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  9:39 pm
Commenter: Christopher Davis

Virginia Should Stay in the RGGI

Section 10.1-1308 of the Virginia Air Pollution Control Law is a thin reed upon which to justify enforcing Executive Order 9, which may not itself be lawful.

Instead of jettisoning the Regional Greenhouse Gas Initiative at the behest of one gas-emiting utility, why not properly implement the consignment auction approach? (The justification for this regulatory action suggests it was not properly implemented. Why not?)

Instead of passing on compliant costs to utility-captive ratepayers, Virginia should do more to incentivize utilities to reduce emissions. The Coastal Virginia Offshore Wind Project is one example, and Dominion Energy should be encouraged to do more of the same.

Our country, not just our state, needs to be more serious about mitigating climate change. The effort is longer-term, and at the very least "regional", not a matter of short-term fixes to rising energy costs, fixes that will be more costly in the long run. Global warming is causing a rise in sea level, and if not arrested, Hampton Roads in particular will see saltwater intrusion into its fresh-water Potomac aquifer. The Regional Greenhouse Gas Initiative has flood control projects (as well as projects to provide energy-efficient housing to low-income families). But more importantly, as a regional endeavor, it presumably brings more minds together to develop new ideas to address climate change.

Virginia should stay in the RGGI.   


CommentID: 197489