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
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3/31/23  11:13 pm
Commenter: Ed Roggenkamp

Virginia should remain in RGGI

I am a resident of Vienna, Virginia, and write to express my view that Virginia should remain in RGGI.

Governor Youngkin's attempt to remove Virginia from RGGI is misguided and goes against the policy preference of the Legislature and the majority of Virginians. It also reduces funding for flood protection, risking great harm to low-lying communities without any compensatory economic benefit. It will also fail to achieve any policy benefits for Virginians. 

RGGI’s benefits are far-reaching. Electricity rates in RGGI states have dropped by almost 6%, while rising almost 9% throughout the rest of the country. And RGGI states are reducing climate-warming emissions 90% faster than non-RGGI states. Governor Youngkin would have Virginians pay more in electricity costs so that the fossil fuel industry could have slightly increased profits. But those profits would come at the expense of the public, because they would result from the economic externality inherent in pollution. Polluting industries do not bear the full cost of their detrimental actions unless forced to internalize those costs by an initiative such as RGGI. The costs of climate change are clear, and Virginia is already feeling their effects. If anything, the carbon allowance price under RGGI should be significantly higher.

Governor Youngkin's misguided policy will only delay the inevitable transition to renewables that is the expressed policy in the Virginia Clean Economy Act. The Virginia Clean Economy Act is the law of Virginia and must be followed despite Governor Youngkin's unlawful attempt to roll it back. I urge the Air Pollution Control Board to follow the directive of the Virginia General Assembly and reject this proposed policy change. Virginia benefits from its membership in RGGI and should remain a member.

CommentID: 216460