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Clean Air Board of Central Pennsylvania: 

A Foith-bosocl Group of Concornccl Citizens 

528 Garland Drive, Carlisle, PA 17013 

Comments by Thomas Y. Au, President of the Clean Air Board 

My name is Thomas Au. I am here today on behalf of the Clean Air Board of Central Pennsylvania, 

528 Garland Drive, Carlisle, PA 17013. In 2005 over 100 Cumberland County physicians published an 

open letter informing the community of the growing danger of air pollution. The Clean Air Board was 

formed to support the physicians in educating our community and advocating for cleaner air. We have 

grown to include hundreds of people in central Pennsylvania. 

The Clean Air Act requires EPA to develop regulations for categories of sources which cause or 

significantly contribute to air pollution which may endanger public health or welfare. Greenhouse gas 

emissions endanger the public health and welfare. The increasing evidence of the sensitivity of climate 

to rising levels of greenhouse gases, such as Superstorm Sandy and more rapid disappearance of 

Arctic sea ice, underscores the need for the states to reduce greenhouse gas emissions. The Clean Air 

Act offers an avenue for addressing greenhouse gas emissions and carbon pollution. 

Fossil fuel power plants are responsible for 40 percent of the carbon pollution in the United States. 

Once EPA promulgates final standards for new fossil fuel-fired power plants, EPA must also issue 

guidance to the states on how to implement the best system of emission reduction for existing sources. 

The Clean Act requires states to develop plans, similar to state implementation plans for criteria 

pollutants, for existing sources of noncriteria pollutants (in this case, greenhouse gases). 

We believe that the regulations you are considering now offer an opportunity to tailor a plan specific to 

Pennsylvania which would accomplish the emissions reductions that are necessary to move forward to 

combat climate disruption. 

On December 2, 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 regulations for greenhouse gases from existing power plants. While Pennsylvania 

is not a member of 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) that the 

RGGI initiative is an example of the magnitude of cuts that EPA should demand from existing sources 

elsewhere in the country. 

The experience in the RGGI states shows the magnitude of emission reductions possible from 

the power sector: a projected 50% decline in tons of carbon dioxide (C02) emissions and a 

fossil fuel-fired generation fleet that is projected to achieve emission rates on par with the 

recently proposed new source performance standard for new electric generating 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% below 2005 emission levels.' 

Some of this reduction is attributable to the successful energy efficiency programs implemented by 

each of the RGGI participating states. For example, New York's energy efficiency programs reduced 

electricity use in New York by a cumulative total of 6.5% in 2012. Also, much of the reduction in power 

sector emissions is attributable to better utilization of a cleaner power system, 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 mechanisms that seek out the least 

expensive emission reductions across the region. 

• It provides economic benefits - creating thousands of jobs 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 of the electricity grid. The RGGI cap ensures that emissions 

decrease across the region, even as it allows increases in some locations in order to reap the 

benefits of more efficient sources in those locations. 

Although Pennsylvania is not part of 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 of the 

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, as well as energy 

efficiency and 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 now and 

should be implemented as part of a 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 low carbon diet 

1 Regional Greenhouse Gas Initiative Letter and Comment to EPA, Dec. 2, 2013, at p. 2 

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