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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10/26/22  2:00 pm
Commenter: Kristel Riddervold

Support for RGGI – City of Charlottesville

Support for RGGI – City of Charlottesville


Greetings Director Rolband and Members of the Air Pollution Control Board,


I am writing today on behalf of the City of Charlottesville to urge you to reject attempts to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI).  In January 2021, under the Clean Energy and Community Flood Preparedness Act (SB 1027), Virginia joined RGGI, a cooperative effort among eleven Eastern states to reduce carbon dioxide (CO2) from power plants within each participating state by setting a regional cap on CO2 emissions.  As the regional cap is reduced over time, so are the associated CO2 emissions – in a planned and predictable way. Alongside the emission reductions is the generation of significant revenue - $4 billion across the participating states since the inception of RGGI1.


Virginia uses the funds generated through the sale of allowances at the RGGI auctions to support energy efficiency programs for socially vulnerable Virginians as well as critical flood prevention and coastal resilience programs. Participation in RGGI is yielding significant economic benefit for Virginians and has put the Commonwealth on a predictable, market-driven path to a clean energy economy. The $452,218,091 that Virginia has earned so far is supporting both families and flood-prone communities. 


Energy Efficiency and Weatherization Funding

In Virginia, RGGI provides unprecedented and irreplaceable funding for energy efficiency improvements in low-income residences. Virginia is the only RGGI state that dedicates fifty percent of its carbon-trading funds to make both new and existing low-income housing more energy-efficient, allowing weatherization providers and affordable housing developers to provide safe, affordable and energy-efficient homes to low-income families like never before.

Virginia’s first year in RGGI generated nearly $114 million for low-income energy efficiency housing. The Housing Innovation Energy Efficiency (HIEE) fund provides capital to make energy efficiency upgrades to both new and existing residential buildings. From major health and safety repairs on existing homes to the construction of affordable, energy-efficient housing, money from RGGI is being used in every region of Virginia — and is creating high-paying jobs that cannot be outsourced.

Virginia’s continued participation in RGGI is crucial to the effectiveness of the Weatherization Assistance Program (WAP).  WAP funding is frequently insufficient or not allowed to be used to correct necessary roof, electrical, and plumbing repairs, thus causing 1 in 5 eligible homes to be deferred (Association of Energy Conservation Professionals, 2020 survey). A portion of the RGGI proceeds is designated for the Weatherization Deferral and Repair (WDR) program that specifically addresses this issue.  By working in tandem with the WAP, the WDR provides funds specifically for health and safety repairs to help our most vulnerable citizens qualify for weatherization services. Unless funds are provided to address these issues, around 20% of eligible homes in the Commonwealth will not receive necessary weatherization services.

RGGI dollars also provide affordable housing developers the financial capital to build and renovate energy-efficient housing for low-income families. In Charlottesville, Piedmont Housing Alliance was awarded RGGI money through the Affordable and Special Needs Housing program to renovate and build over 230 homes in the region. They are committed to making future housing units more energy-efficient, but that may not be feasible if RGGI funding disappears.

Community Flood Preparedness Fund (CFPF)

Virginia’s continued participation in RGGI provides the sole source of funding for the Commonwealth’s statewide CFPF which was established to provide support to localities across Virginia to reduce flooding impacts and impacts from climate change.  The CFPF is guided by resiliency principles that acknowledge climate change, science-based decision making, socioeconomic inequities, adaptation, community and regional scale planning, fiscal realities and cost-effective solutions, and the role of nature-based solutions. 45% of RGGI revenues are directed to the CFPF with nearly $46 million awarded to more than 40 localities, including $541,561 to the City of Charlottesville through three separate grants with future funding needs anticipated.


CFPF is the only dedicated state funding source for flood resilience planning and project implementation for localities, tribes, and soil and water conservation districts across Virginia. Pulling Virginia out of RGGI would disproportionately harm under-resourced, small, and rural communities who do not have the capacity to address flood risk on their own. Without a reliable, adequate, and long-term funding source like RGGI to keep money flowing into the CFPF, localities will be unable to complete necessary flood resilience planning, studies, and implementation they need to address current and future flood risk.


We recognize the important role of energy in our society as well as the importance of a clean energy future. A stepwise, predictable transition to a clean energy future will contribute to our quality of life, improve economic resilience, and foster responsible stewardship of our shared natural resources and climate.  RGGI provides the state policy framework and structure needed to support that transition.


Beyond its climate implications, participation in RGGI benefits Virginians in other ways:

  • Residents of RGGI states enjoy lower energy prices: electricity prices in RGGI states dropped by almost 6% while they went up almost 9% throughout the rest of the country.4 
  • RGGI has already generated $452 million to support much-needed low-income energy efficiency programs and flood resilience infrastructure in the Commonwealth.5


In light of these considerations, we urge the Virginia Air Pollution Control Board to embrace the numerous economic and environmental benefits of Virginia’s continued participation in RGGI.




Kristel Riddervold

City of Charlottesville, Environmental Sustainability Manager


1 RGGI 101 Fact Sheet, September 2021

2 Report: The Regional Greenhouse Gas Initiative: Ten Years in Review, 2019 (updated October 2022), Acadia Center

3 Letter from the Office of Senator Lynwood Lewis to the Air Pollution Control Board; Sept 8, 2022

4 Report: The Regional Greenhouse Gas Initiative: Ten Years in Review, 2019 (updated October 2022), Acadia Center

5 Auction Materials, Cumulative State Charts, Virginia Proceeds by Auction

CommentID: 199088