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
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8/7/23  11:29 pm
Commenter: Anonymous

Lacks source of legal authority and social costs of repeal

The fiscal impact reports states that the primary advantage to the public includes reduced residential and commercial energy costs but it does not address disadvantages of the public due to unclean air.   The fiscal impact report states that the primary advantages to the Commonwealth are reduced energy costs but does not account for social and environmental costs in unclean air.   The fiscal impact report states that the Commonwealth will also benefit from greater certainty and transparency in the energy markets, but again the many disadvantages are not stated or weighed, rather, the report says there are no disadvantages to the public or the Commonwealth associated with this regulatory change.  I agree with other commenters that the proposed regulation appear unconstitutional as the requirement for the program is statutory and cannot be repealed by regulation.  

CommentID: 218530