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
Previous Comment     Next Comment     Back to List of Comments
10/26/22  10:52 am
Commenter: Justin M. Wilson, Mayor, City of Alexandria

RGGI is Critical to Local Government Efforts to Plan For, and Mitigate, the Impacts of Flooding

Dear Governor Youngkin,

The City Council of Alexandria urges you to keep the Commonwealth of Virginia in the Regional Greenhouse Gas Initiative (RGGI) and asks you not to repeal the CO2 budget trading program as required by Executive Order 9 (Revision A22).

In addition to driving down greenhouse gas emissions, which improves air quality and public health, Virginia’s participation in RGGI brings in otherwise unavailable revenue to assist Virginia families with energy bills through weatherization funding and flood protection through projects funded by the Community Flood Preparedness Fund (CFPF). The funding available through the CFPF is critical to efforts in localities to create and implement comprehensive flood mitigation plans, reduce the impacts of flooding, and protect the life, health, safety and property of Virginians across our great Commonwealth.

Flooding is the most common and costly natural disaster, and communities across Virginia are experiencing coastal, riverine and stormwater flooding more often, and with greater impacts to homes, businesses, roads, life, health and public safety, than ever before. We know that proactively investing in programs and projects to prevent flooding is a more efficient and effective use of taxpayer dollars than spending on flooding recovery, as exemplified by FEMA research showing that $1 spent on disaster prevention saves up to $7 in recovery costs.

Virginia’s participation in RGGI provides the sole source of funding for the Community Flood Preparedness Fund (CFPF), which is currently supported in its entirety by 45% of the revenue generated by our participation in RGGI. To date, the CFPF has granted just over $45 million to communities across Virginia in support of flood resilience initiatives and efforts to reduce the impacts of flooding in these communities. But the demand far exceeds this level of investment, with over $93 million in planning and project requests submitted during Round 3 alone.

Localities across the Commonwealth are working to put the infrastructure in place that can allow our communities to adapt and become more resilient in the face of the impacts of a changing climate. This significant undertaking requires a massive financial commitment that goes far beyond the ability of any single locality to fund with their own resources. As a Commonwealth, we must explore, and take advantage, of every option to plan for and accelerate this work. This includes the CFPF, which is wholly funded through Virginia’s participation in RGGI.

In recent years, the City of Alexandria has experienced severe impacts from multiple urban flash flooding events due to intense storms caused by climate change.  In response to these events, the City created the Flood Action Alexandria initiative in 2021 to accelerate capital projects and operating programs to help mitigate the impacts of flooding caused by these storms.  The creation of the Flood Action Alexandria initiative coincided with a doubling of the local Stormwater Utility Fee and a shift in resources to develop the Stormwater Management 10-Year Plan to focus on flooding mitigation capital projects and related programs. The City’s commitment to investing in flood related infrastructure in Alexandria is clearly reflected in this $197 million, 10-year stormwater capacity and spot improvement capital program, with $136 million of investment planned over the next five years.

In addition to the City’s ongoing investment in these plans, programs and projects, the City has been awarded approximately $5.5 million in CFPF grants, which have allowed us to accelerate these capital projects and bring relief to our community even faster than previously planned. For instance, CFPF funding has allowed the City to begin delivering smaller flood mitigation projects in the equity area of Arlandria well in advance of the FY 2026 scheduled funding for the large capacity project planned for this area.  In this way, we can protect people and property from flooding ahead of our existing funding schedule while seeking to reduce the burden of the Stormwater Utility Fee on rate payers.

But the CFPF is potentially even more valuable, and critical, to localities across the Commonwealth that otherwise would not have the financial resources or professional expertise to even take the first steps towards resilience, including developing comprehensive flood vulnerability assessments and action-oriented flood mitigation plans.

Communities across Virginia need to plan for, mitigate, and build resilience to the climate change impacts being felt today. The dedicated source of funding for the Community Flood Preparedness Fund provided by Virginia’s participation in the Regional Greenhouse Gas Initiative is critical to our ability to do the work of flood mitigation and resilience planning in our communities. We urge you to keep the Commonwealth of Virginia in the Regional Greenhouse Gas Initiative and ask you not to repeal the CO2 budget trading program as required by Executive Order 9 (Revision A22).


Justin M. Wilson

Mayor, City of Alexandria

CommentID: 198268