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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8/25/23  2:43 pm
Commenter: Audrey Clement, Candidate Arlington County Board

Removing Virginia from RGGI Is Contrary to the National Interest

In June, 2023 I had the good fortune of touring Norfolk Harbor while attending a family reunion in Virginia Beach. According to Wikipedia:

“Norfolk holds a strategic position as the historical, urban, financial, and cultural center of the Hampton Roads . . . The largest naval base in the world, Naval Station Norfolk, is located in Norfolk along with one of NATO's two Strategic Command headquarters. Additionally Norfolk is an important contributor to the Port of Virginia. It is home to Maersk Line, Limited, which manages the world's largest fleet of US-flag vessels. This low-lying coastal infrastructure is very vulnerable to sea level rise, with water levels expected to rise by more than 5.5 feet (1.7 meters) by the end of the 21st century.”

In a nutshell one of the most important military installations in the world together with an equally important civilian seaport is at risk of climate change induced flooding. Yet the state of Virginia is removing itself from RGGI, which has already provided millions of dollars for flood mitigation in the Norfolk vicinity. This is truly remarkable not only because the proposed executive action is unlawful, but because both U.S. economic and military interests are at stake in Norfolk Harbor.

The Governor argues that the RGGI compliance costs that Dominion has passed on to consumers constitutes a regressive tax, and he’s right. But the method by which he proposes to correct the problem, is not only unlawful, it is contrary to the national interest.

What the Governor should do is propose legislation that will bar Dominion from passing some or all of RGGI compliance costs on to consumers, not refuse to enforce a duly enacted statute of the Commonwealth of Virginia. Only if the legislature reviews the existing Virginia Clean Economy Act and considers ways to revise it, can a compromise be reached that incentivizes Dominion to reduce fossil emissions, while shielding consumers from regressive taxation.


CommentID: 219764