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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3/3/19  4:29 pm
Commenter: Lisa Linowes, The Windaction Group

Oppose / No Support for RGGI

Thank you for the opportunity to provide comment.

As executive director of the Windaction Group, I have tracked the electricity market in the RGGI states closely since the program’s inception. Claims that RGGI is responsible for precipitous declines in carbon emissions while saving consumers in energy costs, creating new jobs, and enhancing public health, are simply not accurate according to RGGI’s own numbers.

Citing from the September 2018 report by, (“The Investment of RGGI Proceeds in 2016” at 13), RGGI allowances cost electricity consumers over $2.65 billion in the period from 2008 to 2016 to be spent on programs meant to reduce carbon emissions.

Of these funds, the states seized $93.1 million to meet budget shortfalls, allocated $245.1 million for future programs and ‘invested’ $2.17 billion in projects that by 2016 reportedly trained 8,150 workers[i] and promised a lifetime reduction in carbon of just 27.8 million short tons.

In the same period (2008–2016) the free market reduced electric sector carbon emissions in the RGGI states by 49 million[ii] short tons – 2 times the claimed lifetime reduction RGGI touted – and at no additional cost to ratepayers. In other words, by 2016 the free market had already exceeded the claimed lifetime reduction in carbon emissions documented by  

With regard to cost per ton, the numbers are worse.

From 2008 to the end of 2016, the clearing price for RGGI allowances averaged $3.03 per ton. At the highest, the allowances reached $7.50 in December 2015 before tumbling to $3.55 per ton at the end of 2016. In the most recent auction held in December 2018, allowances cleared at $5.35. Yet, state regulators approved ‘investing’ $2.17 billion to lower emissions by just 27.8 million short tons which equates to $78 per ton. In other words, RGGI sold allowances for well under $10/ton and then RGGI states built offset projects costing $78/ton. On specific projects, the cost per allowance was often much higher.[iii]

RGGI proponents are asking the public to believe that the program is delivering on a global environmental promise, but the reality is the nine-state cap-and-trade system is a colossal failure of resource allocation that should be repealed to leave more efficient market forces. There are far more productive options for lowering emissions that do not involve extracting billions from ratepayers. I encourage the Commonwealth to look past ideology behind RGGI and look at the numbers. 


--Lisa Linowes
286 Parker Hill Road
Lyman, NH 03585


[i] RGGI does not cite the number of jobs created. Workers trained represents the total number of “training seats filled directly by the program from inception through to 2014” without double counting workers who might have attended more than one training course.

[ii]US Energy Information Agency (EIA). EIA reports figures in million metric tons. For these comments the figure was converted to million short tons.

[iii] The $1.5 million price tag for Sofia’s Plaza in Connecticut to install a 0.5 MW solar PV system (rooftop and ground-based) was funded 100% through RGGI auction proceeds. According to RGGI, the project is expected to annually save 475.2 MWh and avoid 275 carbon tons (5,500 short tons saved over 20 years) - page 16-17. Based on these figures, the cost per carbon ton over 20 years is $273. at 16

CommentID: 69503