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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10/21/22  11:22 am
Commenter: Jerome Paulson, MD, FAAP

For the health of Virginians, keep Virginia in RGGI

I am Jerome A. Paulson, MD, FAAP, a pediatrician concerned about the impact of climate change on human health. It is imperative the Commonwealth of Virginia remain a part of the Regional Greenhouse Gas Initiative (RGGI). I am opposed to removing Virginia from RGGI because RGGI protects the health of Virginians both in the short term and in the long term.


Burning of fossil fuels releases carbon dioxide (CO2), a greenhouse gas which is driving the climate change emergency worldwide. Burning of fossil fuels also releases other air pollutants such as fine particulate matter, volatile organic compounds, oxides of nitrogen, oxides of sulfur and other harmful substances. It is the air pollutants other than CO2 that have the more immediate adverse impacts on human health. For example, fine particulate matter is so small that it can enter into the lungs, move into the tiny blood vessels and then move throughout the body. The presence of these fine particles in the blood stream then contributes to the occurrence of strokes and heart attacks. Volatile organic compounds (VOCs) and oxides of nitrogen (NOx) contribute to the development of ozone in the air. Ozone can exacerbate asthma and chronic obstructive pulmonary disease (COPD, also called emphysema) and can contribute to the new onset of asthma in children. All of these medical problems are devastating to the individuals who have them and the families who support the individuals with these diseases.


The health problems associated with air pollution are not evenly distributed. Low wealth communities and minoritized communities are more likely to be exposed to air pollution and more likely to have health problems as a result of that exposure.


RGGI has proven to reduce air pollution in the states where it is in force and in neighboring states as well. Virginia’s own Department of Environmental Quality has documented this fact. Less air pollution for Virginia means better health for Virginians – fewer asthma attacks, fewer children with the new onset of asthma, fewer adults with exacerbations of chronic obstructive pulmonary disease (also known as COPD or emphysema), fewer individuals with problems with their pregnancy and with preterm birth and fewer adults with heart attacks and strokes. Less air pollution and better health means fewer days-lost from work and school. According to the Acadia Center review of the RGGI program, in just 10 years, participating states realized $5.7 billion in public health benefits thanks to RGGI.


Climate change is harmful to human health in many ways beyond air pollution. Virginia and the world need to decarbonize as soon as possible to stabilize the climate and prevent the most catastrophic outcomes of climate change. While RGGI alone will not bring Virginia to carbon neutral by 2050 as required by Virginia law, it is a significant step in that direction. For the health of Virginians, the Commonwealth must continue to be in and reap the benefits of the Regional Green House Gas Initiative.   

CommentID: 191883