Lctter - irrc.state.pa.us

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$3174 Stephen Hoffman ftr,n Lctter b 1.2? From: Calvin Smith <[email protected]> I Sent: Friday, August 27, 2021 1:47 PM i To: IRRC Subject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274 AUG 2 7 ?021 Ifldependenc Reguiatoi’y ev’pw c,10n CAUTION: **E)CERNAL SENOER This email originated from outside of the organization. Do not click links or open attac m s unless you recognize the sender and know the content is safe. Dear Independent Regulatory Review Commission. I strongly urge you to support the final draft regulation, Carbon Dioxide (C02) Budget Trading Program. to amend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and a public hearing is scheduled for September 1,2021. This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generating units (EGU5). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking will not only greatly impact the environment, it will also benefit the economy. improve human health. and protect agriculture and tourism. According to the United States Energy Information Administration. Pennsylvania generates the fifth most C02 emissions from EGUs in the country. C02 emissions are a major contributor to regional climate change impacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so. ultimately help this Commonwealth in terms of human health, environmental impacts. and our economy. Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to be approved and linalized. Some of these criteria are already explained quite well in the Department of Environmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need further discussion. Some of these criteria include, statutory authority, clarity, feasibility, and reasonableness, supported by acceptable data, impacts to small businesses and meeting regulatory requirements. For purposes of this letter, I will focus on the great public health, environmental, and economic benefits the final draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects. Public Health, Safety and Welfare: Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma and infections by increasing irritants in the air, such as pollen and mold concentrations. Further, disease-bearing mosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused by climate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater risk for deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines. in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lower incidences in emergency department visits for asthma. acute bronchitis. upper and lower respiratory symptoms. lost workdays, hospital admissions and more. Overall, this C.O2 reducing program created by the regulations is an opportunity to protect Pennsylvanians from the worst effects of climate change. Effect on this Commonwealth’s Natural Resources: Adverse impacts from climate change are already being experienced throughout Pennsylvania. Higher temperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such 1

Transcript of Lctter - irrc.state.pa.us

Page 1: Lctter - irrc.state.pa.us

$3174

Stephen Hoffman ftr,n Lctter b — 1.2?

From: Calvin Smith <[email protected]> ISent: Friday, August 27, 2021 1:47 PM i

To: IRRCSubject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274 AUG 2 7 ?021

Ifldependenc Reguiatoi’yev’pw c,10n

CAUTION: **E)CERNAL SENOER This email originated from outside of the organization. Do not click links or open attac m sunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission.

I strongly urge you to support the final draft regulation, Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and apublic hearing is scheduled for September 1,2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGU5). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy. improve human health. and protectagriculture and tourism.

According to the United States Energy Information Administration. Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so.ultimately help this Commonwealth in terms of human health, environmental impacts. and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to beapproved and linalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need further discussion. Someof these criteria include, statutory authority, clarity, feasibility, and reasonableness, supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter, I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health, Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air, such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines.in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma. acute bronchitis. upper and lower respiratory symptoms.lost workdays, hospital admissions and more. Overall, this C.O2 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

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as the summer of 2018. and increased periods of drought. heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is C02.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants. and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprccipitation and drought. both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningftil yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.[ligher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate, the farmers will have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further, forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to CO2 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently. during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical, and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth. water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native fish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. However, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically, ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce CO2 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The final draft rulemaking will not only combat climate change. as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of$1.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example, asthma), fewer pest related problems in agriculture and humans (such as Spotted Lantemflies andtick-borne diseases).

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This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound $339 million in 2022 and around $190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefticiency. renewable energy, and greenhouse gas (GHG) abatement. Ultimately, these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical. innovative, and expansive, regional mar[et and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more. I urge you to consider approving and finalizing the rulemaking.

Sincerely.Calvin Smith1020 Topview DrHarrisburg, PA [email protected]

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Stephen Hoffman

From: William Davidson <William.Davidson.4729901 [email protected]>Sent: Friday, August 27, 2021 1:18 PMTo: IRRCSubject: I Support Final Draft Regulation SO Pa. 8, 6212, IRRC #3274

CAUTION: **EXTERNAL SENDER This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission.

I strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and apublic hearing is scheduled for September 1, 2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGUs). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy, improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration, Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so,ultimately help this Commonwealth in terms of human health, environmental impacts, and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to beapproved and finalized. Some of these criteria are already explained quite well in the Department of’Environmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need further discussion. Someof these criteria include, statutory authority, clarity, feasibility, and reasonableness, supported by acceptabledata. impacts to small businesses and meeting regulaton’ requirements.

For purposes of Ihis letter, I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health, Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air, such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and Ike longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines.in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma, acute bronchitis, upper and lower respiratory symptoms,lost workdays. hospital admissions and more. Overall, this C02 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

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as the summer of 2018, and increased periods of drought. heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to 0KG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants, and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought. both of which pose great difficulties for Pennsylvania Ihimers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.I ligher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate, the farmers wiLl have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further, forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to C02 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently. during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical, and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth. water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native lish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. However, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically, ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizens interests in mind and acting with prudence and loyalty by approvingregulations that reduce C02 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The final draft rulemaking will not only combat climate change, as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of $1.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected. drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example, asthma), fewer pest related problems in agriculture and humans (such as Spotted Lanternflies andtick-borne diseases).

2

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This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound S339 million in 2022 and around $190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety’ of beneficial ways such as investing in energyefficiency, renewable energy. and greenhouse gas (GHG) abatement. Ultimately. these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and oflèring low-cost electricity to theurid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical, innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those hanns created by GHGs.

For these reasons and more. I urge you to consider approving and finalizing the rulemaking.

Sincerely,William Davidson2421 Heilmandale RdJonestown, PA 17038billdavidsonjrU’comcast.net

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Stephen Hoffman

From: Calvin Smith <[email protected]>Sent: Friday, August 27, 2021 1:09 PMTo: IRRCSubject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274

CAUTION: tEXTERNAL SENDER” This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission,

I strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and apublic hearing is scheduled for September 1,2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGUs). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy. improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration. Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so.ultimately help this Commonwealth in terms of hui an health, environmental impacts. and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to beapproved and finalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulaton Analysis Form (RAF) and do not need further discussion. Someof these criteria include, statutory authority, clarity, feasibility, and reasonableness. supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter. I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health. Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air, such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines,in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerineidences in emergency department visits for asthma, acute bronchitis. upper and lower respiratory symptoms.lost workdays, hospital admissions and more. Overall, this CO2 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Eflèct on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

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as the summer of 2018, and increased periods of drought, heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants. and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought. both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.higher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate. the farmers will have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further, forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to C02 emissions. 1-ligher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdiseasc and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently. during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical. and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth, water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native fish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. 1-lowever, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically, Article1, Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce CO2 will help to conserve and maintain our air and waters for generation yet to come asrcquired by the state Constitution.

Economic Impacts:The final draft rulemaking will not only combat climate change, as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of$I.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example. asthma), fewer pest related problems in agriculture and humans (such as Spotted Lantemiies andtick-borne diseases).

2

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This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound $339 niillion in 2022 and around $190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of benelicial ways such as investing in energyefficiency. renewable energy, and greenhouse gas (GHG) abatement. Ultimately, these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy ill help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical. innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more. I urge you to consider approving and finalizing the rulemaking.

Sincerely.Calvin Smith1020 Topview DrI-Iarrisburg, PA [email protected]

3

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Stephen Hoffman

From: Karen K Smith <[email protected]>Sent Friday, August 27, 2021 12:56 PMTo: IRRCSubject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274

CAUTION: **EWFERNAL SENDER This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe. -—

Dear Independent Regulatory Review Commission.

I strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and apublic hearing is scheduled for September 1.2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGUs). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy. improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration, Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so,ultimately help this Commonwealth in terms of human health, environmental impacts, and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to heapproved and finalized. Sonic of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need ftirther discussion. Someof these criteria include, statutory authority, clarity, feasibility, and reasonableness, supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter. I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health, Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air. such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke. heart failure and more. Data within the RAF. specifically Table 4 outlines.in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma. acute bronchitis, upper and lower respiratory sympioms.lost workdays. hospital admissions and more. Overall, this C02 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

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as the summer of 2018, and increased periods of drought. heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants. and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought, both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to dif’ficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.Higher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate. the farmers will have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further. Ibrests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to C02 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently, during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical. and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth. water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmild algal blooms. 1-ligher temperatures in local waters also leads to problems withaquatic species spawning and more. Native fish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. However, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically. ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce CO2 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The final drafi rulemaking will not only combat climate change. as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of $1.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healtheare(for example, asthma), fewer pest related problems in agriculture and humans (such as Spotted Lantemfiies andtick-borne diseases).

