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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10/24/22  9:44 pm
Commenter: Whitney Redding, Friends of Holmes Run

Keep Virginia in RGGI!

On behalf of the board members and 170 volunteers who comprise Friends of Holmes Run in the Cameron Run watershed (which passes through Falls Church, Fairfax County and City of Alexandria, VA on its way to the Potomac River), we STRONGLY OPPOSE Gov. Youngkin’s attempt to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI) program. 

Now is not the time to cut off this new and critical source of non-tax revenue for the local jurisdictions and citizens that are already experiencing increased flooding due to climate change. In 2021, Virginia received $102.4 million for the Virginia Community Flood Preparedness Fund (CFPF). Over the next ten years, RGGI proceeds could generate upwards of $750 million for the CFPF – but only if Virginia stays in RGGI. Regional RGGI funding reduces the burden on taxpayers and shortens the timeline for getting critical flood control projects done in local watersheds such as ours. Without RGGI funds, Virginia’s local jurisdictions would have to revert to the bad old days of completely relying on taxpayer revenues for major flood control projects. This is particularly puzzling; we presume raising taxes runs counter to the Youngkin administration’s own priorities. Nor does RGGI offer cities and counties any sort of ‘free ride’; local jurisdictions still must come up with matching funds.

The flood-mitigation aspects of the RGGI program are especially relevant to residents in older, urbanized watersheds such as ours. That’s because money that Virginia receives from the carbon allowance auctions has been allocated to critical programs for flood control and adaptation. Like our surrounding watersheds, our watershed is highly armored and channelized. It passes through a mix of established suburban and commercial areas that were developed long before modern stormwater management practices. As a result, the recent trend of more frequent and intense rainstorms has turned the vast web of local tributaries such as Holmes Run, Hooffs Run, Backlick Run and the like into a network of  ‘luge runways’ for accelerating stormwater as they drain from impervious surfaces into Cameron Run, Hunting Creek and the Potomac. The City of Alexandria’s existing urban sewer infrastructure cannot keep up with these intense storm events, which leads to back ups in the system and flooding on streets, sidewalks, yards, and into basements and even directly into first floors. The flood waters have been known to break through glass windows and doors, completely filling up basement units, and requiring swift water rescues across the city. This flooding contributes greatly to human health and safety issues as roads become impassable during large storm events and emergency vehicles have difficulty getting to where their services are needed. As properties become greatly damaged, insurance rates and property replacements become greater or too far out of reach for some, especially the most vulnerable populations. Furthermore, flooding causes total vehicle losses across Northern Virginia. These are just some examples of the impacts of intense summer storms, ones who have no ‘name’ or ‘record’; our region and the Commonwealth of Virginia must further prepare for impacts from hurricanes and Tropical Storms, as well, that have a great possibility to impact our area.

 As a centralized funding source, RGGI is a more fair and equitable source of funding for addressing such cross-jurisdictional challenges. Inland streams literally are the lifeblood of Virginia. They are necessary for clean water, and they literally run under every highway and through every neighborhood. But they also can be a source of downstream flooding. As long as streams cross property lines and bridge magisterial boundaries, we all must do the same in our stormwater management and flood mitigation.  As a downstream community, the City of Alexandria has $170 million worth of large capacity stormwater projects ( in just two of its local watersheds. Obviously, they have no choice but to fix the problems they inherit from upstream. The RGGI funding is an ingenious way of NOT taxing citizens of any one jurisdiction, but rather relying on fees from Greenhouse Gas emitters such as Dominion Power (which, we understand, has a profit surplus and, as such, should not be allowed to pass along the RGGI fee to their customers).  

Last but not least, we respectfully remind you that Virginia’s participation in RGGI is a matter of law, and as with any law, any objection to RGGI should properly be addressed by the General Assembly.

Thank you for your attention.


CommentID: 195907