To the VA Air Pollution Control Board: Thank you for your support of the Carbon Rule, essential to addressing climate change in the Commonwealth, the injustices and health harms of climate change and the pollution that causes it. The Rule has grown stronger because it has been linked with participation in RGGI. RGGI brings funds to the most impacted communities and low-income households and neighborhoods who face the environmental injustices of living nearest to toxic pollution health hazards, yet least contribute to climate change as consumers. As an ally working with rural low-income, Indigenous, African American, and Appalachian communities facing new toxic pollution sources, I appreciate DEQ's commitment to field organizers that engage often and learn from these communities' experiential knowledge of these health and climate change impacts.  

Please finalize the Carbon Rule and do not repeal Virginia's participation in RGGI.  I am very concerned about Gov. Youngkin's ongoing efforts to repeal RGGI. The very report written by the DEQ refutes each of Youngkin's arguments. His repeal efforts are not intended to help Virginia ratepayers. Please do not do so.

Without the funds that RGGI supplies, Virginia's plans for a 50% reduction in carbon emissions by 2030, and for net zero carbon emissions by 2050 will be unattainable. Further, RGGI provides constant incentives to utilities to lessen carbon emissions, as they pay quarterly for carbon allowances. We appreciate Gov. Youngkin's support of legislation to return public utility regulatory power to the SCC to prevent overcharging and to return energy efficiency gains to ratepayers. But, for RGGI, Youngkin exaggerates RGGI's costs to ratepayers when our utilities pass those costs back into monthly bills ($2+ household average) and denies the cost benefits to ratepayers of RGGI programs.

1. Under RGGI, carbon emissions allowances decrease in amounts over time. This is a huge incentive to utilities to transition swiftly to clean energy solutions.

2. Participation in RGGI over time leads to lower carbon emissions by states that have participated longer than Virginia.

3. The $2+ cost to households will be more than repaid by the energy efficiency programs RGGI pays for, which could reduce household energy bills by 25% or more.

4. RGGI provides the framework for energy efficiency-lessened carbon emissions across all income households in Virginia -- the only way to secure Virginia's future.

Half of RGGI funds support energy efficiency programs for low-income energy consumers least able to afford home repairs or buy energy efficient heating, cooling and appliances that IRA-funded tax incentives provide higher-income consumers.

5. RGGI funds programs to address ground-level harms of rapid climate change -- flooding, stormwater, and erosion from sea level rise and more frequent, disastrous storms. 25% of Community Flood Preparedness Funds are for low-income neighborhoods with least tax revenue for municipalities to undertake.

6. RGGI supports the use of nature-based solutions -- conserving riparian buffers and floodplains from development that will endanger everything downstream. Stream restoration prevents flooding-caused erosion. The involvement of local community members ensures these mitigations are built using community knowledge, while working together to build and maintain these efforts creates community cohesion.

Please finalize the Carbon Rule and do not repeal RGGI!