DV Journal

Last year, the Maryland General Assembly announced plans to reduce its output of carbon dioxide (CO2) emissions 60 percent by 2031. The Climate Pollution Reduction Plan was sold as a roadmap to achieve near-term climate goals and a path to reach net zero emissions by 2045, setting the tone for environmental and energy decision-making throughout the state.

The problem with this roadmap is that it leads to nowhere but disruption to the reliability of our electric supply and a higher cost to all ratepayers, including Pennsylvanians. Yes, Pennsylvania ratepayers will pay part of the costs generated by the closure of thermal generation like coal, natural gas, oil, or nuclear facilities in Maryland.

The City of Baltimore is served primarily by a coal-fired thermal electric generation facility known as Brandon Shores. Brandon Shores and the nearby Wagner facility supply approximately 2200 megawatts of thermal electricity to PJM, the organization designated by the Federal Energy Regulatory Commission (FERC) to manage the mid-Atlantic power grid and the safe and reliable flow of electricity for 65 million people from Chicago to Philadelphia and many places in between.

Talen Energy, the owner of Brandon Shores, had been discussing the conversion of the facility from coal to oil. In mid-2023, unbeknownst to PJM, Talen entered into an agreement with the Sierra Club to close Brandon Shores in June 2025, taking enough electricity to power about 2 million homes from the supply available to the grid.

PJM analyses show that without proper upgrades, the deactivation of Brandon Shores would cause a severe voltage drop across seven PJM zones, leading to a widespread reliability risk not only in Maryland but in the surrounding zones including Northern Virginia, the District of Columbia, Delaware, and Pennsylvania. This is a scenario that FERC Commissioner Mark Christie called “potentially catastrophic.”

But why should Pennsylvanians care? Because Maryland and the City of Baltimore don’t exist in a vacuum, and they will still need electricity. To replace the production at Brandon Shores with solar, it would require a minimum of 15,400 acres of solar panels or about 1400 windmills. There are no such projects underway. The only answer for Maryland, short of shuttering the City of Baltimore, is to import the electric power needed to replace the capacity of Brandon Shores from generation states like Pennsylvania.

To import more electricity into Maryland from other generation facilities requires approximately $800 million worth of upgrades and new construction to high-voltage power lines throughout Maryland, Delaware, and Pennsylvania. The cost of the upgrades will be passed onto ratepayers in the areas where the upgrades are made. While the majority of the costs will be borne by Marylanders, about 20 percent or $160 million will fall on ratepayers in Pennsylvania. The crux of the problem, however, is that the upgrades will not be completed until sometime in 2028.

The real question is, what happens to Maryland and the City of Baltimore for those three years between the announced closure date of June 2025 and the necessary transmission line upgrades which are projected to be completed in 2028?  PJM has requested a voluntary agreement to delay the proposed shutdown to allow time to bring replacement power online. So far, that effort has been rejected. Frankly, it is unclear whether Maryland or the City of Baltimore understand the dilemma they are in and just how rapidly disaster is approaching.

Unfortunately, this scenario is being repeated throughout the PJM grid and the United States. The knee-jerk reaction to move to so-called “green energy” is occurring without considering the ramifications of what powers our daily lives.

For many years, we have become accustomed to flipping a switch and our lights come on. That reliability rests solely on thermal generation that can be brought online 24 hours a day, 7 days a week, 365 days a year without regard to weather, time of day, or duration. The inevitable fact is that as we introduce more of the so-called renewable electric generation, which is intermittent and of limited duration, into the grid, the more the grid will become intermittent and of limited duration. States like Maryland will soon face the consequences of short-sighted energy decisions. Sadly, Pennsylvanians will pay for it.

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For an alternate viewpoint see: GUINEY: Your Freedom is on the Ballot This November

Nearly a year ago in December 2021, President Joe Biden declared inflation had peaked at 6.8 percent and predicted it would decline shortly and “rapidly.” In June, seven months later, we saw inflation surge by 9.1 percent. September was not much better, with prices rising 8.2 percent over the prior year. The state of our economy has had far-reaching impacts on working families and our seniors on fixed incomes.

