|Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
|Ended on 3/31/2023
Dear Air Board members:
The following comments are submitted on behalf of Virginia Conservation Network. VCN is a partnership of over 150 environmental organizations across the Commonwealth. I’m writing today to implore you to REJECT the proposed Regulation for Emissions Trading 9VAC5-140 and NOT withdraw Virginia from the Regional Greenhouse Gas Initiative (“RGGI”).
First, the RGGI program works to advance the Air Board’s own mission to “abate and control air pollution.” The proposed repeal would do exactly the opposite. States that have chosen to participate in RGGI have seen CO2 emissions drop while also experiencing economic growth.
Second, the Board lacks the authority to erase the existing RGGI regulations, under the terms of the RGGI law itself. The General Assembly mandated Virginia’s participation in RGGI through legislation. Therefore, the Air Board and DEQ cannot override this legislative mandate through the regulatory process.
Third, Virginia has already received tens of millions of dollars through RGGI to help fund critical programs to fight the effects of the climate crisis and support a more resilient economy. This money has been used to expand energy efficiency offerings to low-income households and protect coastal Virginia from flooding.
Simply put, RGGI is an investment in the future of all Virginians. It protects us from the pollution that worsens climate change which in turn contributes to sea level rise, it makes sure that low-income communities have resources to make vital energy efficiency improvements, and it will bring down the cost of our energy bills over time. By staying in RGGI, Virginia will continue to participate in a proven, market-based program for reducing carbon pollution from our region’s electricity sector in a manner that protects ratepayers. Virginia risks backsliding on its climate goals, forfeiting valuable funding, and harming vulnerable communities if it withdraws from the program.
I hope that you listen to the vast majority of Virginians who support this key climate program and reject this regulation to withdraw from RGGI once and for all.