2

Page 15: Lctter - irrc.state.pa.us

This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound $339 million in 2022 and around $190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefficiency, renewable energy. and greenhouse gas (GHG) abatement. Ultimately, these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical, innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more. I urue you to consider approving and finalizing the rulemaking.

Sincerely.Karen K Smith1029 Topview DrHarrisburg, PA [email protected]

3

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Page 17: Lctter - irrc.state.pa.us

Stephen Hoffman

From: Karen K Smith <KarenK.Smith.472987634@p2aco>Sent Friday, August 27, 2021 12:55 PMTo: IRRCSubject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274

CAUTION: “EXTERNAL SENDER This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission,

I strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28, 2021. and apublic hearing is scheduled for September 1, 2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGU5). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy. improve human health. and protectagriculture and tourism.

According to the United States Energy Information Administration. Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so.ultimately help this Commonwealth in temis of human health, environmental impacts. and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to beapproved and finalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (lt&F) and do not need further discussion. Sonicof these criteria include, statutory authority, clarity, feasibility, and reasonableness, supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter, I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health. Safety and Welfare:Climate change will impact human health in a variety of ways. It infiames respiratory problems like asthma andinfections by increasing irritants in the air. such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines.in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma, acute bronchitis. upper and lower respiratory symptoms.lost workdays. hospital admissions and more. Overall, this C02 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

Page 18: Lctter - irrc.state.pa.us

as the summer of 2018, and increased periods of drought, heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants, and more.

By changing the trajectory of climate change. we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought. both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.Higher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate. the farniers will have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further. forests and plants that typically help by naturally reducing carbon dioxide, can also becomeovenvhelmed and stressed if changes are not made to C02 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently, during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical, and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth. water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native fish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport tishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogcns. Many of these incidences are currentlyhappening throughout the state and is not uncommon. However, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution. specifically. ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce C02 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The final draft rulemaking will not only combat climate change, as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of$l.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example. asthma). fewer pest related problems in agriculture and humans (such as Spotted Lantemflies andtick-borne diseases).

2

Page 19: Lctter - irrc.state.pa.us

This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound $339 million in 2022 and around $190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefficiency. renewable energy, and greenhouse gas (GHG) abatement. Ultimately, these investments also haveripple effects in that the proceeds to invest in energy efliciency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical. innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more, I urge you to consider approving and finalizing the rulemaking.

Sincerely’.Karen K Smith1029 Topview DrHarrisburg, PA [email protected]

3

Page 20: Lctter - irrc.state.pa.us
Page 21: Lctter - irrc.state.pa.us

Stephen Hoffman

From: Karen K Smith <[email protected]>Sent: Friday, August 27, 2021 12:55 PMTo: RRCSubject: I Support Final Draft Regulation SO Pa. B. 6212, IRRC #3274

CAUTION: **E)(TERNAL SENDER** This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission,

I strongly urge you to support the final draft regulation, Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and apublic hearing is scheduled for September 1, 2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-tired electric generatingunits (EGUs). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy, improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration. Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so.ultimately help this Commonwealth in terms of human health, environmental impacts, and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to heapproved and finalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need further discussion. Sonicof these criteria include, statutory authority, clarity, feasibility, and reasonableness, supported by acceptabledata. impacts to small businesses and meeting regulatory requirements.

For purposes of this letter, I will focus on the great public health, environmental, and economic benetits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health. Safety and Welfare:Climate change will impact human health in a variety of ways. It infiames respiratory problems like asthma andinfections by increasing irritants in the air, such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines.in detail, avoided health impacts b’ 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma, acute bronchitis, upper and lower respirator symptoms.lost workdays, hospital admissions and more. Overall, this CO2 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

Page 22: Lctter - irrc.state.pa.us

as the summer of 2018. and increased periods of drought, heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants. and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought, both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.I ligher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate. the farmers will have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further, forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to CO2 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently, during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical, and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth. water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native lish may need to migrate to cooler areas to sun’ive. impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. 1-lowever, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution. specifically, ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce C02 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The linal draft rulemaking will not only combat climate change. as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of$J .9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactifil to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more, The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example, asthma). fewer pest related problems in agriculture and humans (such as Spotted Lanternflies andtick-borne diseases).

