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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10/25/22  3:51 pm
Commenter: John Bagwell, Virginia Clinicians for Climate Action

RGGI Protects Health

Virginia Clinicians for Climate Action (VCCA) was founded in 2017 in order to bring the health voice to climate change advocacy in the state of Virginia. On behalf of VCCA and our nearly 500 Virginia health professional members, we submit this statement in support of Virginia’s ongoing participation in the Regional Greenhouse Gas Initiative (RGGI). RGGI effectively protects the health of Virginia residents from climate change and air pollution. As such, VCCA strongly opposes efforts to remove Virginia from the program.

Climate change is associated with far-reaching adverse health impacts. Worsening extreme weather events place residents of affected communities at risk of injury, death, disrupted medical services and mental health effects. Longer and more intense heat waves increase the risk of heat-related illness, particularly in the elderly, outdoor workers and student athletes. More severe allergy seasons worsen exacerbations of asthma, chronic lung disease, and allergic diseases. Infectious disease patterns shift in response to changing climate conditions.1

Reducing carbon emissions in order to reduce climate change impacts is imperative to protecting public health. Since its inception in 2009, RGGI has effectively reduced carbon emissions from electricity generating facilities. States that participate in the RGGI program have reduced their power plant carbon emissions by 50 percent, outpacing the rest of the country by 90 percent. Electricity prices have simultaneously declined in RGGI states while increasing in the rest of the country.2

In addition to carbon dioxide, fossil fuel combustion releases numerous other air pollutants including fine particulate matter, volatile organic compounds, nitrogen oxides, and sulfur oxides that are harmful to human health. Adverse health impacts of air pollution include but are not limited to heart attacks, strokes, asthma exacerbations, chronic obstructive pulmonary disease exacerbations, and preterm births.3,4  These harms disproportionately impact low income and racial minority populations due higher likelihood of pollution exposure in these populations.

RGGI is already protecting health across the Northeast by reducing toxic air pollution. A 2017 study found that from 2009-2014, RGGI-associated reductions in air pollution prevented 420-510 instances of acute bronchitis, 240-540 instances of adult mortality, 8,200 asthma exacerbations, over 200 asthma Emergency Department visits, and tens of thousands of lost work days.5 Prevention of these outcomes resulted in over $5.7 billion in health and productivity savings. A second study in 2020 found that air pollution reductions associated with RGGI prevented 537 cases of child asthma, 98 instances of autism spectrum disorder, and 112 preterm births in the Northeast from 2009-2014.6

In addition to reducing air pollution, RGGI protects the health of Virginians by providing crucial funding for energy efficiency improvements to low-income families. Through major health and safety repairs on existing homes as well as the construction of affordable energy efficient homes, revenue from RGGI is being used to improve living conditions for residents across the Commonwealth. These improvements to insulation, ventilation, and energy efficiency create homes with reduced indoor pollutants, better controlled moisture, and reduced mold. These improvements lower the risk of heart disease, respiratory disease, severe asthma, COPD, and cancer.7,8

Since its implementation, the RGGI program has proven highly effective at reducing harmful emissions and protecting the health of Americans across the Northeast. VCCA therefore strongly supports Virginia’s continued participation in the program.


1 USGCRP, 2018: Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment, Volume II [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global Change Research Program, Washington, DC, USA, 1515 pp. doi: 10.7930/NCA4.2018

2 Stutt J. The Regional Greenhouse Gas Initiative: 10 Years in Review. Acadia Center. 2019

3 Perera, F., Ashrafi, A., Kinney, P., & Mills, D. (2019). Towards a fuller assessment of benefits to children's health of reducing air pollution and mitigating climate change due to fossil fuel combustion. Environmental research, 172, 55-72.

4 U.S. Environmental Protection Agency (EPA). 2011. The Benefits and Costs of the Clean Air Act: 1990 to 2020.

5 Manion M, Zarakas C, Wnuck S, Haskell J, Belova A, Cooley D, et al. Analysis of the Public Health Impacts of the Regional Greenhouse Gas Initiative. Abt Associates, Cambridge, MA. 2017.

6 Perera, F., Cooley, D., Berberian, A., Mills, D., & Kinney, P. (2020). Co-benefits to children’s health of the US regional greenhouse gas initiative. Environmental Health Perspectives, 128(7), 077006.

7 Sharpe, R. A., Taylor, T., Fleming, L. E., Morrissey, K., Morris, G., & Wigglesworth, R. (2018). Making the case for “whole system” approaches: Integrating public health and housing. International journal of environmental research and public health, 15(11), 2345.

8 Wilson, J., Jacobs, D., Reddy, A., Tohn, E., Cohen, J., & Jacobsohn, E. (2016). Home Rx: the health benefits of home performance (No. DOE/EE-1505). National Center for Healthy Housing, US Department of Energy.

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