Listening sessions held by the Department of Environmental Protection around the state are gathering comments on EPA’s Clean Power Climate Plan to help Pennsylvania develop a plan for meeting those requirements.
Robert B. McKinstry, Jr., Esq, the former Maurice K. Goddard Chair in Forestry and Environmental Resource Conservation, a member of the PA Environmental Council Board and an attorney at Ballard Spahr, LLP in Philadelphia, presented these comments on his own behalf at the September 30 session--
Good afternoon, Secretary Quigley. As you know, my name is Robert McKinstry and I would like to thank the Department for providing this open process for the public to give its views on Pennsylvania’s efforts to implement the President’s Clean Power Plan.
Although you know me in many capacities, I am here today to speak as a private citizen in favor of Pennsylvania moving quickly to implement a strong and effective regulatory program to reduce emissions from the utility sector.
In 2001, when I took the Goddard Chair at Penn State, I identified reduction of greenhouse gas emissions as an area where Pennsylvania could “do well by doing good.”
However, while nine neighboring states have grown their economies and created jobs by reducing emissions from power plants by auctioning tradable emissions allowances and reinvesting the proceeds, Pennsylvania, with one percent of global greenhouse gas emissions, has missed out.
We now have the opportunity to rectify that mistake and to satisfy the trust obligations imposed by Pennsylvania’s Environmental Rights Amendment.
I urge the Department to adopt a program that puts the Commonwealth on track to reduce its emissions by 80 percent by 2050 by putting a meaningful price on carbon emissions, reinvesting the proceeds in Pennsylvania, and encouraging investment in technologies that eliminate greenhouse gas emissions from fossil sources, including new and existing nuclear, hydroelectric, solar, wind, biomass, energy efficiency, and carbon capture and sequestration.
Specifically,
— This should be a mass-based trading program applicable to all new and existing power plants, where the majority of allowances are auctioned with a meaningful reserve price and the value of the allowances are retained for investment in Pennsylvania, either as a means to fund deficits or through reinvestment in the Commonwealth. This type of program is already authorized under the Pennsylvania Air Pollution Control Act and the Environmental Rights Amendment and requires no legislative action.
— The cap on emissions should be applicable to all new and existing power plants and be set at or below EPA’s cap for existing plants only. Load growth does not require emissions increases.
— Pennsylvania should participate in EPA’s early action program to qualify for receiving additional federal allowances, whose value might otherwise be invested in other states.
— The Department must be careful to structure its program so that it does not rob Peter to pay Paul. Any program to encourage investment in emissions reduction technologies should be structured to provide investment subsidies but not operating subsidies that will undermine electricity revenues necessary to preserve our critical investment in zero emissions nuclear, hydroelectric and renewable generation sources.
Pennsylvania should avoid creating operating subsidies to certain technologies, such as might be created by expansion of the Tier 1 AEPS. Putting a price on carbon emissions and providing allowances to reduce the cost of initial investment will be much more effective.
Pennsylvania should also consider devoting some allowances to encourage reduction of use of heating oil or gas in homes, such as can be accomplished through insulation and ground source geothermal.
— Pennsylvania should adopt measures to prevent leakage, in which new fossil-fired power plants in states without a mass cap for new and existing sources might export power into Pennsylvania and both undermine all Pennsylvania power producers and potentially replace our existing valuable nuclear, hydroelectric and other zero emission domestic resources with new out-of-state power that increases emissions.
This, unlike other measures I am suggesting, might require legislation. I believe that this might be accomplished through amendment of the Alternative Energy Portfolio Standards Act to require that all electricity distributed within the Commonwealth come from facilities in states with mass-based emissions caps similar to Pennsylvania’s.
— Pennsylvania should start its program as soon as feasible without creating leakage.
This type of mass-based plan will position Pennsylvania’s economy to transition to a program that can achieve the necessary 80 percent emissions reductions by 2050. It will encourage long term investment to maintain and expand zero emissions sources.
A mass based program for the entire electricity sector is necessary to facilitate a trading program for other industries who will be regulated in the future. Pounds per megawatt hour cannot be traded with pounds per ton of steel, cement or chemicals, but tons of emissions are fungible across all industries.
The utility sector produces 80 percent of emissions from stationary sources and a robust market for the utility sector is a prerequisite for emissions trading opportunities for other industries. An auction assures that no one receives a windfall, will prevent market manipulation and will provide much needed revenues.
A complete copy of McKinstry’s comments is available online.
For more information and a schedule of the remaining sessions, visit DEP’s Climate Change webpage. Comments on the Clean Power Plan can be submitted online. Click Here to see comments submitted by others so far.
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