Virginia's coastal communties and families of low income households have been feeling the burden of sea level rise and climate change for decades. The excessive omission of carbon dioxide and green house gases have now become a national threat to our military bases and roadway infrastructure. Flooding and extreme storms surges continue to have detrimental impacts to the Hampton Roads region, rated second only to New Orleans as the most vulnerable area impacted by rising seas. President Trump has already promised to rollback on numerous environmental protections through his proposed budget for FY18 and an executive order. We ask that our state continues to defend Virginia values in protecting our public health and natural resources. The next four years will present many unknown challenges pertinent to citizens in the Commonwealth and we depend on Governor McAuliffe to reduce our carbon emissions by 30% by the year 2030.  

Implementationn of this rule will be a big step for a more sustainable world.  State and local actions to protect our environment are now more important than ever.  Virginia and other states step forward instead of waiting for federal action.

Assessing Virginia's Carbon Reduction Policy Options

Public Comment by Stanford University graduate and law students pursuant to Executive Order 57: Development of Carbon Reduction Strategies for Electric Power Generating Facilities.

April 24, 2017

Comment submitted by:

Brittany Gibbons, MS '17

Alison Gocke, JD/MS '17

Patricia Levi, PhD '20

Kelley Luyken, MS '17

Lauren Tarpey, JD/MS '17

The following comment is an excerpt from our Executive Summary of our Public Comment to the E.O. 57 Work Group process. Due to the word limit constaints on this public comment, we were not able to submit all of our findings. We are happy to provide additional information into our research and our model assumptions as needed; feel free to contact us at the email address provided pursuant to this Comment.

Pursuant to Executive Order 57, the Secretary of Natural Resources and the Work Group participants are tasked with "study[ing] and recommend[ing] methods to reduce carbon emissions from electric power generation facilities."[1] Several such methods have been proposed and discussed since the Work Group's inception in August 2016, including:

1. Establishing a market-based regulation of carbon emissions similar to a cap-and-trade scheme, as suggested by the Warrenton Climate Change Group, the Virginia Chapter of the Sierra Club, and the Southern Environmental Law Center, among other stakeholders;
2. Increasing Virginia's energy efficiency targets, as suggested by the Business Council for Sustainable Energy, the Virginia League of Conservation Voters, the American Council for an Energy Efficient Economy, and Appalachian Voices, among other stakeholders;
3. Increasing Virginia's renewable energy portfolio, as suggested by the Advanced Energy Economy, the Virginia Chapter of the Sierra Club, National Green Fuels, and Ceres, among other stakeholders; and
4. Reducing the local health impacts of in-state energy generation, as suggested by the American Lung Association, the Virginia Environmental Justice Collaborative, the Faith Alliance of Climate Solutions, and the Virginia Poverty Law Center, among other stakeholders.

Participants also proposed some combination of these policies in order to achieve carbon emissions reductions in Virginia.

The purpose of this Comment is to assess the economic and health impacts of these policy proposals; to evaluate their feasibility in achieving E.O. 57's overall goal of reducing carbon emissions; and to suggest a favored policy option(s) to the E.O. 57 Work Group.

In order to satisfy this goal, we built an economic optimization model of Virginia's electricity sector. The model determines the least-cost generation capacity investment for the electricity sector, and simulates a full year of operation. We populated the model with detailed data on the electricity generators available to Virginia, real historical demand data, and information on renewable resource availability. The model represents Virginia at a high level of fidelity, and has a simplified representation of out-of-state generation resources.

We discovered several trends in our results that we believe should influence the Work Group's decision-making. First, we found that if the Work Group elects to adopt a market-based cap-and-trade system, it will have to also adopt a mechanism for enforcing such a cap on electricity generated out-of-state and then imported into Virginia; otherwise, the benefits of capping carbon emissions within the state are almost entirely overrun by pollution generated out-of-state.

Second, we found that using complementary policies like energy efficiency and renewable energy portfolio standards can reduce the costs of implementing a carbon cap and help insulate Virginia from fluctuating fossil fuel prices, which make up a significant portion of total system costs. These policies also reduce the effects of emissions leakage resulting from imported electricity.

