The public comment period for regulations that would enable Pennsylvania’s participation in the Regional Greenhouse Gas Initiative (RGGI) cap-and-trade program drew more than 13,000 responses by the time it closed . The proposal, championed by Governor Tom Wolf, would impose a shrinking cap on carbon dioxide emissions from electric generators.

A quick scan of the comments shows that most are in favor of the proposal, although many of those are simply form letters. Here are two recent articles describing comments both for and against Pennsylvania joining RGGI:

You can find PIOGA’s formal comment here. Our comments make the following major points:

  • Pennsylvania’s participation in RGGI without authorization by the General Assembly is unlawful.
  • Pennsylvania’s Air Pollution Control Act (ACPA) does not authorize the regulation of CO2.
  • Neither the ACPA nor Pennsylvania’s Uniform Interstate Air Pollution Agreements Act authorizes the state to participate in RGGI through this rulemaking.
  • The proposed mandatory CO2 emission allowance fees constitute taxes that the legislature has not authorized.
  • Joining RGGI is not in Pennsylvania’s best interest.

Watch for a more an in-depth discussion of PIOGA’s and other comments in the February issue of The PIOGA Press.

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