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  2:06 pm
Commenter: Leigh Anne Weitzenfeld


About RGGI

“The  Regional  Greenhouse  Gas  Initiative  (RGGI)  is  a  cooperative  effort  among eleven  Eastern  states  to  reduce  carbon  dioxide  (CO2)  emissions  from  power plants  within  each  participating  state.

Together,  the  participating  states  have  established  a  regional  cap  on  CO2 emissions,  which  sets a  limit  on  the  emissions from  regulated  power  plants within  the  RGGI  states.  Over  time,  the  regional cap  declines,  so  that  CO2 emissions decrease  in a  planned  and  predictable way. Since  its inception,  RGGI emissions  have  reduced  by  more  than  50%—twice  as  fast  as  the  nation  as  a whole—and  raised  over $4  billion  to  invest  into  local communities (RGGI Fact Sheet, September 2021).”

Is it Working?

  • RGGI states have reduced their carbon emissions while still experiencing economic growth (Analysis Group, 2018).
  • Carbon emissions from the power sector have reduced by more than 50%, which is twice as fast as the rest of the nation.
  • RGGI has public health benefits as states transition to cleaner energy by reducing particulate matter in air. Measurable benefits include reductions in asthma attacks, chronic bronchitis, hospital admissions, and premature deaths (Clean Air Task Force Study, 2015). The medical savings and health benefits has been estimated at $5.7 billion in the first five years (Abt Associates RGGI study, 2017).


Virginia joined the program on January 1, 2021 under the Clean Energy and Community Flood Preparedness Act (SB 1027) adopted in 2020. Under the Virginia Clean Economy Act of 2020, the state is legally bound to transition its electric grid to 100% clean energy by 2050, even if the General Assembly votes to forgo participation in RGGI.

This program is supported by Virginia business leaders, municipalities and citizens:

  • Virginia Leaders’ Appreciation Letter
  • Voters support the state’s membership in the Regional Greenhouse Gas Initiative carbon cap-and-trade program (67% to 26%) and the Virginia Clean Economy Act (67% to 28%), a law requiring the state to generate 100% of its electricity from renewable energy by 2050 (Watson Center Survey 2022).


How Does VA use the funds?

In the program’s first year, Virginia took in over $227.6 million by selling 23.7 million allowances at the RGGI auction.

  • 50%  is used for energy efficient programs for socially vulnerable Virginians
  • 45% is used for the Community Flood Prevention and Coastal Resilience Programs
  • 3% is used by VDEQ (Department of Environmental Quality) for climate planning efforts



What Do These Funds Mean for VA?

Community Flood Preparedness Fund (CFPF)

The Community Flood Preparedness Fund (CFPF) was established to provide support to localities across Virginia to reduce flooding impacts and impacts from climate change. The CFPF is guided by the following resiliency principles:

  • Acknowledge climate change and its consequences, and base decision making on the best available science.
  • Identify and address socioeconomic inequities and work to enhance equity through adaptation and protection efforts.
  • Utilize community and regional scale planning to the maximum extent possible, seeking region-specific approaches tailored to the needs of individual communities.
  • Understand fiscal realities and focus on the most cost-effective solutions for the protection and adaptation of communities, businesses and critical infrastructure. The solutions will, to the extent possible, prioritize effective natural solutions.
  • Recognize the importance of protecting and enhancing green infrastructure in all regions and in the coastal region, natural coastal barriers, and fish and wildlife habitat by prioritizing nature-based solutions.

Many of the repetitive loss area properties and properties in the floodplain will not be competitive on a national scale for FEMA grants. As the VA cities move towards its resiliency and mitigation goals to protect human well-being & property, the CFPF grant funds will be vitally important to assist our socially vulnerable neighborhoods to install smaller mitigation practices, like raising HVAC, back-up valves, flood gates, etc.

This money is also essential for capital improvement projects to alleviate flooding. The CFPF can also be used for studies such as the needed comprehensive stormwater upgrade and replacement of aging infrastructure, which is important in the context of climate change, due to more intense rainfall events and challenge the capacity of the system.


Total Action for Progress


Virginia’s continued participation in the Regional Greenhouse Gas Initiative (RGGI), is crucial to the Weatherization Assistance Program (WAP).


WAP is primarily federally funded. However, these funds are frequently insufficient or not allowed to be used to correct necessary repairs, thus causing eligible homes to be deferred.

  • The low-income families that receive weatherization services on their homes see an average energy savings of 25%, which equates to 1 metric ton of carbon reduction.
  • In 2020, the Association of Energy Conservation Professionals conducted a survey of Virginia WAP providers and determined that 1 in 5 households that apply and are eligible for weatherization services are deferred due primarily to roof, electrical, and plumbing problems.
  • Total Action for Progress (TAP), is one of 17 WAP providers in Virginia and has been providing weatherization services for nearly four decades. In the 2020 and 2021 program years alone, TAP had to defer 33 homes as they needed repairs that exceeded WAP funding, including wall and ceiling repairs, asbestos removal, furnace replacement, and more.
  • Unless funds are provided to address these issues, over 20% of eligible homes in the Commonwealth will not receive necessary weatherization services.


Virginia is a current participant in the RGGI, through which the state receives funds based on proceeds from carbon auctions. A portion of these funds have been designated for the Weatherization Deferral and Repair (WDR) program.

  • WDR funds are being used by non-profit WAP providers to address jobs that have been deferred.
  • By being able to weatherize these homes, not only do more individuals and families in need receive services, but carbon is reduced, energy bills are lowered, and homes become healthier and safer.


The RGGI/WDR process is working. To date, based on data provided by the Virginia Department of Housing and Community Development (DHCD):

•             $15.2 million in WDR funds has been obligated through agreements with the WAP program in Virginia.

•             46 projects have been completed.

•             154 projects have been submitted and are waiting for approval from DHCD, including 13 TAP jobs.

•             The completed jobs and jobs in the pipeline represent about 2.5 million in expenditures and savings to low-income families.


Through the RGGI and WDR program, an important need is being met, more homes will now be weatherized, local economies are being supported, and low-income families are being served in a way that benefits everyone.



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