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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10/22/22  11:29 am
Commenter: Lawrence Connell

For our health and our economy: Keep Virginia in the Regional Greenhouse Gas Initiative

Please Keep Virginia in the Regional Greenhouse Gas Initiative


I am writing to express my opposition to Gov. Youngkin's proposal to withdraw Virginia from the Regional Greenhouse Gas Initiative (RGGI).  RGGI is effective in reducing greenhouse gases, and provides Virginia with revenues needed for our communities to adapt to climate impacts that are already happening.  Instead of abdicating from action to mitigate and adapt to climate change, Virginia should focus on reducing emissions (e.g. from state agencies), increasing energy efficiency, and providing incentives for business and consumers to do the same.  Further reasons for remaining in RGGI are grounded in both public health and economics.

1. Public Health: RGGI protects the health of Virginians both in the short term and in the long term.  Burning of fossil fuels releases carbon dioxide (CO2), a greenhouse gas which is driving the climate change emergency worldwide. Burning of fossil fuels also releases other air pollutants such as fine particulate matter, volatile organic compounds, oxides of nitrogen, oxides of sulfur and other harmful substances. It is the air pollutants other than CO2 that have the more immediate adverse impacts on human health. For example, fine particulate matter is so small that it can enter into the lungs, move into the tiny blood vessels and then move throughout the body. The presence of these fine particles in the blood stream then contributes to the occurrence of strokes and heart attacks. Volatile organic compounds (VOCs) and oxides of nitrogen (NOx) contribute to the development of ozone in the air. Ozone can exacerbate asthma and chronic obstructive pulmonary disease (COPD, also called emphysema) and can contribute to the new onset of asthma in children. All of these medical problems are devastating to the individuals who have them and the families who support the individuals with these diseases. 

The health problems associated with air pollution are not evenly distributed. Low wealth communities and minority communities are more likely to be exposed to air pollution and more likely to have health problems as a result of that exposure. 

RGGI has proven to reduce air pollution in the states where it is in force and in neighboring states as well. Virginia’s own Department of Environmental Quality has documented this fact. Less air pollution for Virginia means better health for Virginians – fewer asthma attacks, fewer children with the new onset of asthma, fewer adults with exacerbations of chronic obstructive pulmonary disease (also known as COPD or emphysema), fewer individuals with problems with their pregnancy and with preterm birth and fewer adults with heart attacks and strokes. Less air pollution and better health means fewer days-lost from work and school. According to the Acadia Center review of the RGGI program, in just 10 years, participating states realized $5.7 billion in public health benefits thanks to RGGI

Climate change is harmful to human health in many ways beyond air pollution. Virginia and the world need to decarbonize as soon as possible to stabilize the climate and prevent the most catastrophic outcomes of climate change. While RGGI alone will not bring Virginia to carbon neutral by 2050 as required by Virginia law, it is a significant step in that direction. For the health of Virginians, the Commonwealth must continue to be in and reap the benefits of the Regional Green House Gas Initiative.   

2.  Economics (Cost/ Benefit Analysis): From an economics perspective, a comprehensive analysis will almost certainly demonstrate the long-term broad and individual net economic benefits of remaining in the program. The analyzed benefits and costs remaining in RGGI must include:

  • Costs associated with lost outcomes from lost program funding, such as for the Community Flood Preparedness Fund and weatherization assistance programs. Any regulation must analyze the cost associated with flooding and the impact of losing CFPF projects to address flooding. Specifically, regulatory analysis must address costs included in Robert M. McNab’s Study Projecting the Cost of Recurrent Flooding in Virginia and the loss funding for flooding resilience projects that will reduce such costs.
  • The analysis must recognize the actual (not modeled) impact of RGGI on rate costs in other states and discuss the mitigation of RGGI on other energy cost factors, including the long-run electricity cost reductions associated with renewables development. The analysis must describe the incremental cost impact of RGGI in context, not nation-wide, but in similar economic and energy systems.
  • The mandate for the regulatory change in Executive Order 9 states that typical bills increased $2.39 per month or $28.68 per year due RGGI. The Notice of Intended Regulatory Action cites the US Department of Energy that the average cost of energy in Virginia is $2,323 per year. The increase associated with RGGI thus represents a 1.2 percent increase to the average energy cost. The impacts of coastal flooding alone, described above are expected to reduce state economic output by over 13 percent. Losing the climate change mitigation of reduced fossil fuel consumptions and adaptation benefits from resilience investments associated with RGGI will result in reduced economic output from future flooding. Additional climate impacts, such as extreme heat, hurricane intensity, drought, etc. must also be considered.
  • The Notice of Intended Regulatory Action anecdotally described the costs of the Coastal Virginia Offshore Wind Project, but failed to disclose costs of non-renewable projects that Dominion is investing in that may require rate payer increases. If one project is considered, then all projects that could cause rate payer increases based on development costs must be included for fair comparison.
  • The variable and ongoing cost of fuel sources must be included for all components of the energy system. That is, the cost of renewable production may be higher upfront, but lower over time, while non-renewable costs are both high (capital-intensive) upfront and high and volatile into the future (as seen this year). Shifting to sources that do not rely on fossil fuels will allow cost reductions in the medium and long term and on a levelized basis over their useful lives.
  • Any analysis to support withdrawal would have to demonstrate that RGGI is making Virginia less competitive than other states with which it is competing for business and residents, as was stated without such evidence in the notice. Any reductions in competitiveness claimed due to marginal utility rate increases from participation in RGGI must be balanced with considerations of the benefits of climate preparedness, lower pollution/improved health (as noted above), and alignment with national and international commitments on greenhouse gas mitigation. 

My views are informed by my professional experience as environment director for a nonprofit agency, as a former economic/commercial officer for the US Dept. of State, as a lending officer for a leading commercial bank, and as a Virginia homeowner and voter since 1994.

CommentID: 193685