I am one of 13 individuals and four organizations to demand that Pennsylvania’s Environmental Quality Board (EQB) act decisively on a petition to develop the Stability and Affordability Via Emissions Reduction (SAVER) regulation, which would promote a strong, sustainable economy while reducing Pennsylvania’s greenhouse gas emissions. Joining this demand are the Clean Air Council, Citizens for Pennsylvania’s Future, Pennsylvania Environmental Defense Foundation, the Responsible Drilling Alliance, and 12 additional scientific, public health, legal, and economic experts.
The initial rulemaking petition, filed with EQB by 192 public interest groups and individuals, has languished for seven years while Pennsylvanians have suffered harm from climate change and watched the cost-of-living soar. The SAVER regulation would help address these crises by creating a program that caps and gradually reduces greenhouse gas (GHG) emissions while generating revenue the Commonwealth needs to invest in public transportation and affordable clean energy. The regulation is a market-based method to reduce GHG emissions by 40% by 2030 and make Pennsylvania carbon neutral by 2052.
If GHG emissions are not reduced quickly, there is a broad scientific consensus that the harms we are already experiencing from climate change will increase dramatically and could be cataclysmic for our children and grandchildren. Pennsylvania is already experiencing more extreme weather events, including flooding, heat waves, periods of drought, and destructive storms, as well as increased insect-borne illnesses. The Center for Climate Integrity found that climate disruption will cost Pennsylvania over $1 billion annually. Most of these costs — a significant driver to today’s affordability crisis — are borne by local and state governments, water departments, electrical utilities, and their taxpayers and ratepayers.
The Department of Environmental Protection (DEP) has clear authority to implement the SAVER Regulation under the Pennsylvania Air Pollution Control Act. Under the Pennsylvania Constitution, the state also has a duty to protect the state’s climate, and the people have the right to ensure it does.
Pennsylvania generates almost one percent of the world’s GHG emissions, more than most other states and nations. There is also a strong scientific consensus that immediate action is urgently needed to avoid the worst consequences of global warming.
“SAVER would promote economic development and make Pennsylvanians healthier, ending the free ride for polluting fossil fuel generators,” said Lawrence Hafetz, Clean Air Council’s Legal Director.” DEP has a duty to end the giveaway for fossil fuel generators foisting the cost of their pollution onto taxpayers. Clean energy is cheaper to produce, creates jobs, and, by combatting climate change, would increase the physical and economic wellbeing of all Pennsylvanians.”
“It is time for Pennsylvania’s Legislature and Executive Branch to take their obligations under the ERA seriously,” said Joseph Otis Minott, retired Executive Director and Chief Counsel of Clean Air Council.
“Clean energy is growing much cheaper while fossil fuel energy is becoming more expensive,” said John C. Dernbach, Professor Emeritus of Widener University Commonwealth Law School. “By making all energy sources compete on a level playing field, the SAVER regulation would speed up the use of cheaper clean energy, making life better for all Pennsylvanians.”
“Pennsylvania has been fiddling this while the world burns. It’s high time for action on climate change.” I put together a conference on climate change at Penn State in 2002. I submitted this petition in 2018. Pennsylvania has fiddled, and now the world is catching fire,” Robert B. McKinstry Jr.,
SAVER’s approach has been used successfully in both the California-Washington-Quebec program and the RGGI states program to reduce emissions while causing greater economic growth and job creation than would have been seen without these programs. By contrast, allowing unabated climate change would cost Pennsylvania billions in necessary climate resilience costs, responses to climate-driven disasters, and heat-related healthcare cost increases in the coming decades.
The SAVER regulation would create a system to cap and reduce greenhouse gas emissions across all sectors of Pennsylvania’s economy. Emission allowances would be auctioned and traded among businesses, and the total amount of allowable emissions would decrease each year. This market-based approach would provide businesses with the predictability and flexibility they need while incentivizing technological innovation.
The SAVER regulation, with recommended provisions for allowance allocation and expenditures from the Clean Air Fund, would promote affordability and address budget challenges by providing a revenue stream from the auction of emission allowances. That revenue could be explicitly directed to securely support public transportation and reduce electricity costs through funds allocated to electric distribution utilities.
Additionally, the cost of electricity, heating, and cooling would be reduced by auction revenues being invested to increase efficiency, improve electricity generation and transmission systems, and promote technological advances and energy conservation. Health benefits would also translate directly into lower costs for healthcare and insurance.
You can find the demand for action here. The cover letter is here. The fact sheet on the SAVER regulation is here.
We originally filed the petition in 2018, as explained here. In response to comments, we filed an amended petition in February 2019. That petition, which includes the proposed regulation we are now designating the SAVER regulation, is here. The state’s April 2019 acceptance of the petition for study is here.

