On February 16, the Independent Regulatory Review Commission submitted its comments to the Environmental Quality Board on the proposed regulation establishing a Carbon Pollution Reduction Program covering power plants consistent with the Regional Greenhouse Gas Initiative.
The IRRC’s 9-page comments summarized many of the comments it received from legislators, environmental groups, the public and other interested stakeholders supporting and opposing the regulation and asked the EQB to respond to those comments, as they typically do.
In several areas, the IRRC went a step further and “encouraged” the EQB to consider several specific changes to the regulations. They include--
-- Add More Environmental Protection Provisions: “Legislators and organizations that advocate for environmental protection, renewable energy, energy efficiency, low-income residents and environmental justice concerns have provided comments in support of the rulemaking. Many individuals and businesses have provided similar comments.”
“Some of the comments from these organizations have provided suggestions for amending the regulation to provide further environmental protections. These suggestions include: modifying or eliminating set-aside allowances for certain industries; inclusion of data collection mechanisms to ensure emissions are not shifted to generation facilities that fall below the 25 megawatt threshold of the rulemaking because the facilities could have a negative impact on environmental justice communities; and ensuring that imported power does not contribute to leakage.
“We encourage the EQB to consider all of the recommendations provided by commentators as a means of further protecting the public health, safety and welfare of citizens of the Commonwealth and its natural resources and meeting the goal of this rulemaking.”
-- Seek Authority For Broader Use Of Action Proceeds: In the RAF [Regulatory Analysis Form], the EQB projects that 31 percent will be used for energy efficiency projects, 32 percent will be used for renewable energy projects and 31 percent will be used for greenhouse gas abatement.
“Many of the commentators that support the rulemaking provided suggestions on how the auction proceeds could be allocated. Some of the suggestions would appear to be outside of the parameters established by 25 Pa. Code Chapter 143. Since potential use of the proceeds is not a part of this rulemaking process, we cannot comment on it.
“However, we agree with comments submitted by the Pennsylvania [PUC] Office of Consumer Advocate that suggest the DEP should “seek further authority” to allow for a broader use of the proceeds. Alternatively, the DEP could initiate a rulemaking to amend existing Chapter 143 to allow for a broader use of the proceeds.”
[Note: As part of the FY 2021-22 budget proposal, Gov. Wolf proposed establishing an Energy Communities Trust Fund to ease transition of workers and communities impacted by power plant closures. Read more here.]
-- Delay Implementation For 1 Year To Allow More Time To Adjust Business Plans: “... we ask EQB to consider delaying the implementation of the rulemaking for one year. This additional time would allow the regulated community an opportunity to adjust their business plans to account for the potential increased costs associated with Pennsylvania joining RGGI.”
The IRRC did not request the EQB to delay adoption of the regulation.
Click Here for a copy of the IRRC comments. Click Here to see comments submitted TO the IRRC.
Visit DEP’s Regional Greenhouse Gas Initiative webpage to learn more about the proposal.
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[Posted: February 17, 2021] PA Environment Digest
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