RGGI Posts

The Regional Greenhouse Gas Initiative (RGGI) is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont, and Virginia to cap and reduce power sector CO2 emissions.  This page lists my posts that address RGGI and summarizes my concerns.

In July 2025, the RGGI states completed the Third Program Review and characterized the program as a longstanding bipartisan success. RGGI’s official program-review page claims that the revised program will “ensure the longstanding bipartisan initiative’s continued success in promoting clean air, health and economic benefits across the region.” It highlights more than $9 billion in auction proceeds, claimed benefits to more than 8 million households and 400,000 businesses, and projected energy-bill savings exceeding $20 billion from state investments of proceeds.  The Investment of RGGI Proceeds in 2024 report claims that “As a whole, the RGGI states have reduced power sector CO2 emissions by about 50% since 2005, while the region’s gross domestic product has continued to grow.”

Those figures are examples of the claims made by RGGI supporters, but as I have shown in my analyses listed here they do not stand up to scrutiny.  They do not demonstrate that the allowance program caused the region’s historical power-sector CO₂ reductions, nor do projected lifetime bill savings establish that RGGI has been a cost-effective emissions-control program. The relevant questions are attribution, the cost per ton of CO₂ actually avoided by RGGI-funded investments, and whether investment results can plausibly meet the increasingly stringent cap trajectory.

In brief, I have found that:

  • RGGI-funded control programs accounted for only 8.7% of the observed 2024 RGGI CO₂-emissions reduction RGGI Investment Proceeds June 2026 Update June 29, 2026.  The 50% reduction since 2005 claim is misleading.
  • The benefits associated with auction revenues are modeled, expected-lifetime estimates. They include projects still in the pipeline that are not yet operational, they have not been adjusted through evaluation, measurement, and verification (EM&V), and they are compared only against historical program expenditures, not against the revenues collected or the program’s full cost.  The cost benefit claims are disingenuous. Hochul and RGGI Affordability September 3, 2026
  • RGGI is supposed to be a CO2 control program but the avoided CO2 emissions cost effectiveness for RGGI auction proceeds is $804 per ton avoided.  RGGI Investment Proceeds June 2026 Update June 29, 2026
  • The RGGI states have not admitted that their cost estimates do not include the effect of RGGI allowance costs on the wholesale electric price.  The allowance cost is part of the wholesale electric bid and can raise the total energy price paid to every accepted resource in the bid interval.  This roughly doubles the cost of RGGI over just the allowance cost. Hochul and RGGI Affordability September 3, 2026
  • The RGGI states have not acknowledged that the current allowance cap reduction trajectory is incompatible with past emission reduction performance and reasonable expectations for future reductions.  RGGI is headed to the point where there will be  insufficient allowances to enable sources to run and remain in compliance.  If left unchecked this will lead to an artificial energy storage as soon as 2032. RGGI – When will the Allowances Run Out May 15, 2026

I have been involved in the RGGI program process since its inception. Before retirement from a non-regulated generating company, I was actively analyzing air quality regulations that could affect company operations and was responsible for the emissions data used for compliance. As a result, I have a niche understanding of the information necessary to critique RGGI. The opinions expressed in these posts do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

The following are my posts on RGGI. Note that I update the status of emission leakage, investment proceeds and allowance holdings reports regularly.

RGGI Posts