The average 401k has lost 25 percent of its value due to the economic downturn. Since Biden took office, Americans’ monthly savings have fallen 83 percent. Mortgage rates are at 20-year highs, placing the dream of homeownership out of reach for too many individuals. Meanwhile, more than half of workers are seeing their real wages lag behind inflation by 9 percent, the equivalent of losing a full month’s pay.  Economists at the Dallas Federal Reserve have labeled it the “most severe” pay cut in 25 years. With income falling behind the rising cost of goods and services, it’s no wonder that so many Pennsylvanians are struggling.

In the Philadelphia region, electricity costs are up more than 20 percent compared to just one year ago.  The cost to fill up your car or truck at the gas station is nearly 60 percent higher than it was two years ago.  And consumers can expect more bad news in the coming months as home-heating bills are projected to reach a 25-year high. A trip to the grocery store is not much better. Since Biden took office, the price of eggs is up 98 percent, chicken breasts are up 46 percent, bacon is up 27 percent, flour is up 25 percent, and sugar is up 23 percent.

When asked just a couple of weeks ago if he is worried about rising inflation and its impact on families and seniors, Biden dismissed concerns, saying “our economy is strong as hell.” That denial of basic facts, the stubborn blindness to what Americans are seeing and experiencing for ourselves, shows the president and his Democratic allies are truly out of touch.

Rather than put forward real solutions to the problem, Democrats helped fuel the increase in inflation by injecting billions of additional funds into the economy. When that bungled plan did what many economists predicted it would – further fuel inflation increases – the Democrats decided to push through a bill funding a range of pet initiatives under the guise of legislation called the “Inflation Reduction Act.” Even before the bill was signed into law, Democrats were already backpedaling from the bill’s name, admitting that it would do nothing to curb inflation.

To be clear, it’s not just national problems that are causing issues. Amid the pandemic, Gov. Tom Wolf capriciously mandated the closure of tens of thousands of Pennsylvania’s small businesses but allowed big box stores like Kohl’s and Walmart to remain open. Many never fully recovered. Earlier this year, CNN reported that nearly 32 percent of small businesses in Pennsylvania were permanently or temporarily closed compared to January 2020.

Rising inflation, lost 401k savings, and declining real wages aren’t the only challenges Pennsylvanians are facing.  Activist prosecutors who care more about violent criminals than the rights of victims have created a culture where criminals are not being held accountable for their crimes. In Philadelphia, the homicide rate so far this year is 57 percent higher than the same point just three years ago. And we are increasingly seeing the violent crime spill out into suburban communities with carjackings and armed robberies of small businesses. The problem is only further compounded by the lingering impacts of the defund the police movement and the demoralizing effect it had on law enforcement. The result is that many police departments are struggling to fill vacancies. It could not come at a worse time.

The list goes on and on. Parents who were concerned about the failure of schools to return to in-person learning were dismissed and told there would be no impact on the education of children. New federal testing results say otherwise, showing between 2019 and 2021 the largest ever decrease in math scores and significant decreases in reading scores. And at the same time that schools are failing to provide these basic education skills, progressives are continuing to push political ideology in the classroom while refusing to provide parents with transparency on curriculum so that parents know what their children are actually being taught.

A lot has changed in the past two years, and not for the better. It is time for voters to send a clear message to the Democrats at the national, state, and local level. The Democrats claimed that the last presidential and federal elections, which provided them with narrow control of Congress, were a voter “mandate” to implement their radical ideas and increase the control that government exerted over citizens. If Democrats truly want a mandate, now is the time to give them one. Voters need to turn out and make their voices heard, letting Democrats know that enough is enough.

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The U.S. Supreme Court delivered a strong message to Congress regarding regulating the nation’s environmental policy:

Do your job.

It’s a particularly important message in Pennsylvania, where the Biden administration’s expansive plans to regulate — and perhaps shut down — fossil fuel energy plants would have a significant effect on the state’s economy.

In West Virginia v Environmental Protection Agency, the Court ruled 6-3 that the Clean Air Act does not give the EPA broad authority to regulate greenhouse gas emissions from power plants on its own.

“Capping carbon dioxide emissions at a level that will force a nationwide transition away from the use of coal to generate electricity may be a sensible ‘solution to the crisis of the day,’” Chief Justice John Roberts wrote in the opinion. “It is not plausible that Congress gave EPA the authority to adopt on its own such a regulatory scheme.

“The agency must point to clear congressional authorization for the power it claims,” Roberts added.

