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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10/26/22  3:09 pm
Commenter: Narissa Turner on behalf of the Virginia Conservation Network

This is unlawful and sets a bad precedent

I am writing today on behalf of the Virginia Conservation Network to urge the Virginia Air Pollution Control Board to reject attempts to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI)- a multi-state initiative to reduce carbon pollution- through regulatory action. Especially since the board does not have the authority to do so.

 The 2020 Clean Energy and Community Flood Preparedness Act made it so that Virginia’s Emissions Reduction Program was no longer subject only to the Air Board’s general regulatory authority, but also the specific requirements of the 2020 law.    It required Virginia to issue the Emissions Reduction Program and participate in RGGI and requires the proceeds from the sale of Virginia’s allowances to be used to help low-income families reduce energy bills and localities address recurrent flooding issues. In other words, the General Assembly decided as a matter of law that Virginia would in fact participate in RGGI. 

Furthermore, RGGI provides unprecedented and irreplaceable funding for energy efficiency improvements in low-income residences. Virginia is the only RGGI state that dedicates fifty percent of its carbon-trading funds to make both new and existing low-income housing more energy-efficient, resulting in tens of millions of dollars annually, allowing weatherization providers and affordable housing developers to provide safe, affordable and
energy-efficient homes to low-income families like never before. Only the General Assembly has the authority to cut off this vital funding source.

Virginia’s Emissions Reduction Program is benefitting all Virginians in numerous ways:

  1. Through its proven market-based mechanism, the program is working to
    drive down air pollution and improve public health;
  2. Continued participation in RGGI will help protect customers from rising
    fossil fuel prices as power plant owners reduce reliance on fossil fuels;
  3. Low-income households are getting their homes weatherized, finally
    getting the energy bill relief they need;
  4. Highly efficient affordable-housing units are under construction to help
    fill the severe affordable-housing gap with units that will come with low
    energy bills for tenants;
  5. And localities finally have access to a dedicated state fund to help address the
    increasingly devastating flooding that is happening all across the

As you can see, RGGI funding is a game-changer for the most vulnerable in our communities, as well as the nonprofits that provide them with safe, affordable, and energy-efficient housing, and a funding source to help protect them from current and future effects of climate Change.

While administration officials have suggested that other funding sources could be found to replace RGGI funds, that would be a herculean task. In 2021, the RGGI auctions brought in millions of dollars more than every other energy efficiency program in the state – combined. Virginians can’t afford to have these programs disappear, which is why we ask members of the air board to embrace, not eliminate, the positive results from the commonwealth’s participation in RGGI.

CommentID: 199491