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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8/27/23  11:08 pm
Commenter: John B. Reeves P.E.

Virginia MUST stay on the Strategic course and remain in RGGI

Virginia should clearly REMAIN in the “RGGI” program.  WHY?

1- “The General Assembly mandated Virginia’s participation in the Regional Greenhouse Gas Initiative (“RGGI”) through legislation. Therefore, the Air Pollution Control Board and DEQ *cannot override this legislative mandate through the regulatory process.” I strongly agree with this conclusion from "Wetlands Watch".       I also fully support the efforts and Fairfax Court petition filed against the Va. DEQ and Va. Air Pollution Control Board to stop this *illegal and poorly justified withdrawal of Virginia from RGGI at the end of 2023.

2- Pulling Virginia from this *successful program (12 States now and getting stronger) would necessitate finding and budgeting alternate ways to reduce our carbon emissions that probably would be less effective plus more costly to manage.

3- Funds allotted to Va. from RGGI CO2 auctions have large benefits:

a- Over $265 million to the Community Flood Preparedness Fund – Virginia’s only source of proactive flood prevention. Critical nature-based *resilience projects - from living shorelines to flood prevention steps to expanding wetlands. These projects slow erosion and reduce the flow of sediment, nutrients and toxins to the Chesapeake Bay.

b- Over $294 million to fund energy efficiency retrofits for low and moderate-income homes and new, energy-efficient affordable housing. Such conservation projects (often called "Negawatt" projects) reduce electric bills, carbon emissions (+associated air & water pollution), and stress on the generation/Grid system. Yes, Virginia could add enough funds to Va. Biennial Budget to gain such important benefits; but really, would that happen?

4- The whole RGGI program contains key practical steps toward slowing the harmful (often devastating) impacts of anthropogenic climate change. All Virginia Exec. staff or politicians pushing for this RGGI withdrawal must review the March 20, 2023 "Synthesis Report" from the IPPC (ending their 6th assessment cycle) and understand the rapidly coming damages and human suffering from anthropogenic climate change.

Therefore, Virginia must stay in this important RGGI program. 


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