Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
Comment Period Ended on 10/26/2022
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10/12/22  4:42 pm
Commenter: Michael Bentley, Plowshare Peace & Justice Center, Roanoke

Don't repeal the RGGI

Governor Youngkin and Acting Secretary of DNHR Travis Voyles claim that the Virginia Regional Greenhouse Gas Initiative doesn't serve our Commonwealth's citizen, and that we should withdraw from it. I think that they are wrong.  The RGGI could be improved with more aggressive emission reductions (such as by putting a price on carbon at the point of fossil fuels extraction, with cashback to consumers). Citizens Climate Lobby has been advocating for such a policy (see Nevertheless, the RGGI program has merrit. From RGGI 101 Fact Sheet, “RGGI emissions have reduced by more than 50% — twice as fast as the nation as a whole — and raised over $4 billion to invest in local communities.”  In addition, RGGI has provided a jump start for VA’s electric utilities in achieving the goals of the Virginia Clean Economy Act and the Federal Inflation Reduction Act.

Further, pRGGI is accomplishing emissions reductions for Virginia. About 45% of the proceeds go to energy efficiency projects and 50% to community flood control.  Energy efficiency projects reduce energy demand and help to keep rates lower than they would have been otherwise, while flood control will help avoid property losses, business interruptions, and damages to public roads and utilities.

Globally, nearly all climate scientists agree that global warming is accelerating and that we've already warmed the planet by 1.2 degrees C, mostly due to human emissions of greenhouse gases (GHGs). Most also say that we need to take immediate, aggressive steps to reduce GHG emissions.  Our government has already committed to reducing our GHG emissions by 50% (compared to 2005 levels) by 2030. This is inadequate, but it will mitigate the worst effects.

Virginians' opinions reflect the scientific consensus and a commitment to do our part.  According to the Yale Climate Opinion Maps 2021 - Yale Program on Climate Change Communication, 64% of Virginians are worried about global warming, 72% support regulating CO2 as a pollutant, and 66% of Virginians support CO2 limits on power plants.

The small charge on our utility bills for RGGI participation is not burdensome given the benefits of meaningful GHG emission cuts.  Given the climate crisis, Virginia shouldn’t withdraw from RGGI unless it has a better alternative – i.e., one that deeply cuts carbon emissions in a more cost-effective way.  The Youngkin Administration has proposed nothing that would be a better alternative.  We should not only stay in RGGI, we should ramp up our GHG mitigation efforts across the board.  Virginians want to go forward, not backward!

CommentID: 189302