RGGI’s Program Review Offers a Chance to Revisit Local Air Quality Needs


While there is substantial evidence that the Regional Greenhouse Gas Initiative (RGGI) has been very successful at reducing carbon and other emissions across the multi-state region, there is still important work to be done to document and ensure air quality improvements at the local level — especially in frontline communities that either host fossil-fuel power plants or are downwind from those plants. Since the RGGI program started 12 years ago, can we better document how air quality has changed in communities that may be affected by the continued operation of fossil energy generation? And in communities where more needs to be done, could RGGI help support local air quality improvements through expanded monitoring?

The RGGI members — 10 states across New England and the Mid-Atlantic — have a history of using a periodic, comprehensive program review to assess RGGI’s operations and ensure its economic, environmental, and equitable performance. As awareness grows of the disproportionate public health impacts in frontline communities from COVID-19 and air pollution, and as Mid-Atlantic and New England states increase their focus on ensuring greater equity in environmental programs, the 2021 program review is an ideal opportunity to consider these questions.

RGGI’s Consumer Benefit Allocation

The RGGI framework is ideally suited to address air quality concerns in frontline communities. The original agreement to develop RGGI, a 2005 memorandum of understanding (MOU) signed by member states, includes a provision for a “comprehensive review” of all aspects of the program. In 2005, RGGI states also agreed to allocate at least a quarter of their allowance revenues for “consumer benefit” or “strategic energy” purposes, which they defined broadly: “to promote energy efficiency, to directly mitigate electricity ratepayer impacts, to promote renewable or non-carbon emitting energy technologies, and to stimulate or reward investment in the development of innovative carbon emissions abatement technologies.”

Initially spurred by the consumer benefit allocation idea, RGGI states have, in fact, invested a far greater amount of their revenues in complementary policies. They have directed nearly $3 billion in proceeds from the quarterly allowance auctions back into state economies, focusing on policies that complement the program and contribute to its success.

The Need for Air Monitoring in Overburdened Communities

The 2021 program review is a good time to better understand the air quality impacts on electricity ratepayers in frontline communities. And one useful first step would be to enable better air quality monitoring at the local level.

We recommend starting with monitoring fine particle pollution that is released from unburnt fuel and from other pollutants like nitrogen and sulfur oxides which have their own health impacts. While there are other pollutants that could be monitored by more complicated and expensive technology, starting with particulates could provide a good idea of the levels of pollution coming from local power plants and from other sources like transportation or other manufacturing plants.

Fine particles are also referred to as “PM2.5,” because EPA’s public health standard addresses particles that are 2.5 microns or smaller. To get a sense of just how small that is, the diameter of a human hair is around 50 microns. The health impacts of particulates are extremely serious. More than 25 years ago, PM2.5 was demonstrated to cause premature mortality. Around 100,000 Americans per year die from fine particle pollution.

In addition, a reason for disproportionate effects of the coronavirus on certain subgroups of the public appears to be related to their long–term exposure to various types of air pollution including fine particles. In spring 2020, public health researchers at Harvard issued a study in which they found this connection between exposure to increased concentrations of PM2.5 and increases in COVID-19 death rates.

Simply investing in monitors, however, will not be enough. States will need to work with community groups to define affected communities and those locations most in need of additional monitoring. Focusing on those adjacent to power plants in RGGI’s jurisdictionmay be a start.

Today, all state and local health agencies are required to maintain monitoring networks, comprised in part by what are known as “federal reference monitors” that meet U.S. Environmental Protection Agency (EPA) requirements for equipment, quality assurance, control and location. A typical continuous PM2.5 monitor is costly and requires ongoing maintenance, an outlay of over $20,000 per year per monitor.

There are good alternatives, which are lower-cost though admittedly somewhat less accurate. A PurpleAir monitor, for example, costs around $300 and needs to be calibrated against a federal reference monitor.  PM2.5 is one pollutant that a PurpleAir monitor is designed to measure. The EPA has studied their use and calibrated them with good success.

In Denver, Colorado, the Love My Air project is an example of the type of project that would be worthwhile in the RGGI region. It is a partnership between the Colorado Department of Public Health & Environment, Denver Public Schools (over 20 of them), and the Tri-County Health Department. The City of Denver has indicated that, while there are multiple factors that influence exposure to air pollution, “schools are an ideal intervention point for sensor deployment, education and empowerment.”

Monitoring that relies on affordable technology like PurpleAir would help in quantifying the burden of particle pollution in communities. It could be used to expand state or local monitoring networks and help citizens learn more about their air quality. Support for monitoring PM2.5 would also help identify whether that pollution stems from a RGGI facility or others nearby pollution sources.

As the RGGI states undertake a comprehensive program review, of all aspects of the program, beginning this year, we encourage them to consider supporting PM2.5 monitoring. It could help RGGI states demonstrate benefits beyond reduction of carbon dioxide emissions, and better ensure that investments made with the program’s revenues are benefitting electricity ratepayers in all the communities within the region.