Supporters of the Obama-era policy argue that the threat of climate change outweighs the limits on government power set by the court and they raised questions as to whether an elected Congress is capable of regulating such an important issue.

“Members of Congress often don’t know enough—and know they don’t know enough—to regulate sensibly on an issue,” Justice Elena Kagan wrote in her dissent.

“The decades-long fight to protect citizens from corporate polluters is being wiped out by these MAGA extremist justices,” said Senate Majority Leader Chuck Schumer (D-N.Y.) “It’s all the more imperative that we soon pass meaningful legislation to fight the climate crisis.”

Court supporters noted the irony of Schumer’s call for legislation, which was the conclusion of the court majority as well.

“It was incredibly risky for the federal government to try to turn our power-generating system inside out,” says Sam Kazman with the Competitive Enterprise Institute. “Today the Supreme Court ruled that if the government is going to do so, then it must be clearly authorized by congressional laws rather than by the dictates of unelected bureaucrats.”

Myron Ebell, Director of CEI’s Center for Energy and Environment, said the court’s ruling walks back its 2007 decision in Massachusetts v EPA.

“The Massachusetts case held that the EPA could use the Clean Air Act to regulate greenhouse gas emissions,” says Ebell. “The Court has now invoked the major questions doctrine and recognized that Congress designed the Clean Air Act to regulate air pollutants and not carbon dioxide emissions from burning coal, natural gas, and oil.

“The Biden administration must now get explicit authorization from Congress if it wants to continue to enact major climate policies that will further raise energy prices,” Ebell added.

President Joe Biden has directed his legal team to work with the Department of Justice and affected agencies to review this decision and find ways that the administration can continue protecting Americans from what he calls harmful pollution that causes climate change.

“We cannot and will not ignore the danger to public health and existential threat the climate crisis poses,” said Biden in a press release Thursday. “The science confirms what we all see with our own eyes – the wildfires, droughts, extreme heat, and intense storms are endangering our lives and livelihoods.”

Former President Barack Obama also weighed in, saying no challenge poses a greater threat to our future than a changing climate.

“Every day, we’re feeling the impact of climate change, and today’s Supreme Court decision is a major step backward,” Obama tweeted.

But it was Obama and his team that pushed through a regulatory scheme, rather than passing legislation limiting greenhouse gas emissions, that led to today’s ruling.

At the state level, Republican gubernatorial candidate state Sen. Doug Mastriano is running as an unapologetic ally of the state’s energy sector. He has pledged, for example, to pull the state out of the Regional Greenhouse Gas Initiative (RGGI) cap-and-trade scheme on his first day in office.  His opponent, Democratic nominee Josh Shapiro, has expressed doubts about RGGI but has kept his stance intentionally vague.

Environmental groups have denounced the Supreme Court’s ruling, calling this a dangerous decision that gives “coal executives and far-right politicians exactly what they asked for” by frustrating EPA’s efforts to protect communities and families.

“For years, EPA has had the clear authority and duty under the Clean Air Act to effectively reduce climate-disrupting carbon dioxide pollution from fossil fuel-burning power plants, in line with the action the public and science demands,” said Andres Restrepo, senior attorney for the Sierra Club’s Environmental Law Program. “But Thursday’s decision accommodates the powerful instead of the people by seriously narrowing that authority.”

But energy sector advocates say their industry still isn’t out of the EPA woods of overregulation.

“While this decision clearly reins in EPA authority to craft carbon rules that force a remaking of the nation’s electricity mix, the agency has already signaled it’s going to use every other tool at its disposal to accelerate coal plant closures and pursue its agenda,” one industry insider told InsideSources. “If you’re concerned about grid reliability and electricity affordability, Congress needs to step up and ensure it is steering domestic energy policy, not the regulators at EPA.”

Still, some conservative groups are taking the win.

“This is a win for the climate and constitutional democracy,” says Drew Bond, president of Conservative Coalition for Climate (C3) Solutions. “Any serious person knows that innovation, not over-regulation, is the solution to reducing global greenhouse gas emissions.”

Instead of looking to regulators to impose top-down mandates, Bond says activists on all sides should ask legislators to pass laws that encourage bottom-up solutions.

“Our Climate and Freedom Agenda highlights dozens of actions Congress can take to meaningfully reduce greenhouse gas emissions through innovation and by expanding economic freedom,” says Bond about C3 Solutions. “Let’s put our focus there. American innovation won’t disappoint.”

