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  8:50 pm
Commenter: Anonymous

Robust Cost/Benefit Analysis of Repeal Action Needed

The repeal of the regulation implementing the Regional Greenhouse Gas Initiative (RGGI) participation must be analyzed both for the benefits and costs of repeal and the benefits and costs of no action, which is to continue participation. This analysis must recognize time horizons to 2050 as the Virginia Clean Energy Act, the law that requires participation in RGGI, used this year as a benchmark. The analysis must also consider a social discount rate to recognize the impact of the regulation on my children and their potential children. A comprehensive analysis will almost certainly demonstrate the long-term broad and individual net economic benefits of taking no action and remaining in the program.

The analyzed benefits and costs of no action must include:

  • Costs associated with lost outcomes from lost program funding, such as for the Community Flood Preparedness Fund and weatherization assistance programs. For instance, the regulation must analyze and discuss the cost associated with flooding and the impact of losing CFPF projects to address flooding. Specifically, the regulation analysis must address costs included in Robert M. McNab’s Study Projecting the Cost of Recurrent Flooding in Virginia and the loss funding for flooding resilience projects that will reduce the costs in the analysis.

The analysis must recognize the actual (not modeled) impact of RGGI on rate costs in other states and discuss the mitigation of RGGI on other energy cost factors, including the long-run electricity cost reductions associated with renewables development. The analysis must describe the incremental cost impact of RGGI in context, not of the nation as a whole, but instead similar economic and energy systems. Any cumulative energy cost impact analysis must describe the synergistic connection between any energy projects used to consider cumulative cost impacts to rate payers. For instance:

  • The mandate and necessity for the regulatory change quoted from Executive Order 9 state that typical bills increased $2.39 per month or $35.16 per year due to the Regional Greenhouse Gas Initiative (RGGI). The Notice of Intended Regulatory Action cites the US Department of Energy that the average cost of energy in Virginia is $2,323 per year. The increase associated with RGGI represents less than a 2 percent increase to the average energy cost. The impacts of coastal flooding alone, described above are expected, to reduce state economic output by over 13 percent. Losing the climate change mitigation of reduced fossil fuel consumptions and adaptation benefits from resilience investments associated with RGGI will realize the full extent of the reduced economic output from future flooding. And this only consider one increased climate change stressor; additional stressors, such as extreme heat, hurricane intensity, drought, etc must also be considered.
  • The Notice of Intended Regulatory Action anecdotally described the costs of the Coastal Virginia Offshore Wind Project, but failed to disclose other non-renewable projects that Dominion is investing in that may require rate payer increases. If one project is considered than all projects that identify potential rate holder increases in their development costs must be included for context.
  • The variable and ongoing cost of fuel sources must be included for all components of the energy system. That is, the cost of renewable production is higher upfront, but reduced through time, while non-renewable capacity is high upfront and high and volatile into the future (as the notice describes for natural gas). Shifting to a less fuel consumptive system will present cost reductions in the long term after capital costs are recovered.

The analysis must provide evidence or references that indicate Virginia is less competitive with other states, as was stated without reference or citation in the notice. Any reductions in competition claimed must use metrics that show Virginia’s economic decline relative to other states due to the participation in RGGI.

CommentID: 192686