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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10/25/22  2:16 pm
Commenter: Glen G Besa

Oppose reversing RGGI participation

I wish to register my opposition to Governor Youngkin's proposed repeal of RGGI.  First, if the Air Board and DEQ proceed with repeal of RGGI, they will be defying state law which specifically directed the state's participation in RGGI. 

It appears that the Governor is pursuing RGGI repeal for political motives that have nothing to do with the merits of the program.  Those political motives relate to his future political ambitions in appealing to a narrow base of supporters who deny the reality of climate change.  Consequently, this action is both illegal and anti-science, and the Air Board should refuse to be a pawn used in advance the Governor's ulterior motives. 

If the board goes along with this repeal of RGGI, Virginia jurisdictions working to mitigate sea level rise and flooding events associated with climate change will lose an important source of funding for these critical projects.  Additionally, low income families that benefit from RGGI funds for weatherization will also experience a cut back in this program that lowers their energy bills. 

Finally, the Governor cites as justification for repeal the cost of the RGGI program to rate payers. However, a review of the RACs listed in the Governor's energy plan shows the lion's share of the costs of RACs are associated with new fracked gas power plants ($8.33/month) not counting the fuel factor of $35.38/month to fuel these gas plants.  RGGI will move us off of gas and fossil fuel to clean renewal energy like wind and solar which have NO fuel costs.  

In conclusion, I urge the Air Board and DEQ to do your job and follow the law which means rejecting the Governor's proposal to repeal RGGI.

Thank you,

Glen Besa

CommentID: 196650