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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8/30/23  11:02 pm
Commenter: Christopher Leyen, Virginia League of Conservation Voters

Virginia LCV Opposes RGGI Repeal

On behalf of the Virginia League of Conservation Voters, I am writing in opposition to the adoption of the final proposed rule repealing Part VII (9VAC5-140-6010 et seq.) of the Virginia Administrative Code–effectively ending Virginia’s participation in the Regional Greenhouse Gas Initiative on Dec 31, 2023.

Removal of Virginia from RGGI constitutes a blatant end-run around the legislature and a handout to big polluters. In just two full years of participation, Virginia power plant emissions have dropped by more than 16%. Burning fossil fuels to generate electricity is a key driver of climate change, and also puts Virginians’ health in danger. In 2021, power plants in Virginia produced 1,228 tons of sulfur dioxide pollution and 6,125 tons of nitrous oxide pollution.

Removal comes at the expense of Virginia communities that are now on their own to combat dangerous flooding. In the next 60 years, nearly 950,000 Virginians will be at risk from major coastal flooding, costing Virginia coastal communities $5.1 billion per year. By the end of this century, Virginia and the Chesapeake Bay watershed is expected to see a 20% increase in extreme precipitation compared to 1950-2000.

To prevent damage and prepare for sea level rise, full funding for the Community Flood Preparedness Fund must be maintained. RGGI proceeds provided over $265 million to the Community Flood Preparedness Fund–Virginia’s only source of proactive flood prevention. The Regional Greenhouse Gas Initiative provides the only guaranteed funding that stakeholders, including local small businesses and residents, rely on to plan and execute flood mitigation and resilience strategies. RGGI funds can uniquely be used to leverage federal dollars that otherwise might be out of reach.

This repeal effort will also lead to a heavier energy burden for vulnerable Virginians already struggling with household costs. RGGI benefits low-income Virginians through the Affordable and Special Needs Housing Fund, which in 2021 delivered $29 million through 35 grants across the state. The people of Virginia would be better served by executive agencies and appointed boards working to ensure these funds are provided to those in need in a timely manner, rather than cutting off the only dedicated source of program funds.

Virginians overwhelmingly support climate action and want to see us stay in this vital program that’s already yielding results for our Commonwealth. Two-thirds of Virginians who soundly support staying the course on cutting power plant pollution and addressing the climate crisis. During the Proposed Regulatory Action Comment Period, over 88% of public comments were in favor of Virginia staying in RGGI. During the NOIRA Public Comment Period, nearly 95% of received comments were opposed to repealing RGGI. At the conclusion of the 60-day Proposed Regulatory Action public comment period in March, the Virginia League of Conservation Voters submitted a petition to the public record with 2,085 signatures Disappointingly, these concerns shared by more than two thousand Virginians were dismissed by agency staff and disregarded during Board deliberations.

In conclusion, the Regional Greenhouse Gas Initiative is working for Virginia, bringing vital, dedicated resources to our state to protect communities from floodwaters and lower energy costs for those who need it most. We urge the Air Pollution Control Board to stop its attempt to remove Virginia from this program–for the sake of our Commonwealth’s most climate-impacted communities.

CommentID: 220027