Third, we found that energy efficiency or renewable energy targets implemented on their own—without a simultaneous carbon cap—are less effective at reducing negative local health impacts than a carbon cap. In our model, this occurred because there are certain coal-fired power plants within Virginia that can operate more cheaply than natural gas plants if natural gas prices increase as projected over the next fifteen years. Under those conditions, reducing electricity demand or building up in-state renewable energy generation does not force a substantial reduction in coal generation, which means that the negative health effects of coal co-pollutants remain. In order to reduce the health impacts of electricity generation in Virginia—a cost that is significantly born by minority and low-income communities—the state must regulate carbon emissions as well.

Finally, we found that if Virginia employs the suite of complementary policies discussed above at only slightly less stringent levels (e.g., a 30% cap as opposed to a 50% cap), the state can achieve significant carbon emissions reductions at a total system cost less than the costs produced under our "business-as-usual" scenario.

Of course, each of these findings should be read with the caveat that they are subject to the assumptions and constraints of our model. A detailed explanation of those assumptions is provided in the Appendices. We caution that our model is best for examining trends and insights, not for precise numbers; the model is not intended to be an exact replica of Virginia's current or future electricity system, just a sufficiently accurate one to observe useful trends. Nonetheless, we do believe that the trends we discovered are valuable, and should be taken into account as the Work Group compiles its recommendations.

Based on our model, we believe that Virginia can achieve deep carbon emissions reductions at a total system cost only slightly higher than a "business-a-usual" scenario by adopting a 50% cap on carbon emissions (which is also enforced against utilities importing electricity from out-of-state); a 20% Renewable Portfolio Standard; and a modest energy efficiency goal of 1.5% annual savings by 2025. This suite of policy options keeps costs relatively low, reduces Virginia's susceptibility to fluctuating fuel prices, builds up Virginia's renewable energy economy, and produces health savings for local Virginians, all while achieving significant reductions in electricity-sector carbon emissions.

The remainder of this Comment is contained within a Comment submitted to the E.O. 57 Work Group because of the word limit here. 

I fully support any and all reduction of carbon.

Increasing emission of carbon dioxide and other greenhouse gases is causing dramatic changes in our climate. The solutions are obvious, the technologies are in hand and becoming ever better and cheaper, all that's missing to address this global crisis is the political will to foster implementation of these solutions.  We can start in Virginia, as people are starting locally in cities and states around the world, to address an existential problem that threatens to cost us lives, money, and our very way of living.  30/30 is a modest goal, but it's a start.  We need to start.

I support cutting carbon pollution in VA by 30% by 2030. It is the best thing we can do for the people of Virginia, for our environment, and doing this will attract cleaner businesses to our state and strengthen our economy. 

I support reducing CO2 levels by 30% ideally through the use of renewables and closure of coal power plants. The reduction of CO2 by 30 percent will help Virginia improve air quality and decrease human health impacts. I grew up (from 1995-2012) within 30 miles of two coal fire power plants, the Spruance Genco LLC plant on the edge of Richmond and the Dominion - Chesterfield Power Station. I have had asthma growing up and now require medicine that cost me $350 every two months. I can’t afford it all the time due to college bills I am required to pay back for my degree. The reduction of CO2 and other pollutants from power plants can decrease the chances that other Virginias will develop asthma like me.

I can’t say with 100% certainty that the two coal plants I grew up close to caused my asthma but it is a very plausible reason with the science and research that have shown pollution from power sources causes health problems. This is why I support the reduction in CO2. This reduction will also directly lead to improved air quality here in Virginia. Finally, it can also lead us to transitioning to a renewable energy producing state which is now recognized by the Department of Energy as a large job producer.

I support as big a reduction (30% or more) in carbon pollution as soon as possible. Virginia should do whatever it can to mitigate the disatrous effects of climate change and environmental degradation.

Type over this ext and enter your comments here. You are limited to approximately 3000 words.

