Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
chapter
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
Stage NOIRA
Comment Period Ended on 10/26/2022
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9/27/22  8:10 am
Commenter: David Stratton

Let the RGGI succeed
 

I think none of the arguments for withdrawing Virginia from the RGGI makes sense.

You say it is a hidden tax?  Well then, have the utilities list the estimated impact of the RGGI on each gas or electric bill.  Then, it will be no more of a hidden tax than the gas tax, or the sales tax.

You say that it delivers the wrong market signals?  That is not consistent with the hidden tax argument.  Someone whose gas or electric bills are going up is receiving a market signal to do something about conserving energy.  

You say that the big utilities in Virginia will simply absorb the RGGI costs and pass them on to the consumer?  Yet, Dominion is investing a lot in solar energy facilities.  Also, one of the characteristics of the RGGI are that the available carbon credits to be auctioned off will periodically be reduced, which will increase the costs to utilities that do nothing to burn less carbon.

You say that let’s get rid of the RGGI and just trust your administration to come out with something that is better — except the promises are even more vague than that.  The reminds me of Trump with his beautiful health insurance plan that was going to replace the ACA, and which nobody ever saw.  Sorry, the prudent thing is get the replacement enacted before demolishing the present solution.  Would you demolish a bridge over a large river when the bridge is only a few years old, and you haven’t designed, funded or constructed a replacement bridge?  Of course not.

The funding that the RGGI is spinning off is important.  Besides that funding, what else is Virginia funding to prepare for more frequent flooding events?  Nada.  The weatherization and energy saving parts of the funding stream are important too.  Both of these funding streams save Virginia taxpayers money.  Making dwellings more energy efficient obviously reduces wasted energy, especially at peak times, and thus reduces demand.  If we stick with this there will a payoff for Virginia ratepayers.  As for flood control projects, think of the devastating property damage losses from flooding.  Homes that need to be gutted where the flood waters were, autos that are ruined by flooding, businesses that lose inventory and also have business interruption losses.  Who pays for all of that?  Well ultimately, we all do through higher insurance premiums, and higher state and local taxes to fix the damage.  So don’t try to argue that the RGGI just creates a slush fund for pet projects.  This work needs to get done.

CommentID: 144874