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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10/20/22  10:41 am
Commenter: Virginia Chapter, American Academy of Pediatrics

VA-AAP Supports VA's Continued Participation in RGGI

The Virginia Chapter of the American Academy of Pediatrics supports Virginia's continued participation in the Regional Greenhouse Gas Initiative (RGGI).  Our organization has supported this program since it was first introduced in 2015 due to its protection of children in the Commonwealth from air pollution and climate change.


Since the 1990’s, market-driven reductions in air and water pollution have proven highly successful at preserving a healthy environment for children. (Stutt, 2019) Building upon the success of prior programs in the Northeast, RGGI reduces air pollution and thereby protects children’s health.


The health outcomes of RGGI have been characterized in two studies. The first analyzed RGGI’s health effects from 2009-2014 as a result of reduced air pollution. (Manion, 2017) Reductions in air pollution associated with the program prevented adverse health outcomes across the Northeast from 2009-2014, including 420-510 instances of acute bronchitis, over 200 asthma Emergency Department visits, more than 8,200 asthma exacerbations, and tens of thousands of lost work days. These and other health benefits have resulted in over $5.7 billion in health and productivity savings.


A second study published in 2020 focused on children and the developing fetus. (Perera et al, 2020) This study found that, across the Northeast from 2009-2014, RGGI-associated reductions in air pollution prevented 537 cases of child asthma, 98 instances of autism spectrum disorder and 112 pre-term births.


While reducing criteria air pollutants, the program also has reduced carbon emissions from power plants in participating states by almost 50%, a 90% greater reduction than in non-participating states. (Stutt, 2019) Protecting children from climate change is a priority of the Virginia Chapter of the American Academy of Pediatrics and is the basis for our support of Virginia’s participation in RGGI since 2015.


The Regional Greenhouse Gas Initiative is working to protect the health of current and future children. We therefore support Virginia’s continued participation in this program.


  1. Stutt J. The Regional Greenhouse Gas Initiative: 10 Years in Review. Acadia Center. 2019
  2. Manion M, Zarakas C, Wnuck S, Haskell J, Belova A, Cooley D, et al. Analysis of the Public Health Impacts of the Regional Greenhouse Gas Initiative. Abt Associates, Cambridge, MA. 2017
  3. Perera F, Cooley D, Berberian A, Mills D, Kinney P. Co-benefits to children's health of the U.S. regional greenhouse gas initiative. Environmental health perspectives. 2020;128(7):77006. doi: 10.1289/EHP6706.
CommentID: 191053