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Energy sector officials have been warning for years about the risks posed to New England’s grid by plunging temperatures, risks exacerbated by anti-energy-infrastructure policies across the region.

Now with New England facing its coldest temperatures since the “polar vortex” of 2019 and wind chills of -45 degrees below zero across the U.S. northern tier states, the grid is under stress once again.

“Well-documented natural gas pipeline constraints, coupled with global supply chain issues related to deliveries of oil and liquefied natural gas (LNG), are placing New England’s power system at heightened risk heading into the winter season,” ISO New England Inc, operator of the region’s power grid said in a December 6 statement.

In that same statement, Peter Brandien, vice president of System Operations & Market Administration, warned “if the region experiences an extended period of extreme cold weather, fuel supplies into the region could become constrained resulting in challenging system operation.”

As ISO=NE continues its work with the New England states and industry stakeholders to transition to what it considers a cleaner grid, the organization said it must also maintain real-time power system reliability.

“In recent years, oil and LNG have filled the gaps when extended periods of very cold weather have constrained natural gas pipeline supplies,” according to ISO New England’s president and CEO Gordon van Welie. “Higher prices globally for these fuels, as well as pandemic-related supply chain challenges, could limit their availability in New England if needed to produce electricity this winter.

“The region would be in a precarious position if an extended cold snap were to develop and these fuels were not available,” van Welie said.

Dan Kish of the Washington, D.C.-based Institute for Energy Research (IER) says these warnings were not sexy at the time, but people are paying attention now.

“What they pointed to was a growing gap between demand for energy and the supply that people are making available either through pipelines or electrical lines or anything else and because New England is an area of the country that does not have a lot of energy production,” says Kish. “I would be concerned based upon what the people who oversee the grid have said about it.”

“Part of the problem with the grid is the problems created by people that say we need to fix the grid,” says Kish. “The more diversity one has, the more options people have to use whatever fits those needs, and when you begin closing those down, that puts excessive strain on the grid, and that’s why the grid is running into trouble.”

Which is why New Hampshire maintains the 459 MW Merrimack Station in Bow, the last coal-burning power plant in New England. While it is seldom powered up, its owners, Granite Shore Power, make millions in capacity payments by acting as a reliable electricity backup for the grid.

“Coal-fired plants no longer supply baseload power,” says the U.S. Energy Information Administration, “but they play an important role in providing electricity on high demand days.”

Green activists have been trying unsuccessfully to shut down the Bow plant for years. Four protesters with the left-wing organization “No Coal, No Gas” were arrested Saturday after two chained themselves to a smokestack at the Bow plant.

None of the four arrested are residents of New Hampshire, according to police reports.

So, what power source should New England use during high-demand periods if they succeeded in getting Bow shut down?

“I recognize that the transition does not happen in one day, and the workers at the coal plant deserve options in the transition away from fossil fuels,” Rebecca Beaulieu, Communications & Youth Programs Organizer at 350 New Hampshire.

Beaulieu argues that coal provides just 3 percent or so of New England’s power, even during a peak in usage, and that three percent can be made up by renewables. “We would love to see the coal plant replaced with solar or wind energy – something that would benefit the residents of Bow and end the pollution of their air and water.”

And she’s right: On. Tuesday, ISO-NE reported just 2.55 percent of power on the grid came from coal. However, that’s about the same as wind (2.9 percent) and 100 times more than solar (o.o2 percent.) Wind and solar output would have to double to replace coal — and that’s assuming there’s not another 2019.

“Wind and solar operate pretty poorly when it’s cold or snowing,” says Kish.

Meanwhile, the use of oil surges during cold periods like this one. According to the dashboard, New England was getting 17 percent of its energy from oil on Tuesday, more than hydro/wind/solar combined.

One of the stated goals of the “No Coal, No Gas” movement is to prevent the Bow plant from being converted to natural gas – despite the fact it emits about half as much carbon as coal.

“Europe right now has been going through a situation where they’re closing industries because you simply can’t make fertilizers or metal, or steel because the cost of energy has gone through the roof because they’re a few years ahead of us in this so-called green transition,” Kish said.

“So, make no mistake about it: The grid itself is actually put in peril by many of the things that they’re preaching that we ought to adopt.”

