Policy Memo: An Environmental Justice Analysis Can Accelerate Carbon Progress in Pennsylvania

To: Patrick McDonnell, Secretary, Pennsylvania Department of Environmental Protection
From: Nikita Naik, Senior Researcher, Food & Water Watch
Subject: DEP Must Investigate Potential Environmental Justice Impacts of RGGI

Issue Summary: Vulnerable communities such as the poor and people of color have long borne pollution burdens at higher rates than the rest of the population and are at higher risk of climate change impacts. The Regional Greenhouse Gas Initiative (RGGI) cap-and-trade program, which Pennsylvania is considering joining, threatens to further burden vulnerable communities in the state. Market-based mechanisms can exacerbate existing pollution disparities and base pollution control on the bottom line rather than environment and health. Furthermore, there is evidence that RGGI and the California cap-and-trade program increase pollution for communities with more people of color and lower-income populations. 
In order to fully assess these potential impacts, I ask that the Pennsylvania Department of Environmental Protection conduct an environmental justice and equity analysis of RGGI. 

Background: Discriminatory laws and practices have placed disproportionate pollution burdens on vulnerable communities for decades.  Persistent pollution hot spots in communities of color, and in low-income and Black neighborhoods in particular, have seen virtually no improvement over the years, with many of the clean air achievements of the past seven decades occurring in whiter, higher-income areas.   Moreover, these populations will bear the worst impacts of climate change.  Cap-and-trade programs threaten to exacerbate these underlying disparities. 

A 2019 analysis I conducted on RGGI power plants in all participating states found that there are environmental justice impacts associated with the program. In this analysis, I first found evidence of discriminatory siting, with RGGI power plants located in areas with more vulnerable populations (see link). Next, I found evidence that RGGI further widens these underlying inequalities: neighborhoods that experienced net increases in CO2 pollution from surrounding cap-and-trade facilities had disproportionately more lower-income populations and people of color than neighborhoods that experienced net decreases in CO2 pollution (in the same research). These disparities widened further when incorporating localized public health pollutants such as fine particulate matter: neighborhoods that experienced net increases in both CO2 and fine particulate matter had even higher proportions of lower-income and non-white populations than neighborhoods that experienced net decreases in both these pollutants. 

These disparities have also been found in another cap-and-trade programs. In 2018, University of California scientists found that communities that experienced net increases in GHGs and local pollution had disproportionately more people of color and lower-income populations than communities that experienced net decreases in these pollutants under the California cap-and-trade program.  

Thus, if Pennsylvania joins RGGI, the state’s most vulnerable populations may be at risk of experiencing increases of harmful pollution in their communities.
 Recommendation: The DEP recently published an analysis that concluded that the program would cut emissions and save money and lives. Furthermore, their website posits that the program would actually improve air quality in low-income and environmental justice communities.  However, these claims hold no weight without a formal analysis. DEP should more closely examine the potential impact of the program on a community-level basis and see what neighborhoods might experience increases in pollution (which will be a given under cap-and-trade), as well as their demographics. 

Before Pennsylvania proceeds with its move to join RGGI, the state must fully consider whether or not the program may increase power plant pollution in already over-burdened communities. The state should also consider programs that would more effectively reduce local air pollution, including a stricter state renewable portfolio standard, tightening pollution standards, and improving monitoring and enforcement of current federal and state air pollution laws, as well as programs that specifically target pollution control and clean energy growth in environmental justice communities.