On behalf of the Virginia Oil and Gas Association, we submit our support for the Proposed Regulation for the Amendment and Repeal of 9 VAC 5-140 Regulation for Emissions Trading (Proposed  Repeal).  Thank you for the opportunity to comment on behalf of our employees and customers who rely on affordable, safe, and efficient energy.

Affordable and available energy, economic prosperity, and human health are foundational
interconnected requirements for our economy and way of life. 

RGGI is an additional tax that will escalate the cost of electricity yielding Virginia less economically competitive.

The Natural Gas Industry as a whole is at the forefront of lowering greenhouse gas emissions, and leads power-sector emissions reductions across multiple areas and basins. Between 2005 and 2019, natural gas was responsible for 61% of cumulative power-sector CO2 emission reductions through changes in the fuel mix -which EIA defined as being the major driver of those sector reductions.

Lastly, the Appalachian Basin continues to provide organically reduced methane emissions from production infrastructure with as much an 82% reduction despite growing production throughput values.

We appreciate your consideration of these comments in support of the repeal of RGGI.  support the Youngkin Administration’s efforts in pursuit of a commonsense approach to energy and the environment.