Secretary Ben Grumbles Maryland Department of the ...

[Pages:3]Secretary Ben Grumbles Maryland Department of the Environment Email: ben.grumbles@

May, 17 2017

Chairman Kevin Hughes Maryland Public Service Commission Email: kevin.hughes@

Mary Beth Tung Maryland Energy Administration Email: marybethtung@

CC: Tad Aburn (george.aburn@); Brian Hug (brian.hug@); Luke Wisniewski (luke.wisniewski@); Marissa Gillett (marissa.gillett@)

RE: Environmental Justice Analysis of the Regional Greenhouse Gas Initiative

Secretary Grumbles, Chairman Hughes, and Director Tung:

We are writing to follow up on comments submitted in 2016 that requested an environmental justice (EJ) analysis of the pollution and development impacts of the RGGI program and the equitable distribution of funds resulting from RGGI auctions. With the RGGI states undergoing additional analysis and evaluation in 2017 we wish to follow up on this topic and respectfully request a meeting with you and pertinent staff to discuss this in greater detail.

In particular, we can provide supplemental information on: ? A framework for an environmental justice impact analysis of the RGGI program that includes an evaluation of pollution and development impacts of the program ? The development of a report on the distribution of RGGI proceeds that highlights an achievable equity-focus for those funds.

The report must define impacted communities and indicators, and identify their locations. Additionally the report should build upon the work of established bodies such as the Commission on Environmental Justice and Sustainable Communities and Maryland Commission on Climate Change to determine, with communities and key stakeholders:

? The definition of a frontline community ? The key indicators of a frontline community (i.e. health, energy use, location and density of

energy generators, cost of energy, climate vulnerability, cumulative risk, etc) ? The location of those communities

Further, the study should include, but does not need to be limited to: ? An analysis of the current RGGI policy and subsequent policy proposals that:

o Identifies inequities in the siting of energy generation facilities in the state and indicates where frontline communities are disproportionately exposed to pollution from energy generation

o Highlights existing factors (i.e. social determinants of health) in a community that make residents less able to respond to additional pollution burdens

o Pinpoints where emissions might increase and where there is greatest need for energy efficiency, job creation, improved community resilience

o Identifies where, if at all, allowance trading has or could have a negative impact on overburdened communities

o Determines the proximity of regulated sources to frontline communities and clearly identifies the carbon and co-pollutants associated with the facilities

? An analysis of the distribution of RGGI proceeds that seeks to answer the following questions: o What is the geographic distribution of the proceeds at least by program? The answer to this question would aim to determine any aggregated patterns in favor of or contravention to frontline communities, including communities of color, as well as any nexus between higher energy costs, and nearby regulated facilities? o What is the distribution of proceeds by organization? Are these proceeds going to forprofit and non-profit organizations in frontline communities? Are there any state agencies, grantees or organizations using RGGI funds who train and hire residents from frontline communities to address energy efficiency and community resiliency needs? o How are the proceeds distributed across income categories? o What evaluation metrics are used to award RGGI auction funds and to assess impact of RGGI-funded programs; and do they include consideration of environmental justice impact and high-energy burden communities? o Is there an opportunity to engage stakeholders of concern in the creation of new programs or any efforts being made to align underserved communities with existing programs? o How are the programs funded by RGGI proceeds communicated to the public and how might they be improved to target frontline communities?

An initial EJ analysis of RGGI would establish a baseline for pollution burden and allow the state and stakeholders to understand the impact of pollution caps and programs. Once a baseline is established, ongoing evaluation and analysis should be used to track the impact over time.

We believe that it is important for Maryland to perform outreach and integrate feedback from environmental justice communities prior to finalizing any EJ and equity analyses. The state should host initial informational and listening sessions before the first draft of a report as well as mid-point check-ins on drafts and public release of the final, official product. This would help ensure that any such study would incorporate the communities' recommendations on what they want studied and evaluated.

We appreciate your time and consideration on this matter and look forward to working with you to make RGGI a success for Maryland as we strengthen it out through 2030. Please respond to let us know if you are available to meet in person to discuss these matters further.

Sincerely,

Chris Espinosa Executive Vice President & COO GreenLatinos

Destiny Watford Free Your Voice A Human Rights Committee of United Workers

Josh Lynch Director of Field Strategy Green For All

Josh Tulkin Director Sierra Club Maryland Chapter

Ramon Palencia-Calvo Program Director Chispa Maryland Maryland League of Conservation Voters

Sacoby Wilson, PhD, MS Assistant Professor Director, Community Engagement, Environmental Justice, and Health (CEEJH) Maryland Institute for Applied Environmental Health School of Public Health University of Maryland-College Park

Tamara Toles O'Laughlin Executive Director Maryland Environmental Health Network

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