Dear Ms. Sabasteanski:

Thank you for the opportunity to comment on the proposed regulation for the Commonwealth to enter carbon emissions trading as a means for reducing the greenhouse gas contribution of coal-fired power plants of a certain size.

In general, I wholeheartedly support movement in this direction.  As a global concern, the rapidly warming temperatures of our planet and the impact this has on climate, on sea levels, on ocean temperatures and acidity, and on severe weather events is deeply concerning for both human and ecologic reasons. 

The approach of this proposed rule is strong – leveraging market forces as a means to create a lowerable cap on carbon emissions of our coal-fired power plants provides flexibility for the utilities impacted that strict regulations would not allow.  Utilities will have the choice of to which power plants they will focus their resources for reducing carbon emissions as well as by what means they will do so, allowing for the most economically efficient path for achieving the cap.  In addition, linking this rule to RGGI saves tax dollars by utilizing an existing market and not incurring the costs of having to create a market specific to Virginia.

I do, however, have a few concerns and suggestions that would improve this proposed rule that largely draw from the AEE STEER model for the Commonwealth (https://info.aee.net/steer-virginia). 

• While I have not fully vetted the STEER model myself, I find the tool to be compelling and feel that the Commonwealth should utilize a third party reviewer to test the model and, if validity is verified, use the model to determine final details of the rule, including but not limited to:
  • Increasing the annual percentage reduction above 3.0%.  I believe that this level is not at the appropriate level of economic efficiency as the marginal damages likely estimated to arrive at this percentage are probably grossly underestimated.  Increase the efficiency by increasing this percentage.
  • Version 1 of the CO2 Allowance Allocations (33 million ton base budget) is preferable between the two Versions.  Even more preferable would be a lower base budget.  However, the negligible difference between the two Versions based upon the utility ownership and current trends in infrastructure investment makes it equally feasible - and more effective - to have the base budget in 2020 be 33 million tons.
• Increase the resources (conditional allowances) provided to DMME to increase the agency’s capacity to monitor and enforce compliance.
• Provide more constraints on the use of auction revenue by CO2 budget units to further promote and incentivize development of renewable energy technologies and markets (https://www.c2es.org/site/assets/uploads/2008/11/greenhouse-gas-emissions-allowance-allocation.pdf)

Again, thank you for the opportunity to comment.  I look forward to piloting the approach with suggested changes made and then expanding the program to additional GHGs and/or CO2 sources once the program proves successful.

Sincerely,

Rob Alexander

Harrisonburg, VA