I am writing to indicate my strong support for Virginia's efforts to regulate CO2 emissions from power plants through a cap-and-trade allowance system and participation in RGGI. However, some expansions to the current proposed regulations are needed to strengthen its benefits to both the clean energy/renewable energy economy in the Commonwealth and to help our agricultural sector as well. Specifically:

1) The regulations should include opportunities for CO2 emission offset allowances in agriculture (forest offsets and avoided methane from agricultural manure management operations). This would enable the farm sector to benefit financially from efforts to protect forests and to afforest, and from efforts to mitigate methane, a highly potent GHG.

2) Very critically, a Commonwealth carbon cap-and-trade regulation MUST make a provision for the voluntary renewable energy market set-aside allocation mechanism, as allowed for by RGGI. The set aside is a mechanism that enables the vountary renewable energy market to contribute to the state's overall CO2 mitigation goals and compliance opportunities, and are critical for the process of reducing emissions. It is also needed to avoid the unintended consequence of weaking the in-state economy for renewables. Because of Green-E regulations (the leading certification authority for voluntary green power), the absence of a set aside could cause Green-E to quit certifying in state green power. 

On this point the Center for Resource Solutions explains that "If a cap-and-trade program is adopted and implemented without a voluntary renewable energy set-aside mechanism, Green-e may be unable to continue to certify voluntary sales of renewable energy from the state, or the additional cost of allowance retirement to the voluntary purchaser may preclude certified sales from generation in the state. This would mean that voluntary buyers in these states will get their certified renewable energy from outside of the state in the future. A voluntary renewable energy set-aside will allow for this demand to be met by resources in the state—allowing your state the opportunity to maintain theprivate investment dollars that may otherwise go elsewhere." See the CRS factsheet here: https://resource-solutions.org/wp-content/uploads/2017/11/Voluntary-RE-Fact-Sheet.pdf.

Respectfully submitted,

Maria Papadakis