Or more! This is a moral issue, we can either adapt or perish.

The sooner the better. I would like to see Virginia become a leader in alternative energy for the US. Other countries are far ahead of us in this area. 

This is a good first step. A more aggressive goal should be pursued. 30% by 2020 is better, visionary, and necessary.

Keep Virginia beautiful! Protect our citizens, livelihoods, and environment by reducing our carbon footprint.

I support policies and funding for clean, renewal energy, and creation of jobs in the green sector. Let's protect the future generations by protecting our planet Earth.

Reducing carbon (and other climate forcing gases) outputs by 30% by 2030 is practical, feasible, and actually very conservative in terms of achievable. The utility companies will deny this, and counterargue, because it would mean an initial cut in their profits. But areas like the Hampton Roads area, Richmond, and Northern Virginia (DC suburbs) are low-lying and already significantly affected by effective sea level rise.

We needed to act 40 years ago. Failing to act now is ludicrous. I'd personally say that we need to reduce our carbon emissions by 50% - 75% by 2030, but 30% should be a no-brainer.

30 by 30, minimum.

We need to reduce our carbon emissions ASAP. Dominion has blocked progress for too long. It's time for VA to go green.

I cannot stop thinking about the future problems my grandchildren will face im thr future, if we continue to pollute the earth as we are currently doing. Science is real and is not made up as some people would have you believe.

I support progressively decreasing the emission of greenhouse gases into the atmosphere by electricity producers.  Renewables are getting cheaper all the time, so Virginia can do this without large financial impacts to its citizens.

Please support the most ambitious carbon reduction rulings you can muster.  The health of our commonwealth in every sector depends utterly on reducing carbon and switching over to a renewable energy grid.  99% of the world's scientists (any not bought), the United Nations, and you know this is true.  As a regulatory agency, your job is to protect the citizens you serve against corporate power and greed and against just plain mistaken thinking or a too slow response to the need for change.  Lead us to water our children can drink.  Air our children can breathe. An economy uncrippled by catastrophic climate change.  Lead us.  

I am totally against picking some arbituary percetage just because you can match it with a year without any thought whatsoever to loss of jobs, rise of costs for a fake concern.  I hope the House and Senate will vote NO on any such Bill.  How about a bill boosting high paying jobs by 30%

This is great, however, 30% isn't going to be enough, soon enough. Tell counties to remove the insanely high permit fees on solar panels. I want my business to be all solar, however, the permit costs are preventing us in doing so. Tell HOA's to allow solar panels. Hopefully Tesla's new solar roof will force legislative action to redefine everything and hopefully, they just get rid of these ridiculous restrictions.

Regulation here is simply unnecessary, the market will drive the transition to wind and solar when they are actually affordable.  As the statement on the petition says: Virginia already reduced carbon emissions by a similar amount between 2000 and 2015, while the state economy continued to grow.  That's true, it did so because of the abundance of cheap natural gas and the ability to cost effectively transition from coal fired power generation to natural gas.  The market drove the change.  Viriginia is doing the right thing by not over regulating autonomous vehicles.  The Commonwealth should follow that example and not regualte the power sector, especially when doing so would require significant subsidies.  Thank you.

I agree we need large reductions (30% or more) in carbon pollution as soon as possible. Virginia should do whatever it can to mitigate the disatrous effects of climate change and environmental degradation. Regulations should promote non carbon discharges and facilitate alternate options (reduce permit fees for solar panels).

I support wind and solar renewable energy solutions. No coal, no nuclear, and natural gas only for transition - but absolutely no fracking!

I support lowering Virginia 's carbon footprint.

Climate change is posing a serious threat to the earth and to the well-being of mankind, and it is not hard to see that it is occurring. Gone are the days of winters that build up and wind down slowly; instead winters waiver between extreme snow events and summer-like temperatures. Ice skating on local ponds is a thing of the past. Back in the 90s, climatologists predicted that global warming would lead not just to localized warming, but to extreme weather events of all kinds, and we're seeing that now. I have children whose futures I worry about constantly. We need our government to do what it can to promote the switch to renewable energy. Across the country, renewable energy has been the biggest source of job growth in the energy sector, so the argument that switching to renewable energy will undermine Virginia's economy just doesn't hold. Many European countries are also quickly ramping up their infrastructure to support renewable energy, so why not us?  Let's be leaders and not followers in the realm of energy development.

