting efficiency standards, clean energy mandates in the 

Alternative Energy Portfolio Standard, fuel switching from coal and oil to natural 

gas, and overall slow economic growth. An analysis by the World Resources 

Institute3has concluded that emissions savings from these existing policies will 

level off in the coming years, meaning that additional actions are needed to 

achieve the necessary carbon emissions reductions. But our past progress will 

make these reductions feasible.

 

3

http://www.wri.org/sites/default/files/power_sector_opportunities_for_reducing_carbon_dioxide_emissions_pe

nnsylvania.pdf
Recognizing that we don’t know what the emissions reduction targets EPA will 

require at this point, we believe that state plans to implement these reductions 

should contain the following elements.

First, each existing source should be responsible for achieving some level of 

emissions reduction on site. This is important because we interpret the intent of 

Section 111d to achieve actual reductions from the sources themselves. It will 

also help protect communities from undue concentration of associated noncarbon air pollution from specific sources if some level of emissions reduction is 

required by each source. We do not know what the target emissions reductions

should be at this time. However, we do not expect that these reductions will be 

sufficient to meet the proposed overall standard.

Second, the predicted shortfall between the on-site emissions reductions and the

overall standard can be met by ramping up energy efficiency and clean energy 

requirements statewide. The EPA has indicated so far that it will allow a large 

degree of flexibility with regard to how states implement the required emissions 

reductions. This could include higher end-use efficiency targets for utilities under 

Act 129, and higher requirements for Tier I energy sources in the Alternative 

Energy Portfolio Standards, or even Pennsylvania’s participation in the Regional 

Greenhouse Gas Initiative. The EPA already offers guidance for how states can 

incorporate these types of programs into their State Implementation Plans.4

 

4

http://www.epa.gov/airquality/eere/manual.html
Third, any plan to offset existing source emissions with offsite reductions should 

focus on energy efficiency and zero-carbon generation, rather than on fuel 

switching to natural gas. Since carbon pollution limits must continue to decline 

over time, heavily investing in gas now will be detrimental to achieving long-term 

goals despite initial emissions reductions of gas relative to coal. Furthermore, 

natural gas extraction results in methane emissions that exacerbate climate 

disruption and would not be covered by this standard.

Fourth, the plan should be enforceable. The SIP should include robust provisions 

for citizen suits to enforce the standards. The development of the plan should 

also include a robust public input process so that it can incorporate the concerns 

of communities impacted by the rule and by the pollution it aims to reduce.

We appreciate the opportunity to share our thoughts at this early stage on how to 

limit carbon pollution from existing sources, and look forward to an ongoing 

dialogue on this critical rule. Thank you.