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  11:52 am
Commenter: Sharon Shutler, Virginia Grassroots Coalition

Virginia Should Stay in RGGI

 The Virginia Grassroots Coalition, an organization which represents 10,000 citizen advocates across the Commonwealth, opposes the Air Pollution Control Board’s attempt to withdraw Virginia from the Regional Greenhouse Gas Initiative (RGGI).  Only the Virginia General Assembly has the authority to repeal the authorizing legislation, the Clean Energy and Community Flood Preparedness Act. More importantly, RGGI provides incalculable benefits to Virginians including:

  • Over $500 million from the market-based carbon auctions have been generated for (1) projects that address flood vulnerability in communities throughout the Commonwealth and (2) home weatherization programs in low-income communities. The monies RGGI generates are helping embattled frontline, flood prone communities, whether Norfolk, Buckingham County, or Tappahannock, deal with some of the severe impacts of massive flooding and sea level rise.  Importantly, RGGI is the ONLY source of monies available for proactive flood prevention.  Pulling out of RGGI would strip away critical funding needed by local governments to invest in vital infrastructure projects – disproportionately harming under-resourced, small, and rural communities.  As for weatherization, energy efficiency upgrades are the best way to lower electricity bills of our citizens who need it the most. 

  • Since RGGI, Virginia’s CO2 emissions have been reduced by 16.8% annually.  According to DEQ’s own report, this drop in emissions follows a decade in which Virginia’s emission did not decline.

  • Improvement in health to thousands.  According to Virginia Clinicians for Climate Action, data from RGGI states indicate that over five years, improved air quality saved residents of those states from over 6,000 asthma attacks, over 100 preterm births, and over 500 deaths.  The EPA has estimated that improving air quality results in public health benefits that exceed the costs by over 30 times. 

The State Air Pollution Control Board responses to these and other points raised in the previous comment period are unconvincing at best.  The Board asserts, for example, that while protection of Virginia’s communities from flooding is a legitimate “public health and welfare” issue, other sources of funding exist to replace RGGI monies including funding from the Inflation Reduction Act.  It is unclear when this other funding will be accessed and for what uses it will be put.  Irrespective, why would any State leave substantial funds on the table generated from a market-based carbon auction?  The Board also asserts that the $2.39 fee tacked onto Dominion’s residential customer bills (increasing to $4.44) to cover RGGI costs incurred by Dominion is simply too much.  The Virginia legislature can lower bills by closing loopholes in the State’s utility laws which have permitted Dominion to overcharge its customers for years.  Given the crises faced by communities throughout the Commonwealth, we should use every dollar available to protect public health, welfare, and the environment.  It is imperative for Virginia to remain in RGGI and say yes to other revenue sources as they become available.  

Sharon Shutler, Amy Bergner, Meredith Haines, Monique Hanis

Leadership Team, Climate & Clean Energy Working Group, Virginia Grassroots Coalition


CommentID: 218680