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The report argues that RGGI's design, which caps emissions only for power plants within participating states, creates a price advantage for imported electricity from coal-heavy states like West Virginia and Pennsylvania. This 'leakage' is exacerbated by excess capacity in existing coal plants and planned transmission upgrades that facilitate power flow from west to east. The authors suggest that RGGI states should implement retail-level carbon caps, prohibit contracts with high-emission plants, and prioritize transmission projects aligned with climate goals to prevent the expansion of coal-based power.

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  • The Regional Greenhouse Gas Initiative (RGGI) may spur an increase in electricity imports from coal-producing states because it only prices emissions from power plants within the region, making out-of-region power relatively cheaper.
  • Existing coal plants to the west and south of the RGGI region have significant unused capacity that could produce emissions 3.5 times the cuts expected under the initiative, equivalent to adding 9 million cars to the road.
  • Six coal plants under or near construction in states adjacent to the Northeast could emit global warming pollution equal to 140 percent of RGGI's projected reductions.
  • Planned transmission expansions, such as the Trans-Allegheny Interstate Line (TrAIL), risk becoming 'leakage highways' that enable more coal-based electricity to flow from non-RGGI states like Ohio, Pennsylvania, and West Virginia into RGGI states like Delaware, Maryland, and New Jersey.
  • Coal is the most carbon-intensive fossil fuel, accounting for one-third of all U.S. CO2 emissions from energy use, and new coal plants emit more than twice the CO2 per unit of electricity as new natural gas plants.
  • California's climate policies, which include an implicit cost for imported carbon emissions, have already led to the cancellation of out-of-state coal projects, such as a 950-megawatt upgrade to the Intermountain Power plant in Utah.
  • To prevent emissions leakage, RGGI states could prohibit utilities from signing long-term contracts with plants exceeding specific carbon emission rates or require distributors to account for emissions from all power sold, regardless of origin.

Cite the original document

APA
ROGERS, J., JAMES, C., & MASLOWSKI, R. (2008). IMPORTING POLLUTION. Union of Concerned Scientists. https://www.ucs.org/sites/default/files/2019-09/importing-pollution_report.pdf
Chicago
ROGERS, JOHN, CHRIS JAMES, and ROBIN MASLOWSKI. IMPORTING POLLUTION. Union of Concerned Scientists, 2008. https://www.ucs.org/sites/default/files/2019-09/importing-pollution_report.pdf.
Wikipedia
{{cite report |last1=ROGERS |first1=JOHN |last2=JAMES |first2=CHRIS |last3=MASLOWSKI |first3=ROBIN |title=IMPORTING POLLUTION |publisher=Union of Concerned Scientists |date=December 2008 |url=https://www.ucs.org/sites/default/files/2019-09/importing-pollution_report.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{rogers2008importing, author = {ROGERS, JOHN and JAMES, CHRIS and MASLOWSKI, ROBIN}, title = {{IMPORTING POLLUTION}}, institution = {Union of Concerned Scientists}, year = {2008}, month = dec, url = {https://www.ucs.org/sites/default/files/2019-09/importing-pollution_report.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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