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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10/25/22  1:53 pm
Commenter: Ed Ashley


I oppose the attempt to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI). Virginia deserves the same benefits that RGGI has brought to other states, including: better public health, substantial reductions in climate-warming greenhouse gasses and an influx of funds to states’ budgets.

Our home in York County is 63’ above sea level and we have flooding in areas within 1 mile of our home. We have friends closer to the York River who have had severe flooding during hurricanes with water in their home half way up the first floor. Our research (NOAA) indicates that the Greenland ice sheet will contribute 6-23 feet of sea level rise when the ice sheet melts down. When the Antarctic ice sheets melt that will add 190’ to the sea level. All the ice masses on this planet are melting simultaneously, continental ice sheets and glaciers, so we can expect significant sea level rise over the next 50 years. We have rosier predictions that that level of melt will not happen until the end of the century although melt rates are much higher than initial predictions and sea level predictions have historically underestimated actual conditions.

But climate change is already showing us its terrifying effects. Yet our governor is one of the large number in our population that believes global warming is a hoax and will cause minimal disruption. Well, that is just WRONG. Nations are already experiencing unprecedented drought, fires, crop failures, severe rain and flooding, and huge population strife and migration from climate change. Youngkin must have slept through the huge fires in our west, Australia and Greece in the last 4 years, and the severe flooding in Germany and Pakistan, or the famine in Ethiopia.

The RGGI is intended to take action toward these catastrophes that are NOW encompassing the whole planet, not just Virginia. The data shows that RGGI is already reducing greenhouse gas emissions and contributing hundreds of millions of dollars to this state for preparedness measures at the local level to combat sea level rise and its huge costs in property damage, disruption of lives, damage to area economies, and the loss of businesses and jobs.

RGGI is helping Virginians right now. Virginia’s participation in RGGI generates funds that are: (a) providing safe, affordable and energy-efficient homes to low-income families in ways that were never possible before RGGI; and (b) providing dedicated funding to localities to plan for and prevent recurrent flooding. There is a massive need for this funding. Flooding damages, for example, will cost the state $79.1 billion if left unchecked. "In 2021, Virginia received $102.4 million for the CFPF. Over the next ten years, RGGI proceeds could generate upwards of $750 million for the CFPF – but only if Virginia stays in RGGI."

We cannot afford to abandon RGGI, we, in fact, need to expand it. RGGI is working and reducing missions easing the impact on the health of Virginians. Even Youngkin’s administration admitted as much in a recent report, concluding that RGGI “has a long track record of emission reductions since the beginning of the program.” This has huge implications for our whole population in terms of life longevity, healthcare burdens and expenses. In just 10 years, participating states realized $5.7 billion in public health benefits thanks to RGGI.

Virginia should maintain its participation in RGGI. RGGI is mandated in the 2020 law mandating Virginia’s participate in RGGI. The repeal is unlawful. The RGGI law was passed by the Virginia General Assembly and Youngkin cannot just brush aside the laws he disagrees with.

Youngkin should fix the utility code not repeal RGGI. His administration should focus on utility rate reform. Dominion has scammed Virginia for decades allowing it to overcharge customers with its monopoly position. It has has been allowed to rewrite the utility code in its favor, while over investing in risky fossil fuel power plants. The administration should abandon this unlawful RGGI repeal attempt and instead support monopoly utility rate reforms.

CommentID: 196602