Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
chapter
Regulation for Emissions Trading Programs [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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3/29/23  1:16 pm
Commenter: CAROLYN A WATTS

Do Not Repeal RGGI participation
 

I am writing to oppose the repeal of Virginia's participation in RGGI.  I have spent the past 45 years teaching health economics, health policy, and most recently two courses in Climate, Health and Health Care. I volunteer with the Chesapeake Bay Foundation and Virginia Clinicians for Climate Action.  

  • RGGI is important for the health of Virginians.  Virginia's continued participation in RGGI is essential both to meeting the Commonwealth's goal for greenhouse gas (GHG) emissions reduction and to the ultimate goal of increasing the health of Virginians.  Evidence about the impact of rising GHG emissions on a wide array of health metrics is overwhelming.  GHG emissions increase the incidence and severity of respiratory illnesses, asthma attacks, premature births, heart attacks, cancer, and heat-related illnesses.  Higher emissions contribute to climate "weirding," which in turn promotes the spread of other diseases as allergy seasons are longer, disease-carrying insects expand their reach, and the health consequences of extreme weather events become more severe, more frequent, and more widespread.
  • RGGI is important for the economic health of Virginia.  There are negative economic effects from increasing GHG emissions as well: more missed days of school and work, reduced productivity during work days, and the medical and other costs of the health and structural effects.  Flooding damages alone are estimated to be $79.1B if GHG emissions continue to increase.
  • RGGI is working:  In the 6 years since RGGI was created, participating states have saved $5.7B in health care costs alone.  RGGI has also provided over $200M for flooding mitigation and prevention for Virginia residents. Since joining RGGI, Virginia's power plant emissions have consistently decreased - by 12.5% between 2020 and 2021 and by nearly 8% between 2021 and 2022.  In the 10 years preceding our participation in RGGI, emissions in Virginia were fairly constant with no discernible trend.
  • RGGI will help Virginians with their utility bills as fossil fuel prices continue to increase. RGGI provides subsidies for lower income households to increase the energy efficiency of their homes, thus reducing their purchases of any kind of energy - a win/win no matter what source of energy dominates.  The program also provides incentives for energy companies to move away from fossil fuels permanently.  The supply of alternative sources of energy increases every year and the price of energy produced by these sources decreases, providing additional savings to all energy consumers in Virginia, both residential and commercial.
  • Finally, RGGI is the law.  The legislation that was passed by the General Assembly in 2020 mandates that the Commonwealth participate in RGGI.  The Administration must comply.

In summary, RGGI is good for Virginia and Virginians.  The benefits are why ten other states created and participate in RGGI, and why the General Assembly voted to make Virginia the 11th RGGI state.  Please do no make the mistake of reversing that important decision.

CommentID: 214854