October 21st, 2022

Karen G. Sabastianski

Department of Environmental Quality

P.O. Box 1105, Richmond VA 23218

RE: Regional Greenhouse Gas Initiative Notice of Intended Regulatory Action

Dear Ms. Sabastianski:

Wetlands Watch appreciates the opportunity to submit the following comments on the Notice of Intended Regulatory Action (“NOIRA”) from the Department of Environmental Quality (“DEQ”) entitled “Repeal CO2 Budget Trading Program as required by Executive Order 9 (Revision A22).” This NOIRA “begins the process of developing a regulation to repeal” Part VII of 9 Va. Admin. Code § 5-140, also known as Virginia’s Emissions Reduction Program or the CO 2 Budget Trading Program.

Wetlands Watch strongly opposes this proposal because neither the Air Pollution Control Board (“Air Board”) nor DEQ has the power to remove Virginia from the Emissions Reduction Program. The General Assembly mandated Virginia’s participation in the Regional Greenhouse Gas Initiative (“RGGI”). Therefore, the Air Board and DEQ cannot override this legislative mandate through the NOIRA regulatory process.

Sincerely, 

William “Skip” Stiles Jr.