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)
Comment Period Ended on 10/26/2022
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9/26/22  8:03 pm
Commenter: Andrew Payton, Climate Action Alliance of the Valley

Keep VA in RGGI

RGGI employs a proven, market-based cap-and-invest mechanism requiring power producers like Dominion Energy to purchase allowances for their carbon emissions, thereby accelerating the deployment of carbon-free energy production through renewable sources like wind and solar. Proceeds from these allowances are delivered proportionally to participating states. Virginia law requires that funds are spent on low-income energy efficiency programs (50%) and community flood preparedness (45%). 

Climate Action Alliance of the Valley, a grassroots coalition in the Shenandoah Valley, opposes Governor Youngkin’s attempt at RGGI withdrawal. He describes RGGI as a “carbon tax”, implying withdrawal will prevent utility rate increases from costing consumers. Utilities like Dominion Energy will seek to recover costs by increasing rates; the Governor, however, is missing the bigger picture. Dominion Energy already passes on to ratepayers the costs of fossil fuel projects, like expensive coal plants that are no longer economically viable. We ratepayers pay for these stranded assets. We are better off paying for renewable energy projects like wind and solar as long term investments. We agree with Mr. Youngkin’s concern about rising energy bills. The electricity burden (the percentage a household spends on electricity) is higher in Virginia than the national average and is unaffordable for 75% of households. Nonetheless, Virginia has an urgent need to fund flood preparedness and to lower energy costs. RGGI can help accomplish both. 

RGGI is the only dedicated source of funding in Virginia for flood preparedness, crucial not just for coastal regions but for communities in the Shenandoah Valley. Republican Delegate Will Morefield of Buchanan County understands this and introduced HB5, to keep the Community Flood Preparedness Fund intact regardless of Virginia’s participation in RGGI. (If Virginia withdraws, we’d have to find other funding sources.) 

RGGI funds are already being used to help low-income families lower their energy use, keeping the lights and heat on for less money. It’s estimated that weatherization--sealing air leaks with insulation, weatherstripping around windows and doors, repairing duct systems, replacing outdated and unsafe heating and cooling systems--could save the average Virginia family as much as $976 every year. 164,000 Virginia households pay about 31% of their income on energy costs. An additional 179,000 pay 17% of their income. Weatherization and energy efficiency are cost effective ways to reduce disproportionate energy costs.

RGGI funds are also being used to address our shortage of affordable rental units. In the initial round of funding, the state awarded eleven affordable housing grants representing 705 energy-efficient units using RGGI funds. The money will help clear the backlog of eligible households that cannot weatherize until certain home repairs are made--like leaky roofs or faulty wiring--by funding those repairs. In a few months of operation in 2021, hundreds of home repairs and weatherization services for low-income families were completed

We don’t have to speculate on whether RGGI is right for Virginia; we can look at how participation has already helped other states. Cutting carbon emissions also leads to reductions in other pollutants harmful to human health–mercury, nitrogen oxides, and sulfur dioxide. A 2017 analysis of RGGI’s first six years found that emission reductions led to health benefits valued at $5.7 billion in participating states by lowering rates of childhood asthma, preterm births, and low birth weights. These are some of the very real externalized costs of fossil fuels rarely discussed. RGGI has also created 45,000 jobs, adding $4 billion in economic value. RGGI state economies have grown faster than non-RGGI economies by 31%. RGGI has also lowered electricity prices by 5.7% in the first nine years, in contrast to increases in non-RGGI states. Major employers in Virginia understand this; leaders from Nestlé to Unilever to Salesforce joined together to applaud lawmakers for the effort, saying RGGI would help the commonwealth “take advantage of the opportunities that accompany the transition to a low-carbon economy.”

RGGI has enormous potential to address crucial needs in Virginia, as it has done in other participating states. We strongly encourage continued participation in RGGI because of the benefits the program brings to Virginia communities like ours.

CommentID: 140384