2

Page 23: Lctter - irrc.state.pa.us

This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound S339 million in 2022 and around £190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefficiency. renewable energy, and greenhouse gas (GHG) abatement. Ultimately. these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help olTset anypotential increased costs to electricity prices by decreasing peak demand and oflëring low-cost electricity to theEnd.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and Ibod security to our health and welfare. Reducing C02through a practical, innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GI-IGs.

For these reasons and more. I urge you to consider approving and finalizing the rulemaking.

Sincerely.Karen K Smith1029 Topview DrHarrisburg, PA 17112cksmithó’21’verizon.net

3

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Stephen Hoffman

From: Doris Adebanjo <[email protected]>Sent: Friday, August 27, 2021 10:24 AMTo: IRRCSubject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274

CAUTION: “EXTERNAL SENDER” This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission.

I strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021. and apublic hearing is scheduled for September 1.2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGUs). with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy. improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration. Pennsylvania generates the fifTh most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so,ultimately help this Commonwealth in terms of human health, environmental impacts. and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order fbr a regulation to beapproved and finalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need further discussion. Sonicof these criteria include, statutory authority, clarity. feasibility, and reasonableness, supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter. I will focus on the great public health, environmental, and economic benelits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health. Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air. such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RALF. specifically Table 4 outlines.in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma, acute bronchitis. upper and lower respiratory symptoms.lost workdays. hospital admissions and more. Overall, this C02 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

Page 26: Lctter - irrc.state.pa.us

as the summer of 2018. and increased periods of drought, heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants, and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought, both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.Higher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate, the farmers will have to include purchasing extensive, and potentiallyexpensive, cooling systems to protect the animals.

Further, forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to C02 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently, during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical. and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth. water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphiis drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native fish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. I-lowever, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically, ArticleI, Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce C02 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The linal draft rulemaking will not only combat climate change, as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of$I.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example, asthma), fewer pest related problems in agriculture and humans (such as Spotted Lantemflies andtick-borne diseases).

2

Page 27: Lctter - irrc.state.pa.us

This final draft ruLemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound $339 million in 2022 and around $190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefficiency. renewable energy. and greenhouse gas (GHG) abatement. Ultimately, these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical. innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more. I urge you to consider approving and finalizing the rulemaking.

Sincerely.Doris Adebanjo508 Benson LnChester Springs, PA 19425smi lesalot95yahoo .com

3

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Stephen Hoffman

From: Lynn Sullivan < [email protected]>Sent: Friday, August 27, 2021 9:16 AMTo: IRRCSubject I Support Final Draft Regulation 50 Pa. 8. 6212, IRRC #3274

CAUTION: **EXTERNAL SENDER This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission.

I strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28, 2021, and apublic hearing is scheduled for September 1, 2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGUs), with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy. improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration, Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so.ultimately help this Commonwealth in terms of human health, environmental impacts. and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to beapproved and finalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need further discussion. Someof these criteria include, statutory authority, clarity. feasibility, and reasonableness, supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter, I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health. Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air. such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specilically Table 4 outlines,in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma, acute bronchitis, upper and lower respiratory symptoms.lost workdays, hospital admissions and more. Overall, this C02 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

1

Page 30: Lctter - irrc.state.pa.us

as the summer of 2018, and increased periods of drought. heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is CO2.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants. and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought, both of which pose great difliculties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.I ligher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate, the farmers will have to include purchasing extensive. and potentiallycxpensive. cooling systems to protect the animals.

Further, forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to CO2 emissions. Higher temperatures and ground levelozonc can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently. during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical, and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth, water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphia’s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. 1-ligher temperatures in local waters also leads to problems withaquatic species spawning and more. Native fish may need to migrate to cooler areas to survive, impactingPennsylvania’s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. However, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically, ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce CO2 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The linal draf’t rulemaking will not only combat climate change, as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of$1.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example. asthma), fewer pest related problems in agriculture and humans (such as Spotted Lanternflies andtick-borne diseases).

