Agencies | Governor
Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
Stage Proposed
Comment Period Ends 3/6/2019
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2/27/19  9:04 am
Commenter: Randall Freed, Climate Reality and Citizens Climate Lobby

Support for VA participating in RGGI

The Citizens Climate Lobby summarizes the current state of climate change science and policy as (1) it's happening (climate change is already well underway), (2) it's us (anthropogenic emissions are driving the change), (3) it's bad (climate change impacts a increasingly serious and will get worse), (4) there's consensus (climatologists overwhelmingly agree, based on the accumulation of piles of data, and (5) there's hope (we can forestall the worst of the changes, provided that we act fast and decisively). I agree with CCL's characterization. It's on the 5th point - there's hope, provided that we act fast and decisively - that I write you, in the context of VA's plan to link with RGGI. 

RGGI has proven to be a cost-effective market-based policy for reducing greenhouse gases and criteria air pollutants in the power sector.  It has had enormous benefits for the states that have adopted it.  VA has lagged toward the back of the pack in terms of policies and regulations to mitigate greenhouse gas (GHG) emissions and to promote clean energy. 

By using the power of market-based incentives to drive Dominion and Appalachian Power to reduce emissions in VA's power sector, DEQ could contribute to the transformation of the economy.  This transformation will happen sooner or later - it's far better for VA's citizens if it happens sooner, so that our monopoly utilities don't make huge investments in fossil fuel generation that would inevitably become stranded assets. Our consumers would then have to pay for these wasteful stranded assets, and the utilities and the SCC would further delay the transformation to clean energy. 

In the long run, it's far more efficient for VA to get on a clean energy track now than to delay it.  And even though climate change-related impacts are already exacting a terrible toll in lives and resources, based on all credible projections, we ain't seen nothing yet.  For the sake of our children and grandchildren, we need to do the responsible thing - put VA on the fastest possible trajectory toward a clean energy future. Pricing pollution - in the form of a cap and trade system on CO2 from electric generating units - will put us on that track.

Please finalize and implement the action "Reduce and Cap CO2 from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)" as written.  Keep up the good work!


J Randall Freed

Manassas, VA 20112