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  9:41 pm
Commenter: G. Lindemann

Plan to pull Virginia out of RGGI is illegal & irregular, and if carried out would confer great harm

I appreciate the opportunity to comment, as RGGI confers great benefit to all Virginians.

My purpose in this comment is to emphasize both the illegality and irregularity of Governor Youngkin’s attempt to pull Virginia out of RGGI. That Virginia must participate in RGGI is settled law, and cannot be repealed either through Executive Order, or by action of either DEQ directly or DEQ’s Air Pollution Control Board, as neither have such authority.

Moreover, any such action attempting to pull Virginia out of RGGI will trigger a cascade of costly and lengthy litigation, whose considerable expense will be foisted upon Virginia taxpayers. Compounding the harm, Virginia’s taxpayers stand to lose even further as such litigation also would likely block, for indefinite periods, the vast benefits to our citizens that the RGGI program has already proven it produces. These strongly negative outcomes render impotent the flimsy “taxpayer energy cost protection” argument the Governor weakly offers as motivation for his RGGI posture.

Thank you, again, for this opportunity.


CommentID: 202184