The following materials provide information about GHG Coalition position statements and comments.

Comments on New York DEC and NYSERDA Proposed RGGI Regulations
These comment memos highlight the GHG Coalition's comments and recommendations regarding the NYDEC and NYSEREDA proposed RGGI regulations.  Submitted to NYDEC and NYSERDA in December 2007.

Download NYDEC Statement (pdf)
Download NYSERDA Statement (pdf)

Comments on RGGI Final Auction Report
This comment memo highlights the GHG Coalition's comments and recommendations regarding the RGGI final auction report.  Submitted to RGGI in November 2007.

Download Statement (pdf)

Comments on Massachusetts DEP and DOER Proposed RGGI Regulations
These comment memos highlight the GHG Coalition's comments and recommendations regarding the MA DEP and DOER proposed RGGI regulations.  Submitted to MA DEP and MA DOER in September 2007.

Download MA DEP Statement (pdf)
Download MA DOER Statement (pdf)

Comments on Maine DEP Proposed RGGI Regulations
These comment memos highlight the GHG Coalition's comments and recommendations regarding the ME DEP proposed RGGI regulations.  Submitted to ME DEP in September 2007.

Download ME DEP Statement (pdf)

Comment Memo on RGGI Final Model Rule
This comment memo was submitted to environmental and energy agency representatives in every RGGI participating state.  It highlights the GHG Coalition's comments and recommendations regarding the RGGI final model rule.  Submitted in October 2006.

Download Statement (pdf)

Comment Memo on RGGI Draft Model Rule
This comment memo was submitted to environmental and energy agency representatives in every RGGI participating state.  It highlights the GHG Coalition's comments and recommendations regarding the RGGI draft model rule.  Submitted in May 2006.

Download Statement (pdf)

Comment Letter on RGGI Process
This comment letter was submitted to environmental and energy agency representatives in every RGGI participating state.  It higlights the GHG Coalition's recommendations regarding the RGGI carbon offset and electricity import and leakage processes.  Submitted in February 2006.

Download Statement (pdf)

RGGI MOU Statement
Statement released by GHG Coalition member companies after the signing of the Regional Greenhouse Gas Initiative Memorandum of Understanding by 7 northeast states on December 20, 2005.

Download Statement (pdf)

RGGI Comprehensive Policy Recommendations
This report provides GHG Coalition policy recommendations for the design of the Regional Greenhouse Gas Initiative (RGGI).  In developing these recommendations, the objective of the GHG Coalition was to develop a set of recommendations that provide a model for a national program that would have a reasonable likelihood of adoption.

Download RGGI Policy Recommendations (pdf)

Comment Letter on RGGI Package Proposal
This comment letter was submitted to environmental and energy agency representatives in every RGGI participating state.  It higlights the GHG Coalition's position regarding the RGGI Package Proposal released in August 2005.

Download Letter (pdf)

Comment Letter on Electricity Imports and Leakage
This letter was submitted to environmental and energy agency representatives in every RGGI participating state.  It higlights the GHG Coalition's concerns regarding the potential for an increase in electricity imports and CO2 emissions leakage once RGGI is implemented.

Download Letter (pdf)

White Paper on Emission Performance Standards
This document contains a discussion of an alternative policy implementation mechanism for an emissions cap-and-trade program called an emission portfolio standard or EPS.  An EPS would subject the distribution or wires company, otherwise known as the load serving entity (or LSE), to an output-based performance standard (using lbs CO2/MWh as the metric).  Under an EPS, the LSE could demonstrate compliance with the performance standard by any combination of approaches including balancing its supply portfolio to meet the target level, trading certificates that are created within the power market and trading project-based emission reductions (or carbon offsets) created in other sectors.

Download White Paper (pdf)

RGGI and RGGR Goals and Objectives

As a stakeholder in the Regional Greenhouse Gas Initiative and Regional Greenhouse Gas Registry, the GHG Coalition developed this set of goals and objectives.  The GHG Coalition believes that RGGI and RGGR are of immense significance because it stands to serve as a model for other areas of the country and even for the country as a whole.  The Coalition offered these goals and objectives as fundamental to the design of RGGI and RGGR.

Download Document (pdf)