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This final drali rulemaking is a two-prong approach. It is both a market-based trading program as welt as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound S339 million in 2022 and around S190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefficiency, renewable energy. and greenhouse gas (GI-IG) abatement. Ultimately. these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical, innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more. I urge you to consider approving and finalizing the rulemaking.

Sincerely.Lynn Sullivan61 8 Flaws AveNonistown. PA 19401lynnsullivanverizon.net

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Stephen Hoffman

From: Joanna Roy <JoannaRoy.41 6083161 @p2a.co>Sent: Friday, August 27, 2021 12:32 PMTo: RRCSubject: I Support Final Draft Regulation 50 Pa. B. 6212, IRRC #3274

CAUTION: *E)CERNAL SENDER’ This email originated from outside of the organization. Do not click links or open attachmentsunless you recognize the sender and know the content is safe.

Dear Independent Regulatory Review Commission,

1 strongly urge you to support the final draft regulation. Carbon Dioxide (C02) Budget Trading Program. toamend 25 Pa. Code Chapter 145. The final regulation was submitted to the Commission on July 28. 2021, and apublic hearing is scheduled for September 1,2021.

This rulemaking would establish a program to limit the emission of C02 from fossil-fired electric generatingunits (EGUs), with a nameplate capacity equal to or greater than 25 megawatts (MWe). This rulemaking willnot only greatly impact the environment, it will also benefit the economy, improve human health, and protectagriculture and tourism.

According to the United States Energy Information Administration, Pennsylvania generates the fifth most C02emissions from EGUs in the country. C02 emissions are a major contributor to regional climate changeimpacts. This final draft regulation and program would help reduce C02 emissions greatly and by doing so.ultimately help this Commonwealth in terms of human health, environmental impacts. and our economy.

Under the Regulatory Review Act, certain criteria must be considered and met in order for a regulation to beapproved and finalized. Some of these criteria are already explained quite well in the Department ofEnvironmental Protection’s (DEP) Regulatory Analysis Form (RAF) and do not need firther discussion. Someof these criteria include, statutory authority, clarity. feasibility, and reasonableness, supported by acceptabledata, impacts to small businesses and meeting regulatory requirements.

For purposes of this letter, I will focus on the great public health, environmental, and economic benefits thefinal draft regulation will establish to change the Commonwealth’s harmful trajectory due to greenhouse effects.

Public Health, Safety and Welfare:Climate change will impact human health in a variety of ways. It inflames respiratory problems like asthma andinfections by increasing irritants in the air, such as pollen and mold concentrations. Further, disease-bearingmosquitos and ticks spread further and live longer due to rising temperatures and milder winters caused byclimate change. Finally, higher temperatures caused by climate change put vulnerable populations at greater riskfor deadly illnesses like heat stroke, heart failure and more. Data within the RAF. specifically Table 4 outlines,in detail, avoided health impacts by 2030 from emission reductions from the regulation. This includes lowerincidences in emergency department visits for asthma, acute bronchitis. upper and lower respiratory symptoms.lost workdays, hospital admissions and more. Overall, this C02 reducing program created by the regulations isan opportunity to protect Pennsylvanians from the worst effects of climate change.

Effect on this Commonwealth’s Natural Resources:Adverse impacts from climate change are already being experienced throughout Pennsylvania. Highertemperatures and an increasing numbers of extreme weather events have led to record rains and flooding, such

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as the summer of 2018. and increased periods of drought, heat waves and large storms. All these harms can beattributed to our changing climate. One big factor in these changes is the effects of greenhouse gases and amajor contributor to GHG is C02.These impacts can cause major environmental harm in numerous ways suchas decreasing water supplies, degrading water quality, causing more disease and pests to impact our agriculture,killing native trees and plants, and more.

