Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
chapter
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
Stage Proposed
Comment Period Ended on 3/31/2023
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3/23/23  11:27 am
Commenter: Mary Korendyke

Stay in RGGI
 

Frankly, I'm unamused by the language of the mandate and impetus. The numbers and statistics are intentionally misleading. In the very first paragraph, it gives the increase for individual households for a month, but then in the next sentence, the scale is changed from individual households' monthly increase, a few bucks, to ratepayers' total cost over four years, a big scary number of 1-1.2 billion. This isn't a comparable example. To start, just who is actually included in ratepayers? Based on the prior sentence, that sounds like both households and industrial customers. So, how much is the average individual household going to pay over four years? What's the monthly average of that time period? How does it compare with the current monthly average? All these questions should be answered in the document, clearly and plainly, yet the document deliberately hides behind confounding numbers. Why obfuscate if the data supports you? 

Oh, yes, there are lots of statistics about the increase in electricity prices. I'm especially impressed by the increase in July 2022, a whopping 1.7%. Remarkable. Who could have imagined it in the hottest month of the year when everyone is trying to stay cool? My point is attribution. How much did RGGI actually change the cost of electricity? How much would it have changed if Virginia hadn't been in RGGI? These are questions that I was hoping would be answered in the document, but weren't. 

Ah, but it seems attribution is the point in this case. Specifically, how much of Virginia's emissions decrease is due to RGGI? What's that, you don't know? The decrease is probably due to other things? In a shocking twist of events, the EPA monitors power plant emissions. And if one were to go to the EPA's Clean Air Markets Program Data, which provides hourly information, one could see for oneself using the very user friendly interface a 16.8% decrease in annual power plant emissions since RGGI was implemented. Gasp.

This is ridiculous and yall know it. You're blatantly ignoring around 80 pages of expert witnesses telling you why this plan is necessary for environmental, public health, and long-term economic reasons. Oh sure, you say that all of this stuff is important, but that it needs to be addressed by something else. Okay, so what is that something else? Even if the RGGI sucks as much as you say it does, it'll have to do until we can replace it. You think we can't afford RGGI, but we really can't afford not having something in place. 

Stay in RGGI.

CommentID: 213266