Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
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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3/31/23  4:40 pm
Commenter: George Kralovec

Stay in RGGI

Keep Virginia in RGGI

I am a voter and have made my home in Annandale, Virginia since 1978.  I have no financial stake in any of the parties on either side of this issue, other than to want my Virginia taxes to be wisely spent by the Commonwealth.  I strongly oppose the proposed action to repeal Virginia’s participation in the Regional Greenhouse Gas Initiative (RGGI).

I was immensely gratified when Virginia joined RGGI in 2020.  Two-thirds of Virginians support Virginia joining RGGI. 

RGGI is a cooperative effort among twelve Eastern states to reduce carbon dioxide (CO2) emissions from power plants within each participating state.  RGGI employs a proven, market-based, cap-and-invest mechanism to accelerate employment of carbon-free energy sources like wind and solar, thereby addressing a massive generational injustice and at the same time providing essential funding for community flood protections and helping low-income families reduce their energy bills.

RGGI today is a widely recognized success, with its process improvements over the years being emulated around the world, including by the European Union.  Since its inception in 2009, RGGI emissions have reduced by more than 50% -- twice as fast as the nation as a whole – and so far raised nearly $6 billion to invest into local communities -- a “win-win” for all.   Further, electricity prices have simultaneously been cut by 5.7% in the first nine years in RGGI states while increasing in the rest of the country, RGGI state economies have grown faster than non-RGGI economies by 31%, and a 2017 study found that from 2009-2014, RGGI-associated reductions in air pollution resulted in $5.7 billion in health and productivity savings.   A peer reviewed econometric study published in Energy Economics (Volume 51, September 2015, Pages 581-589) quantified emissions reductions due to RGGI and those due to other factors such as the recession, complementary environmental programs, and lower nature gas prices.  The analysis shows that after the introduction of RGGI in 2009 the region’s emissions would have been 24% higher without the program, accounting for about half of the region’s emission reductions during that time, which were far greater than those achieved in the rest of the United States. 

As a late-comer to RGGI, Virginian’s missed out on these associated economic, health, and environmental benefits, but that’s no reason not to take advantage of them going forward.  In fact, participation is already working for Virginians.  In less than two years RGGI has produced $523 million in revenue for shoring up community flood protection and helping low-income families reduce their energy bills.  RGGI is the sole source of revenue for the Virginia Community Flood Preparedness Fund (CFPF).  Of the $235.6 million in flood preparedness revenue, 25% is set aside for flood protection in low-income communities.  Another $261.8 million is allocated to low-income household energy efficiency and weatherization. 

Also please consider carefully the extensive analysis submitted by the prestigious non-partisan climate and energy econometric house, Resources for the Future, which concludes that, “In summary, the withdrawal of Virginia from RGGI would erode the direct benefits to Virginia residents that are a focus of the Virginia Clean Energy Act, would raise electricity prices over the decade, and would undermine the implementation of the VCEA.”





At the level of government where “the rubber meets the road” the Mayor of Richmond, Levar Stoney, in his 2/27/23 comments to this proposal urges Members of the Air Pollution Control Board to continue Virginia’s participation in RGGI noting that local governments alone cannot solve the climate crisis and that RGGI is a common sense, market-based, cost-effective, and critically important program delivering a multitude of benefits across Virginia.  For Richmond he cites $1,246,047 in RGGI CFPF funding that is increasing flood protection in some of the most vulnerable and underserved Richmond neighborhoods and $720,000 in much needed health and safety repairs for low-income households from the RGGI funded Weatherization Deferral Repair program.  

Perhaps most concerning is that 17 Hampton Roads cities and counties oppose Virginia leaving RGGI and last year so notified the state by letter.  The letter, from the Hampton Roads Planning District Commission, noted the Hampton Roads region is significantly vulnerable to both current and future flooding and stated that, “Until an alternative source of revenue for the Community Flood Preparedness Fund has been identified, any decision to remove the Commonwealth from RGGI will be premature. 

Hampton Roads municipalities have come to rely on RGGI as a funding source for work to improve flood protection. Almost half the money Virginia receives from the allowances bought by power plants goes to the Community Flood Preparedness Fund, for which there is no other funding source.

Half of the money granted under the program so far – about $25 million out of $45 million total – has flowed to flood-prone Hampton Roads.

Ben McFarlane, senior regional planner for the Hampton Roads commission, has been reported as noting Hampton Roads is the most vulnerable region in the state (to flooding). “So having this source of funding has been a huge deal for our communities.

I strongly disagree that a RGGI charge of less than $2.50 a month on electric bills will unfairly burden Virginia’s residential utility customers, given the sizeable revenue RGGI provides in return targeted at those most unfairly burdened by climate harms. 

There’s no doubt:  It’s not the average rate-payer that will be burdened by the small extra charge on our electric bills for RGGI. The Virginians adversely affected by Virginia withdrawing from RGGI will clearly  be those who, through no fault of their own, are living in flood-prone areas across the Commonwealth or those who cannot afford to renovate for energy efficiency. 

RGGI was a big step forward by Virginia to join with eleven other states to reduce carbon pollution and associated health costs while simultaneously generating substantial revenues for the state to invest in unmet needs of local underserved and vulnerable communities, as Virginians see fit.   As a Virginia voter and taxpayer since 1978,  I urge the members of the Air Pollution Control Board not to take the big step backward of withdrawing Virginia from RGGI.   

Stay in RGGI.

Thank you.  


CommentID: 216187