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  12:00 pm
Commenter: Carol L Davis

Support for RGGI - Town of Blacksburg

Greetings Director Rolband and Members of the Air Pollution Control Board,


I am writing today on behalf of the Mayor and Town Council of the Town of Blacksburg to urge the Virginia Air Board to reject attempts to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI).  Participation in RGGI is already yielding tremendous economic benefit for Virginians and has put the Commonwealth on a predictable, market-driven path to a clean energy economy.  In fact, the ten other Northeast and Mid-Atlantic states that have participated in RGGI have reduced climate-warming emissions 90% faster than the rest of the country – while growing 31% faster economically1.  Furthermore, it has been asserted that the Virginia Air Board does not have clear authority to take this action as detailed in a recent letter signed by 61 state lawmakers2.


Evidence continues to mount that continued inaction on greenhouse gas emissions could lead to catastrophic changes for Virginians, destabilizing the very systems that support and sustain our communities. Millions of people will experience these changes through threats to public health, disruption of national and local economies, and food and water insecurity. Buildings and infrastructure will be increasingly impacted by the severity and frequency of weather events with enormous response and recovery costs falling on resource-strapped local governments. For coastal communities, these threats will be amplified by rising sea levels.


We know that nearly early every element of our society is impacted by energy. It warms our homes, fuels our vehicles, runs our businesses, enables communication across distances, and plays a critical role in producing and transporting the food we eat. A step-wise, predictable transition to a clean energy future will preserve our quality of life, improve economic resilience and foster an ethic of responsible stewardship of our shared natural resources and climate.  RGGI provides the state policy framework and structure needed to support that transition.


Beyond its climate implications, participation in RGGI benefits Virginians in other ways:

  • Residents of RGGI states enjoy lower energy prices: electricity prices in RGGI states dropped by almost 6% while they went up almost 9% throughout the rest of the country.3 
  • RGGI has already generated $452 million to support much-needed low-income energy efficiency programs and flood resilience infrastructure in the Commonwealth.4


In light of these considerations, we urge the members of the Virginia Air Board to embrace the numerous economic and environmental benefits of Virginia’s continued participation in RGGI.




Carol Davis,

Town of Blacksburg Sustainability Manager


1 Report: The Regional Greenhouse Gas Initiative: Ten Years in Review, 2019 (updated October 2022), Acadia Center, link to report

2 Letter from the Office of Senator Lynwood Lewis to the Air Pollution Control Board; Sept 8, 2022, link to letter

3 Report: The Regional Greenhouse Gas Initiative: Ten Years in Review, 2019 (updated October 2022), Acadia Center, link to report

4 Auction Materials, Cumulative State Charts, Virginia Proceeds by Auction, link to spreadsheet

CommentID: 192010