Lowering carbon pollution means greater efficiency, and more industry innovation (which means, better/more jobs).  Doing our part to mitigate climate change, which threatens Virginia's agricultural industries, is also wise.

Not only is Climate Change real, it's man made.  Let's not as Virginian's wait on the sidelines on this matter.  Let us be a leader in the Climate Chnage fight!  Let's lower carbon emissions, create jobs, and make Virginia a healthier place to live. 

Climate change is the single most pressing local, regional, national, and international issue of the modern era. Without immediate and significant action to mitigate human emissions of greenhouse gases, we are headed down a path that will destroy our future as a civilization and a species.

As an agricultural state and as a coastal state, Virginia is on the front lines of this fight. The Hampton Roads / Norfolk / Virginia Beach metro area and large swaths of the Chesapeake Bay have already begun to see devastating effects from sea level rise. Our agricultural industry is at risk from hotter summers and erratic precipitation. Virginia's snowsports industry is gasping its dying breaths as winters shrink in length. We must act now.

30% by 2030 is an extremely reasonable target. In truth, we should be aiming for a much bigger reduction. Our future and our childrens' future depends on it.

Virginia stands to suffers huge consequences from greenhouse gas pollution. Considering that the costs of being proactive are far less than those associated with the effects of health damage and sea level rise, the Air Pollution Control Board could be considered negligent for not acting to reduce pollution that has is already impacting Virginia residents and has the potential to have devastating impacts in the future. A great way to start is to reduce Total Carbon Dioxide Pollution in the Commonwealth by 30% by 2030 from Electric Generating Units.

100% renewable energy by 2030.

100% renewable energy by 2030. It's so important!

Other countries have already done the right thing!  Do it for ours!

I agree to a reduction of air pollution to our community.   High levels of air pollution leads to asthma and other health problems and acid rain which is harmful to us and our environment.

I am strongly in support of requiring at least 30% renewable sources for electricity in VA. 

Climate change is not a value based issue like abortion, and it is not one rooted in primitive bias like civil rights. No, it is a simple matter of science that can and should be acted on by our government.

My Fanily supports wind and solar renewable energy solutions. No coal, no nuclear, and natural gas only for transition - but absolutely no fracking!  There is a conflict of interest in the agencies.  Renewals Must be removed from the hands of the coal interests.  Tax breaks for all solar and wind installs for residents, not just farmers.  Metering should let residents sell their extra power back to the grid.

Please make it a goal to cut environmental pollution by at least 30% by 2030.  It is sad that our federal government seems to be going backwards but that makes it even more important for our State government to have an enlightened energy policy.

virginia should joint other states like California in reducing carbon emissions  using a variety of means...offering wind and solar as alternatives, requiring cars to meet strict auto emission standards, reducing the number of coal burning plants, etc. we also need to prevent fracking which is clearly having a negative effect in other states (earthquakes, poisoned ground water).

There is absolutely no good reason to continue building infrastructure for and/or usin carbon based fuels.  Renewables have surpassed them as a source of jobs and energy.

It's time to move forward to sane, intelligent management of our natural resources and the shift to sustainable energy. Now 

Cost for Renewable Energies are on par with fossil fuels. Wind and solar installations, energy storage of the future, create good and sustainable jobs at every level - without the health and environmental risks of fossil fuels. Germany, China and California have been paving the way, it is time Virginia follows suit! I have a small business architecture firm, specializing in design of energy-efficient net-zero or net-positive homes - a very rewarding and exciting business, and I see how much potential for growth is still in this field. Thank you for your considerations!

Let's try to beat the 30 by 30 goal!  Stop fracking and no off shore drilling!