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)
Comment Period Ended on 10/26/2022
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10/12/22  9:04 am
Commenter: Randall Freed, Citizens' Climate Lobby

Stay in RGGI, fight climate change

Governor Youngkin and Acting Secretary of DNHR Travis Voyles assert that the Virginia Regional Greenhouse Gas Initiative is a bad deal for Virginians, and that Virginia should withdraw from the Initiative.


I disagree.  While RGGI isn’t perfect — more aggressive emission reductions (e.g., through a national economy-wide price on carbon at the point of fossil fuels extraction, with cash back to consumers) would be better — it’s a cost-effective and significant program to reduce emissions from the power sector.  Per RGGI 101 Fact Sheet “RGGI emissions have reduced by more than 50% — twice as fast as the nation as a whole — and raised over $4 billion to invest in local communities.”  In addition, RGGI has provided a jump start for VA’s electric utilities in achieving the goals of the Virginia Clean Economy Act and the Federal Inflation Reduction Act.  


Furthermore, please consider what RGGI is accomplishing for Virginia. About 45% of the proceeds goes to energy efficiency projects and 50% to community flood control.  Energy efficiency projects reduce energy demand and help to keep rates lower than they would have been otherwise, while flood control will help avoid property losses, business interruptions, and damages to public roads and utilities.


Virtually all of the world's reputable climate scientists agree that climate change is happening, it's caused primarily by human emissions of greenhouse gases (GHGs), it's getting worse, and that we need to take immediate, aggressive steps to reduce GHG emissions.  As a nation, we've committed to reduce our GHG emissions by 50% (compared to 2005 levels) by 2030.


Virginians' opinions reflect the scientific consensus and a commitment to do our part.  According to the Yale Climate Opinion Maps 2021 - Yale Program on Climate Change Communication, 64% of Virginians are worried about global warming, 72% support regulating CO2 as a pollutant, and 66% of Virginians support CO2 limits on power plants.


The incremental charge on our utility bills for RGGI participation is a small price to pay for meaningful GHG emission cuts from the power sector.  

Given the climate crisis, VA shouldn’t withdraw from RGGI unless it has a better alternative -- i.e., one that deeply cuts carbon emissions in a more cost-effective way.  The Youngkin Administration has proposed nothing that would be a better alternative.  We should not only stay in RGGI, we should ramp up our GHG mitigation efforts across the board.  Virginians want to go forward, not backward -- please let us in the right direction!

CommentID: 189159