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# , Clean Air Board of Central Pennsylvania: A Foith-bosocl Group ofConcornccl Citizens
528 Garland Drive, Carlisle, PA 17013 Comments 

### by Thomas Y. Au, President ofthe Clean Air Board My name is Thomas Au. Iam here today on behalfofthe Clean Air Board of Central Pennsylvania, 528 Garland Drive, Carlisle, PA 17013. In 2005 over 100 Cumberland County physicians publishedan open letterinforming the community ofthe growing dangerofair pollution. The Clean Air Board was formed to support the physicians in educating ourcommunity and advocating for cleanerair. We have grown to include hundreds of people in central Pennsylvania. The Clean AirAct requires EPA to develop regulations for categories of sources which cause or significantly contribute to air pollution which may endanger public health orwelfare. Greenhouse gas emissions endangerthe public health and welfare. The increasing evidence ofthe sensitivity of climate to rising levels of greenhouse gases, such as Superstorm Sandy and more rapid disappearance of Arctic sea ice, underscores the need forthe states to reduce greenhouse gas emissions. The Clean Air Actoffers an avenue for addressing greenhouse gas emissions and carbon pollution. Fossil fuel powerplants are responsible for40 percentofthe carbon pollution in the United States. Once EPA promulgates final standards fornewfossil fuel-fired powerplants, EPA mustalso issue guidanceto the states on howto implementthe best system ofemission reduction forexisting sources. The Clean Act requires states to develop plans, similarto state implementation plans for criteria pollutants, for existingsources of noncriteria pollutants (in this case, greenhouse gases). We believe thatthe regulations you are considering nowofferan opportunity to tailora plan specificto Pennsylvania which would accomplish the emissions reductions thatare necessary to move forward to combat climate disruption. On December2, 2013, the commissioners, secretaries and directors of environmental and energy agencies from states within the Regional Greenhouse Gas lnitiative(RGGI) commented to EPA on the agency's forthcoming regulationsforgreenhouse gases from existing power plants. While Pennsylvania is nota memberof RGGI, we believe that Pennsylvania can learn from RGGI's experience. Recent RGGI's comments encourage EPA to design its regulations to maximize energy efficiency, to allow emissions already reduced to count for compliance, and to maximize greenhouse gas reductions within a large region RGGI states have asserted (and EPA has recognized in its preamble to these regulations) thatthe RGGI initiative is an example ofthe magnitude of cuts that EPA should demand from existing sources elsewhere in the country. The experience in the RGGI states shows the magnitude ofemission reductions possible from the powersector: a projected 50% decline in tons of carbon dioxide (C02) emissions anda fossil fuel-fired generation fleet that is projected to achieve emission rates on parwith the recently proposed new source performance standardfor new electricgenerating units. Between 2005 and 2012, C02 emissions from the power sector in the nine participating RGGI states dropped more than 40%, from 162.5 million tons in 2005 to 92 million tons in 2012. The RGGI states are locking in this reduction by reducing the regional cap to 91 million tons in 2014, and

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# . reducing it an additional 2.5% each year thereafter to 78 million tons in 2020. In 2020, the RGGI emissions cap will ensure that regional emissions are 50% below2005 emission levels.' Someofthis reduction is attributable to the successful energy efficiency programs implemented by each ofthe RGGI participating states. For example, NewYork's energy efficiency programs reduced electricity use in NewYork by a cumulative total of6.5% in 2012. Also, much ofthe reduction in power sectoremissions is attributable to better utilization ofa cleaner powersystem, resulting in a substantiaiiJl.reduced system-wide emission rate. 

# """""J; RGGI state that this regional approach to emissions reduction has several benefits: 

# ,. • It is extremely cost-effective because it uses market mechanismsthat seek out the least expensive emission reductions across the region. • It provides economic benefits - creating thousands ofjobs in 3 years, reducing energy bills by over$1 billion, and adding a net benefit of $1.6 billion to the economies in the RGGI states. • It aligns with the regional nature ofthe electricity grid. The RGGI cap ensures thatemissions decrease across the region, even as it allows increases in some locations in orderto reap the benefits of more efficient sources in those locations. Although Pennsylvania is not partof RGGI, Pennsylvania utilities work in RGGI states and Pennsylvania can design a state plan which could dovetail with the RGGI initiative and which would have many of the same benefits In designing a state plan, Pennsylvania should adopt some ofthe guiding principles pioneered by RGGI. The plan should encourage real reductions in greenhouse gases through low and zero carbon generation, energy efficiency, and energy conservation. The plan should set allowance price targets that are sufficiently high and consistent to provide an adequate return to those investing in low and zero carbon electricity, aswell as energy efficiencyand conservation. The allowance auctions should generate a reliable revenue stream for state energy efficiency and adaptation programs. Pennsylvania already has several emission reduction policies in place to accomplish these goals. Expanding the Alternative Energy Portfolio Standard to more ambitious targets, increasing incentives to fund energy efficiency programs, and ramping up renewable projects are all doable right nowand should be implemented as partofa robust and sustainable economy The Commonwealth of Pennsylvania should look at ways to reduce emissions on the scale which EPA final rules contemplate. Beyond the moral imperative to reduce the industrial emissions that contribute to climate disruption, there are sound economic reasons to adopt a lowcarbon diet

1 Regional Greenhouse Gas Initiative Letter and Commentto EPA, Dec. 2, 2013, atp. 2

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