Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
chapter
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
Stage NOIRA
Comment Period Ended on 7/26/2017
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7/25/17  2:38 pm
Commenter: Jon Ward

Cut CO2 Emissions to Support Global Targets
 

I encourage the Commonwealth of Virginia to implement a CO2 cap-and-trade system that:

  • Includes an "Emissions Containment Reserve," such as that being discussed among the RGGI states, to reduce the allotment of CO2 allowances if their price falls to a specified level, incentivizing the market to reduce emissions below the cap if market conditions allow.
  • In working with other states in setting the cap's aggressiveness, recognizes the particular vulnerability of Virginia's tourist, fishing, military, and agricultural industries to contuned and worsening climate change and sea-level rise.
  • Follows and regularly adapts to guidance from global climate-science experts as to the level of emissions reduction needed to restrict greehouse gas (GHG) concentrations to internationally agreed upon targets.
  • Considers well-to-plant methane leakage in the calulation of GHG emissions attributable to power plants.
  • Directs proceeds of CO2 allowance sales to energy-efficiency projects and fossil-industry-worker retraining, and not to electric utilities.  Utilities earn a return on equity to cover risks such as regulatory changes, and Virginia utilities have continued to build gas and coal plants in the face of climate concensus and clear likelihood of future federal and state regulations.
CommentID: 62487