By changing the trajectory of climate change, we can help our agricultural community and food security in theCommonwealth. Climate change is upending normal weather patterns, leading to periods of both intenseprecipitation and drought. both of which pose great difficulties for Pennsylvania farmers. Increasedprecipitation leads to difficulty in planting crops and harvesting meaningful yields and an increase in plantdisease and destruction caused by pests. In the inverse, more frequent droughts will require an increase inirrigation to sustain crops and may lead to a large decrease in water quantity throughout the Commonwealth.Iligher temperatures also impact livestock such as dairy cows and poultry. Stress caused by heat will decreasemilk and egg production. To mitigate. the farmers will have to include purchasing extensive, and potentiallycxpcnsive. cooling systems to protect the animals.

Further. forests and plants that typically help by naturally reducing carbon dioxide, can also becomeoverwhelmed and stressed if changes are not made to CO2 emissions. Higher temperatures and ground levelozone can contribute to destroying chlorophyll, reducing survivability of tree seedlings, and increasing plantdisease and pests. These impacts to our forested and natural areas can ultimately impact outdoor recreation andtourism. Currently. during this pandemic it has been shown that outdoor recreation has been utilized much moreand has helped with both mental, physical, and emotional health.Without making changes in greenhouse gas emissions in this Commonwealth, water quantity and quality will begreatly impacted. Climate change is leading to sea level rises, which greatly impacts the Delaware River estuaryand Philadelphi&s drinking water supplies. It also leads to flooding and nutrients rushing into our local waterswhich can and has led to harmful algal blooms. Higher temperatures in local waters also leads to problems withaquatic species spawning and more. Native lish may need to migrate to cooler areas to survive, impactingPennsylvani&s sport fishing and more. Swimming and recreating in local waters can become increasingdangerous due to poor water quality from increased pathogens. Many of these incidences are currentlyhappening throughout the state and is not uncommon. However, these incidences will continue to increase ifchanges do not take place to mitigate the harm. These final draft regulations provide the change that is needed.Finally, approving these final draft regulations would be in line with our state Constitution, specifically, ArticleI. Section 27 by ensuring that Pennsylvanians are receiving their fundamental right to clean air and pure water.These types of regulations are exactly how the Commonwealth acts as a trustee in accordance with theConstitution. By keeping our citizen’s interests in mind and acting with prudence and loyalty by approvingregulations that reduce CO2 will help to conserve and maintain our air and waters for generation yet to come asrequired by the state Constitution.

Economic Impacts:The final draft rulemaking will not only combat climate change, as discussed above, but will provide a positiveeconomic value to the Commonwealth. According to the modeling shown within the RAF, between the years2022-2030 this rulemaking will lead to a Gross State Product of $1.9 billion and net increase of 27,752 jobswithin the Commonwealth. There are also many other economic benefits that may be more difficult to projectbut will certainly be impactful to the Commonwealth. These benefits will come from less emergency fundinghaving to be spent for extreme weather events, such as increased flooding, increased droughts, andtornado/storm damage. The Commonwealth will have less infrastructure damage caused by flooding, outdoorrecreation and tourism industries will be protected, drinking water issues and costs (in protecting water qualityand improving quality) will be mitigated, and more. The benefits will be felt by citizens too: fewer extremeweather events will lead to less crop and livestock damage, decrease in health-related impacts and healthcare(for example, asthma), fewer pest related problems in agriculture and humans (such as Spotted Lantemflies andtick-borne diseases).

2

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This final draft rulemaking is a two-prong approach. It is both a market-based trading program as well as aninvestment program. The RAF explains that the proceeds generated from the multistate auction may generatearound $339 million in 2022 and around S190 million in 2030 by selling C02 allowances. These proceeds canthen be distributed within the Commonwealth in a variety of beneficial ways such as investing in energyefficiency. renewable energy. and greenhouse gas (GHG) abatement. Ultimately, these investments also haveripple effects in that the proceeds to invest in energy efficiency and renewable energy will help offset anypotential increased costs to electricity prices by decreasing peak demand and offering low-cost electricity to thegrid.

The direct and indirect positive impacts that this regulation has on our Commonwealth is extensive: from oureconomy and the environment to our agriculture and food security to our health and welfare. Reducing C02through a practical, innovative, and expansive, regional market and investment program as designed by thispropose rulemaking will help mitigate those harms created by GHGs.

For these reasons and more, I urge you to consider approving and finalizing the rulemaking.

Sincerely,Joanna Roy917 S 23rd StPhiladelphia. PA 19146joa846’ggmail.com

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