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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8/24/23  3:21 pm
Commenter: Perry Cogburn

Stay in RGGI

Climate change as a result of greenhouse gas emissions from fossil fuel usage is having a significant impact on the world's weather. Carbon dioxide (CO2) in the atmosphere has risen from 280 parts per million (ppm) prior to the industrial revolution to currently 420 ppm based on data from the National Oceanic and Atmospheric Administration. CO2 will stay in the atmosphere reflecting heat back to the earth for centuries. Methane, the main component of natural gas, reflects 100 times more heat than CO2 and lasts in the atmosphere for decades. Prior to the industrial revolution, methane levels in the atmosphere were 0.9 ppm. Currently, the level is 1.9 ppm and rising. Roughly 60% of the atmospheric methane comes from human activities which include fossil fuel use, farming, landfills and waste.

RGGI is working. Those states that are participating in this initiative have had a steep decline in emissions compared to the non participating states. Also, since facilities have to pay when they exceed a certain pollution level, it causes the facilities to utilize the less polluting plants it runs to provide power to the grid. It is also important to note that one quarter of Virginia’s carbon emissions covered by RGGI come from non regulated power producers which have no incentive to reduce its carbon emissions if we exit RGGI.

In Article 11, Section 1 of the Constitution of Virginia, it states “Further, it shall be the Commonwealth’s policy to protect its atmosphere, lands, and waters from pollution, impairment, or destruction, for the benefit, enjoyment, and general welfare of the people of the Commonwealth.” We know that the power companies like the fossil fuel industry has known for years that they have been releasing the pollutants CO2 and methane to the atmosphere. Scientist were talking about greenhouse gases in the 1960s! The Governor and his cronies would allow the power industry to continue to pollute our atmosphere in direct opposition of the Constitution of Virginia.

The Governor implies that RGGI is a tax levied by Dominion Energy and that it is a burden on hard working families. Dominion is not a government entity, therefore it cannot levy a tax. Once Virginia joined RGGI and Dominion saw that they were going to far exceed the pollution limits, they went to the State Corporation Commission and were granted a Ryder to collect money from their customers to pay for them to exceed the pollution limits. Dominion has gone on record as stating that 0 carbon emissions by 2045 is unattainable so have plans to continue to use coal fired plants and wants to build additional natural gas plants. Without RGGI, there is no incentive for any of these facilities to curb CO2 and methane pollution.

CommentID: 219753