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 Final
Comment Period Ended on 8/30/2023
Previous Comment     Next Comment     Back to List of Comments
8/7/23  6:14 pm
Commenter: Caroline Corum


Virginia needs the Regional Greenhouse Gas Initiative (RGGI). By law, 50% of RGGI revenue goes to low-income energy efficiency programs, mitigating rate increases for energy burdened households. RGGI dollars are being used in every region of Virginia. 

This year we are seeing the devastating effects of climate disruption caused by greenhouse gas emissions.  A carbon cap-and-trade program is an effective state action to mitigate emissions.  Most other actions to address the climate crisis require federal government intervention.  This is the one strategy which is within Virginia’s power to act. 

Flood damage is increasing across the Commonwealth and without RGGI we will not have the funds to cope. By law, 45% of RGGI revenue goes to the Community Flood Preparedness Fund. That’s why seventeen Hampton Roads cities and counties opposed Virginia leaving RGGI in a letter from the HRPDC

Actual revenues from RGGI have far outstripped state officials’ projections.  Alternate funding sources that have been proposed are smaller, ignore low-income households, and are contingent on available funding. The current budget surplus is the result of pandemic recovery efforts and is not a permanent source of funds.  

Furthermore, a letter that 61 legislators have already sent to the Air Pollution Control Board states, "Virginia’s participation in RGGI is mandated by law. Therefore, ultimately only a change in the law that passes both chambers of the General Assembly and is signed by the Governor can remove Virginia’s participation.” Attempts to circumvent the law will end up in court costing taxpayers.  

Since participation in RGGI was passed as legislation by the General Assembly and is now in the Code of Virginia, the Governor’s efforts to unilaterally ignore laws and effectively repeal them, threaten the purpose in having a legislative body.  These actions violate the separation of powers that is the foundation of US constitutional government. Even aside from the climate crisis we must oppose such a dangerous precedent.  

CommentID: 218520