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)
Stage Proposed
Comment Period Ended on 3/31/2023
Previous Comment     Next Comment     Back to List of Comments
3/31/23  3:55 pm
Commenter: Cale Jaffe, Environmental Law and Community Engagement Clinic, UVA Law

Comments of Virginia Clinicians for Climate Action in Opposition to the Proposed Action

Below please find a link to the comments of the Virginia Clinicians for Climate Action (“Virginia Clinicians”), which have been submitted, by counsel, in opposition to the proposed action, “Repeal CO2 Budget Trading Program as required by Executive Order 9 (Revision A2).”

Comments of Virginia Clinicians for Climate Action Opposing Proposed Regulation to Withdraw Virginia from the Regional Greenhouse Gas Initiative ("RGGI")

The linked comments were previously submitted to Karen G. Sabasteanski  via email, at  

* * *

Founded in 2017, Virginia Clinicians aims to bring the health voice to climate change advocacy in the state of Virginia. Virginia Clinicians’ nearly 500 medical professionals and allies are concerned about climate change and the worsening health impacts of increasing greenhouse gas pollution. By emphasizing the need for climate solutions, Virginia Clinicians’ advocacy seeks to protect patients, their families, and their communities from the public and environmental health impacts of climate change.

Virginia Clinicians urges the State Air Pollution Control Board (“Air Board”) and the Virginia Department of Environmental Quality (“DEQ”) to reject the proposed regulations and support Virginia’s ongoing participation in the Regional Greenhouse Gas Initiative (“RGGI”), which has already provided tangible benefits to improve public health in the Commonwealth. In Virginia, RGGI has proven to be a vital source of funds to address the Social Determinants of Health.

A large body of literature suggests that factors separate from medical care and biological well-being—called “Social Determinants of Health”—can play a strong role in shaping an individual’s health. Social Determinants of Health are “the conditions in the environments where people are born, live, learn, work, play, worship, and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks.” Often, Social Determinants of Health are grouped into five broad categories: economic stability, education access and quality, health care access and quality, neighborhood and built environment, and social and community context. Examples of common Social Determinants of Health include safe housing, income, job opportunity, pollution levels, and access to nutritious foods.

In the comment letter linked above, Virginia Clinicians highlights (1) the adverse and immediate impacts of climate change on the health of Virginians; (2) the public health benefits that RGGI has helped to deliver thus far; and (3) the importance of RGGI-funded programs—including efforts to weatherize low-income homes, construct efficient affordable housing, and increase flood resilience—to address key Social Determinants of Health.

Executive Order 9 (“EO 9”), the directive on which this proposed repeal is premised, asserts that RGGI operates as a “burden on the Commonwealth’s households and businesses.” Virginia Clinicians strenuously disagrees. To the contrary, RGGI has already succeeded in reducing harmful emissions and providing critical funding to address the Social Determinants of Health among the state’s most overburdened communities. Climate change poses an imminent threat to the health of Virginians, and RGGI helps equip Virginia communities with the resources needed to cope with these dangers.

The medical literature has documented that climate change is contributing to a range of adverse health impacts in Virginia. From heat-related illnesses and injuries from flooding to the increased spread of infectious diseases, Virginians today are experiencing direct and concrete effects from a changing climate. Further, the scientific literature has unquestionably established the connection between fossil fuel consumption and climate change. Together, the peer-reviewed, scientific and medical literature reveal that the public health impacts of human-induced climate change are here and being experienced by Virginians now.

Decreased emissions result in a range of avoided health effects, with researchers having already begun quantifying the health-related benefits delivered by RGGI. One study estimated that in just six years, participating states realized at least $5.7 billion in health benefits from reduced emissions, including the avoidance of 39,000 lost work/school days, a reduction of over 8,200 asthma attacks, and the avoidance of 300–830 excess deaths.

Alongside the health benefits of climate change mitigation and reduced criteria air pollutants, RGGI-funded programs also help address the direct effects of climate change on public health. By funding programs that support safe, affordable housing and lower electricity costs, RGGI is improving key Social Determinants of Health for the most vulnerable Virginians.

When allowances are sold at RGGI auctions, states earn significant revenues from those sales, all while providing a free market-oriented economic incentive to reduce harmful emissions of greenhouse gas pollution. To date, Virginia has participated in seven RGGI auctions and has gained over $452 million in revenue through the sale of 40 million allowances.

Virtually all of these funds support communities identified for protection in the Virginia Environmental Justice Act. The 2020 Clean Energy and Community Flood Preparedness Act (“Act”)—the very statute that mandated Virginia’s participation in RGGI—also determined where RGGI-derived funds would be allocated. The Act requires 50 percent of Virginia’s RGGI proceeds to be directed to low-income energy efficiency programs and 45 percent to the Virginia Community Flood Preparedness Fund. That is, the majority of RGGI revenues are being used to respond to critical needs of Virginians—helping low-income households to weatherize their homes and reduce their energy bills. RGGI’s efforts to improve housing conditions and reduce electricity bills through investments in energy-efficient measures undeniably tackles important Social Determinants of Health and advances health outcomes in the Commonwealth.

Virginia’s participation in RGGI is critical to funding efforts that protect public health in the state and help address the Social Determinants of Health. Virginia Clinicians for Climate Action thus urges both the State Air Pollution Control Board and the Virginia Department of Environmental Quality to reject efforts to remove the Commonwealth from participation in this remarkably successful, multi-state effort.

CommentID: 216167