Charles Vaughn Ware

Richmond, Virginia 23225-3556

March 29, 2023

The Virginia Air Pollution Control Board

111 East Main Street, Suite 1400

Richmond, Virginia 23218

Attention:  Ms. Karen G. Sabasteanski

Karen.sabasteanski@deq.virginia.gov

VA DEQ does not have the authority to remove Virginia from RGGI 

COMMENTS OF CHARLES WARE ON THE PROPOSED REMOVAL OF VIIRGINIA FROM A CO2 TRADING PROGRAM AS REQUIRED BY EXECUTIVE ORDER 9

To the State Air Pollution Control Board:

     I submit the following comments in response to the Virginia Department of Environmental Quality Notice of Proposed Rulemaking concerning Virginia’s participation in the Regional Greenhouse Gas Initiative {RGGI}.   The Virginia General Assembly mandated participation in RGGI in 2020 through the Virginia Clean Energy Act.  Compliance with this regional initiative requires that Virginia regulated electric power utilities, essentially a state-managed duopoly of two major electric power firms, reduce CO2 emissions, with such climate-changing pollution reductions incentivized by a “cap and trade” scheme.   The Governor of Virginia does not have authority to disregard legislation adopted by the General Assembly, nor does VA DEQ or the State Air Pollution Control Board have authority to withdraw from the agreement.  Governor Youngkin’s Executive Order Nine {2022} directs VA DEQ to evaluate costs and benefits of participation, which seems reasonable.  However, this executive order demands that “all necessary steps” to withdraw from RGGI be taken even before such an evaluation has been presented for consideration.   The 2023 session of the General Assembly rejected proposals to remove Virginia from the RGGI agreements.

     Cap and trade initiatives originated with certain “moderate” Republican and Democratic Party elected representatives who have been supported by regulated industries, and by corporations involved in fossil fuel extraction, processing, and sales.  Cap and trade incentives have been advocated as an alternative to what I believe to be a better approach to the current climate crisis.   It is my opinion that major utility corporations such as Dominion Energy should be nationalized,  and that the current practice of allowing preferred stockholders, corporate officers, and director to extract exorbitant amounts of money from these utilities should be ended, as should be our current Virginia practice of allowing unlimited bribery of elected officials {or “contributions”}  by regulated corporations.  Federal and state lawmakers should directly address the significant threats posed by the burning of coal for electric power generation {or other uses.  Additionally, lawmakers should, and really must, address our nation’s inefficient use of fossil fuels to power motor vehicles.  Our taxation of motor fuels is at levels far below those of most other industrialized nations, and this has incentivized ownership of oversized and inefficient trucks and cars.   Taxes on motor fuels could be used to build sustainable modes of transportation, such as {nationalized} high-speed freight and passenger rail systems.  Federal and state governments should and must require higher energy efficiencies for residential, commercial, and institutional businesses through adoption of new construction and materials standards.    Absent the political will in the United States to take these effective actions to address climate change, however,  RGGI should continue as a stopgap measure.  

     Governor Youngkin’s Executive Order quotes a filing by Dominion Energy with the State Corporation Commission that RGGI “will cost ratepayers between $1 billion and $1.2 billion over the next four years.”  Even if it was the role of the Air Pollution Control Board to minimize electrical utility costs {which is not the case}, this $250 million/year cost should be contrasted with the demonstrable immediate costs of sea level rise attributable to climate change.  These current costs in Virginia alone are in the hundreds of billions of dollars that will be needed to protect coastal lands from submersion.  Among critical facilities having a substantial current risk of storm-induced flooding are Dominion Energy’s Surry Nuclear Power Plant {Fukushima on the James}, and the Norfolk Naval Base and the vital Norfolk area seaports.

     I note with interest a March 21, 2019 letter from Kate Addelson of the Sierra Club Virginia Chapter to Andrew McKeon, then Executive Director of the RGGI {based in New York City}.  Addelson noted that, in 2019, Virginia was “far behind {other RGGI states} in its reductions of CO2 emissions. …  {and that} while RGGI states reduced their covered power plant emissions by 40% from 2008 to 2016, EIA data indicate that Virginia’s emissions from all fossil-fuel power plants declined by only 7%. … Virginia will have to continue reducing its CO2 emissions long beyond 2030 just to catch up {with the other RGGI states}.”  And, “we know from volumes of scientific studies that much greater CO2 reductions will be needed as we head towards 2050, just to keep worldwide temperatures from rising 1.5 degrees Celsius to 2.0 degrees C above pre-industrial levels.”

     Recent projections of global warming attributable to CO2 have been increasingly gloomy.  It has been well-documented that major energy corporations concealed their knowledge of climate change based own their own assessments of the effects of increased fossil fuel usage in the post WWII period.   This deliberate and criminal deception, and the spreading of disinformation,  have encouraged widespread denial of climate change and its implications.   On January 30, 2023, it was reported in Proceedings of the Academy of Sciences  that global warming would surpass a 1.5 degree C target established in the 2015 Paris Climate Agreement “between 2033 and 2035, … despite current efforts to limit fossil fuel pollution.”  It was also forecast that a two degree C  warming level would likely occur by 2050 despite currently proposed pollution control efforts.   There is a consensus among climate scientists that a two-degree increase would present an existential threat to human civilization. 

     I call upon every member of the Virginia Air Pollution Control Board to affirm their acceptance of this consensus view.  Governor Youngkin’s Executive Order, as well as many other of his policies regarding preservation of our environment, appear to be based on fundamentalist religious superstitions,  an expedient view regarding the preservation of the rights and privileges of the ruling elite, political partisanship, and a rigid right-wing orthodoxy.  I ask that if the Board rejects an agreement that is intended to reduce CO@ pollution, and is able to sustain this rejection through the inevitable court review, that it should recommend more effective measures to address climate change.

     Submitted as a life-long resident of Virginia.