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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8/14/23  11:37 am
Commenter: Joan N Curry

RGGI is the Law and Benefits all Virginians

Regional Greenhouse Gas Initiative

In April 2020, Virginia legislature passed the Clean Energy and Community Flood Preparedness Act that set out the guidelines for joining and implementing the Regional Greenhouse Gas Initiative (RGGI). RGGI is a carbon cap and trade market involving 10 other New England and Mid-Atlantic states. RGGI requires power producers to purchase carbon allowances at quarterly auctions for each ton of carbon they emit. The proceeds of auctions are then returned to participating states. In Virginia,  utilities are allowed to recover from ratepayers the "necessary" costs of buying allowances at auction. The number of allowances available to producers declines annually. The system is designed to incentivize power generators to switch from forms of energy that produce greenhouse gases that are driving climate change to non-carbon emitting sources. In over a decade of program implementation, power sector emissions in the RGGI states have declined by more than 50% relative to 2005 and provided net benefits to their economies on the order of $4 billion.

45% of all RGGI revenue goes to projects to protect Virginians from flooding caused by rising seas and more intense storms:  The law authorizing Virginia's participation in RGGI requires 45% of all proceeds from the auctions go toward the Community Flood Preparedness Fund (CFPF) . Further provisions require that at least 25% of the flood preparedness funds go to projects in low income areas. As of December 2022, RGGI had raised $524 million with allocations going to the CFPF of $235 million. Flooding from sea level rise and more frequent intense rainstorms from climate change are set to accelerate in the coming decades.Since 1927 alone, the sea level has risen by about 1 1/2 feet in Sewells Point at the Naval Station Norfolk in the Hampton Roads area (and an additional foot is predicted by 2050). "Between 2020 and 2080, the number of residents living in homes exposed to extreme coastal flooding will triple to about a million; roadways flooded will increase from 55 to 340 miles and 170,000 acres of tidal wetlands will be permanently inundated." [Virginia Mercury;12-8-21]. In addition, the Hampton Roads area, the Middle Peninsula, the Northern Neck, the Eastern Shore and cities such as Alexandria will also experience more frequent flooding due to high tide events.

50% of RGGI proceeds go to low income households to upgrade energy efficiency for cost-savings, health and safety:  Another 50% of RGGI proceeds ($250 million as of December) provide capital for low income energy efficiency upgrades to both new and existing housing. The program administered by Housing Innovation Energy Efficiency (HIEE) and Affordable and Special Needs Housing (ASNH) works in tandem with the federal weatherization program to provide funds for major health and safety repairs. Low income households face a disproportionately higher energy burden (as a % of gross income) due to energy inefficient housing. Since its inception, HIEE funding from RGGI has financed nearly $31M in energy-efficient upgrades for new and renovated affordable housing. According to the Piedmont Housing Alliance, "lower income families will spend hundreds of dollars less a year on energy costs on average – hundreds of dollars that translates to stable, safe, warm home environments." RGGI dollars are being used in every region of Virginia and are creating high-paying jobs that cannot be outsourced. 

Environmental and faith-based groups, Virginia localities and many legislators oppose Gov. Youngkin's efforts to withdraw from RGGI:  In September of 2022, Gov. Youngkin outlined a plan to withdraw Virginia from RGGI, a move critics say is not allowed by law, would drain important state programs of funding, and would hurt the fight against climate change. The plan involves regulatory changes that govern the state's participation in the market. Regulatory process typically takes 18 to 24 months start to finish. Virginia's 3 year contract with RGGI, Inc., the body that coordinates the market, ends this year. In addition to many environmental, faith based and regional groups such as Appalachian Voices, 17 Hampton Roads cities and counties sent a letter opposing Gov. Youngkin's proposal to withdraw from the initiative. Recently 61 Virginia legislators signed onto a letter in support of remaining in RGGI. The entire Virginia General Assembly will be up for election in November, 2023. Now is a critical time to call on legislators to maintain our membership in RGGI and the vulnerable communities it protects. All Virginians must be allowed to decide their future and ways to confront the existential threat of climate change.

CommentID: 218679