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Last month, seven environmental groups wrote a misguided letter to Philadelphia officials bashing legislation that I sponsored as counterintuitive to the city’s decarbonization goals.

In October, six Democrats, including two from the southeast corner of the state, joined all 28 Republicans and our chamber’s lone independent to approve Senate Bill 275. That’s a veto-proof majority, for those counting.

Why? Because the bill’s purpose is simple. It prevents Pennsylvania’s 2,500-plus municipalities from banning access to certain utilities, like natural gas or heating oil. That will preserve consumer access to affordable electricity, no matter where they live, and prevent a chaotic patchwork of regulations that ultimately undermine statewide environmental and energy policies.

It also reaffirms what many local and statewide officials, including the Pennsylvania Public Utility Commission, already understand to be true: municipalities do not have the authority to restrict energy sources.

What the bill does not do is prevent the Philadelphia City Council from pursuing its goal to retrofit all publicly owned buildings to reduce emissions 50 percent over the next decade. It’s not just about ripping out gas lines and oil tanks and installing heat pumps instead. Reducing electricity usage – through upgraded windows, roofs, and insulation – is also a crucial piece of the puzzle.

The aforementioned environmental groups said SB 275 will eliminate any hope of Philadelphia reaching carbon neutrality by 2050. Which begs the question, if the only way to achieve decarbonization is by indiscriminatingly banning utilities deemed “dirty” and “bad,” is that even a good plan? Isn’t there an old adage forewarning the danger of putting all your eggs in one basket?

Banning specific fuel sources in pursuit of “clean energy” makes zero sense in Philadelphia and beyond. First, clean energy is a misnomer. There’s simply no such thing. Even if we shuttered every coal and gas plant across the world tomorrow and began a frantic campaign to install wind and solar farms in their place, we’d need to cover about 1.8 million square kilometers of land and coastline to replace the lost capacity.

And we would need fossil fuels to produce all of those solar panels and wind turbines. Just like we need oil and gas to create and distribute nearly every product we use every single day, from the medications we take to the clothes we wear to the packaging we use to preserve our food. To assume that banning fossil fuels will only impact emissions and electricity prices is to ignore the intricate web that is our economy.

Besides, the city doesn’t exist in a vacuum. It’s connected to a vast, 13-state power grid called PJM, that manages the safe and reliable flow of electricity for 65 million people from Chicago to Washington D.C. and many places in between.

PJM’s operators ensure that its network of transmission lines and generation facilities work in tandem every minute of the day, preventing system overloads that could trigger massive utility failures and inflict untold suffering on millions in its territory. So, if electricity demand spikes in Philadelphia, but environmental policies have forced fossil-fuel plants into nonexistence, there are fewer reliable energy sources to shoulder the burden.

A similar story unfolded in Texas in February when an unprecedented winter storm froze generators and rendered solar and wind farms useless, leaving as many as 4 million Texans without power or water. More than 200 people died amid the chaos. The Electric Reliability Council of Texas, the state’s grid operator, promised to winterize its system to harden it against future storms, but the damage was done. The rest of the nation should take note: a diversified and robust grid is key to preventing systemwide catastrophes.

Which brings me back to the idea of banning access to fossil fuels. If we are willing to sacrifice our food, clothing, shelter, and transportation, doing so might eliminate some carbon emissions in the United States. Globally, U.S. emissions equal about half of what China produces on an annual basis, according to 2018 figures. The annual combined emissions from the other three top polluting nations – India, Russia, and Japan – would likewise take our place.

Then there are the emissions from sources we can’t always control: Volcanic eruptions, livestock, forest fires. Or the damage caused by human activity like deforestation and degenerative agriculture. Even if the United States found a solution to every single unsustainable practice that critics say contributes to climate change, the rest of the world’s leading nations aren’t following suit.

So, what do these groups really want from the city? They want officials to take a sledgehammer to our carefully planned and managed power grid, collapse our economy, and leave Pennsylvanians with higher electric bills, fewer jobs, and unreliable utilities. All for the sake of reducing carbon emissions that will be offset by the rest of the world in perpetuity.

Protecting energy choices for consumers means that residents can pursue “cleaner” electricity sources if they want to or can afford to, while not punishing those who don’t have the option. SB 275 isn’t about protecting special interests – what does a senator from Williamsport owe to Philadelphia’s gas utility?

