The PA Environmental Council President and CEO Davitt Woodwell Tuesday submitted comments on DEP’s Climate Change Action Plan calling for an 80 percent reduction in greenhouse gas emissions by mid-century and the use of the “deep decarbonization” strategy to reduce emissions from the electric generation sector.

A copy of PEC’s comments is available online.  The text of the Council’s cover letter follows--

On behalf of the Pennsylvania Environmental Council (PEC), I am writing to express our support of the state’s efforts to address greenhouse gas (GHG) emissions, and to submit the following comments on the Draft 2015 Climate Change Action Plan Update.

We commend the Climate Change Advisory Committee for drafting such a comprehensive update.

One concern we have is that the plan does not set a target for GHG reductions.  While not explicitly required by law, without a specific target, and timeline for achieving it, the recommendations in the plan are of limited significance.

Only with a meaningful, and actual target, can decision makers then assess what combination of actions from the plan will be the most cost-effective means for achieving sufficient GHG reductions.

There is general consensus among experts that they goals of the [EPA] Clean Power [Climate] Plan will not be sufficient to achieve the carbon reductions necessary to prevent irreparable harm from climate change.

Strategies chosen to meet a 20 or 30 percent goal many not be the most cost-effective options for reaching a 50 or 80 percent target.  In fact, they could lock us into pathways that make it more expensive to eventually achieve deeper reductions.

At a minimum, the state should be focusing on a goal of 80 percent reduction in GHG emissions by mid-century.  PEC recommends a strategy of deep decarbonization, with a particular focus on electricity generation and use, which has historically been the largest contributor of GHG emission in the state accounting for over one-third of statewide gross GHG emissions in 2012.

The results of the Center for Climate Strategies’ macroeconomic analysis dispel the myth that climate protection is at odds with economic goals.  While not all actions are ranked equally, most recommendations result in increased household and individual welfare.

Comments on specific recommendations within the plan follow.  Thank you for the opportunity to review and comment on this plan.

Sincerely,

Davitt Woodwell, President & CEO

Pennsylvania Environmental Council

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