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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10/13/22  1:36 pm
Commenter: Paul Atelsek, Faith Alliance for Climate Solutions

Protect our kids

Dear members of the Air Pollution Control Board,

One would think an Air Pollution Control board is supposed to control air pollution.  Yet some of your new members appointed by Gov. Youngkin have begun administrative action to pull Virginia out of the Regional Greenhouse Gas Initiative (RGGI).

Virginia’s participation in RGGI is the law, passed and defended by our elected representatives in the General Assembly. An administrative board cannot lawfully undermine this legislation.  Moreover, RGGI is a successful, bipartisan, multi-state effort to...CONTROL AIR POLLUTION.  While greenhouse gases are not "criteria air pollutants" under the National Ambient Air Quality Standards, they are the most consequential air pollutant in the world right now.  Fortunately, your charter is not limited to NAAQS, you have to consider harms from all air emissions.

RGGI is effective, and Gov. Youngkin's hostility toward it is odd--conservative republicans normally love market-based solutions.  Nothing is as efficient.  RGGI has a strong track record of cutting planet-warming pollution from power plants. It simply makes no sense to leave RGGI, given the growing climate crisis. If you were to withdraw from it, you would INCREASE, not control, air pollution.

Besides, RGGI generates funds in areas that Virginia desperately needs.  Half goes to low-income energy efficiency and 45% goes toward the Community Flood Preparedness Fund. Virginia has received $452 million from RGGI in less two years—$203 million for flood resiliency. Virginia's own Department of Conservation and Recreation states that "[f]looding is the most common and costly natural disaster, but only 3% of Virginians have flood insurance." Floods in the past year make it clear that preparedness and resiliency is desperately needed--check with the communities in the tidewater and SW Virginia and review Gov. Youngkin's Executive Order 21 declaring a disaster due to flooding. If you withdraw from RGGI, where will the replacement funds come from?  

The safety and welfare of our children is at stake. We are witnessing the destructive impacts of increasingly severe weather, here at home in Virginia and across the country, turbocharged by global heating. This attitude that "oh, we are only a small part of global warming so let's kick the can down the road and go for short-term political gain" is unbefitting an organization that is supposed to use science as its guiding principle.  Our kids deserve a livable world, and pulling Virginia out of RGGI would only help make their future one of heat, extreme weather, and decimated ecosystems that can't handle the strain.

Virginia must do its part to reduce greenhouse gas emissions as quickly as possible.  Withdrawing Virginia from RGGI is not within your power, but even if it were, it would be a stupid move that flies in the face of science and puts our children at risk. The APCB is not supposed to be partisan.  Do the right thing and don't try to withdraw Virginia from RGGI.  

Paul Atelsek

CommentID: 189557