What I do care about is promoting a sound energy policy that doesn’t leave others behind for the constant pursuit of ideological purity, no matter how impractical or impossible or harmful it is for the very people such policies purport to help.

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I’ve sounded the alarm over the Regional Greenhouse Gas Initiative (RGGI) in many public settings over the past several months. This undertaking, an executive fiat ordered by Gov. Tom Wolf, will impact the life and wallet of virtually every Pennsylvanian and deliver almost nothing in terms of improved air quality.

At the outset, the stated purpose of RGGI is to reduce greenhouse gases. In theory, this works through an auction that is open to power producers and industrial plants in 12 states that buy “credits” to offset the excess emissions their facilities generate. The proceeds from the auction sales are then distributed to various government programs, the majority of which have nothing to do with the environment.

The current RGGI states include Connecticut, Delaware, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont and Virginia. They will control the amount of credits Pennsylvania can sell at auction and, as an inevitable consequence, will dictate many decisions affecting our environment and economy.

In reality, RGGI forces Pennsylvania to undermine its own position as a top energy producer and hand over economic control to a collection of states that bear little resemblance to us. This is troubling when we consider that New England would prefer to buy natural gas from Russia rather than permit the construction of a pipeline that would connect their region to Pennsylvania’s plentiful supply.

Eight RGGI states report some of the highest electricity rates in the nation. In some RGGI states, residents pay double the rates paid by Pennsylvanians. According to a study done by PJM, the operator of the 13-state power grid which controls the flow of our electricity, RGGI will cause an 18 percent increase in rates – nine times larger than the spike the Department of Environment Protection (DEP) claims will occur through 2030.

DEP hails the projected 2 percent reduction in rates seen in other states as proof that RGGI works. This is misleading, at best, when we consider that those residents pay 50 percent to 75 percent more for electricity compared to Pennsylvanians. A 2 percent decrease when rates are nearly twice as high translates into a negligible savings – if at all – in Pennsylvania.

In 2019, the state predicted that clearing prices for the credits bought at auction would not rise above $3 per ton. RGGI’s most recent auction, completed on Dec. 1, set a clearing price of $13 per ton – more than four times the rate DEP forecasted and a 40 percent increase over the Sept. 8 auction clearing price alone. At current prices, the Wolf RGGI scheme translates to an approximately $750 million annual tax on Pennsylvania consumers.

It gets worse. According to DEP’s own modeling, 90.1 percent of the emissions reduced in Pennsylvania will be offset by increased pollution from non-RGGI states in our electric grid. A similar report by Penn State University shows that 86 percent of the electric capacity lost in Pennsylvania under RGGI will be replaced by increased coal-fired generation in neighboring non-participating states.

Make no mistake, RGGI depends on continued pollution. Without it, there would be no need for credits. With no need for credits, there is no market and thus no one would need to participate in RGGI’s auctions. So, rather than curbing environmental air pollution, RGGI depends on continuing it.

Some estimates forecast that in the first decade of RGGI, the reduction in carbon dioxide emissions will be less than 1 percent. This is despite the fact that, due to state-of-the art technology, CO2 emissions in Pennsylvania from fossil fuel generation have already been reduced by 38 percent since 2002 – more than all RGGI states combined.

A DEP presentation on July 22, 2020 indicated that great improvements had been achieved in ambient air quality in Pennsylvania. How did this great news in July become such a problem that only RGGI could fix just a few months later? The answer is politics.

RGGI targets coal-fired electric generation plants and the thousands of skilled trade jobs these facilities support. States, and even countries, with far fewer environmental controls in place than those in Pennsylvania, will absorb those jobs. Why would we close highly regulated Pennsylvania electric plants and send that generation capacity and those opportunities elsewhere?

No matter how its viewed, RGGI is not good for the environment or the economy of Pennsylvania.

RGGI supporters conveniently ignore that RGGI will leave thousands unemployed, skyrocket electricity bills for everyone – including our most vulnerable populations – and serve as an unauthorized carbon tax implemented without legislative approval. It’s just another way that the current Administration wants to bypass our government’s fundamental checks and balances to further policy goals that harm the very residents they mean to help.

In its simplest terms, RGGI fails miserably in accomplishing its only stated purpose.

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