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 Final
Comment Period Ended on 8/30/2023
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8/7/23  7:35 pm
Commenter: JoAnne Trimbur

VA needs to stay in RGGI

Virginia needs the Regional Greenhouse Gas Initiative (RGGI).

Revenues from RGGI have far outstripped state officials’ projections, amounting to nearly a half a billion dollars to date. These revenues benefit people all over our state. By law, 50% of RGGI revenue goes to low-income energy efficiency / home weatherization programs, mitigating rate increases for households that struggle to afford energy costs in every region of the state. Not only that, but by law, 45% of RGGI revenue goes to the Community Flood Preparedness Fund. That’s why seventeen Hampton Roads cities and counties opposed Virginia leaving RGGI in a letter from the HRPDC. If you have spent any time in the coastal areas of Virginia, then you know that worsening flooding in many coastal communities is very real.
No truly sustainable and adequate funding source has been proposed to replace the revenue from RGGI needed to address this flooding, just as no funds have been proposed to replace the 50% of RGGI revenue mandated to permanently reduce the energy burden on low-income households through weatherization. Those alternative funding sources that have been proposed are smaller, ignore low-income households, and are contingent on available funding in the general state budget. The current budget surplus is the result of pandemic recovery efforts and is not a permanent source of funds, and I very much fear such funding would evaporate in the next budget cycle, especially given the talk of tax cuts.?

This year we are seeing the devastating effects of climate disruption caused by greenhouse gas emissions.  A carbon cap-and-trade program is an effective state action to mitigate emissions.  Most other actions to address the climate crisis require federal government intervention.  This is the one strategy which is within Virginia’s power to use to address this issue. 
Furthermore, a letter that 61 legislators have already sent to the Air Pollution Control Board states, "Virginia’s participation in RGGI is mandated by law. Therefore, ultimately only a change in the law that passes both chambers of the General Assembly and is signed by the Governor can remove Virginia’s participation.” Attempts to circumvent the law will end up in court costing taxpayers.  
Since participation in RGGI was passed as legislation by the General Assembly and is now in the Code of Virginia, the Governor’s efforts to unilaterally ignore laws and effectively repeal them, threaten the purpose in having a legislative body.  These actions violate the separation of powers that is the foundation of our constitutional government. Climate crisis aside ( and no matter how you feel about it), we must oppose such a dangerous precedent.  

CommentID: 218526