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  10:16 pm
Commenter: Mimi Stevens

RGGI is good for Virginia

I am sending this message to express my firm support of Virginia's participation in RGGI, and my strong opposition to the move being made by the Youngkin administration to repeal that participation.

The data clearly show that RGGI is beneficial to the states where it is in effect. Even the administration admits that RGGI reduces emissions that are harmful to the atmosphere and to the citizens of states where it is in effect. Over the decade prior to Virginia's 2020 passage of the law mandating Virginia's participation, emissions had not declined, and without its continuance we will not be able to achieve carbon-free power by 2050. This is the goal of the Virginia Clean Economy Act.

Decreased air pollution is important to the health of the population. As the air becomes cleaner, we will see fewer asthma attacks, premature births, and missed days of school and work. States where RGGI has been in effect over the past ten years have seen a reduction in public heath expenses amounting to $5.7 billion.

In Virginia, the money the state receives from the carbon allowance auctions has been allocated to  energy-efficient housing and flood control, two programs that have an important effect on the well-being of our citizens and the communities in which we live. Since January of 2021, RGGI has generated upwards of $378 million for these efforts, with proceeds continuing to come in every quarter.

With no “Plan B” to make up this revenue, this action would leave localities without a funding stream to adapt to climate change and protect their communities, while also leaving low-income Virginians behind. Taking Virginia out of RGGI will undermine our ability to cut harmful pollution from power plants. RGGI is helping drive down pollution, leading to positive health outcomes. Flooding will continue to be a growing problem as sea levels rise and coastal land sinks.

This misguided repeal also imperils our economy. We are one of the fastest growing states for clean energy jobs because of strong policies like our membership in RGGI, and we must stay the course to advance the clean energy transition already underway.

In spite of all the clear benefits of staying in this program, it’s pretty obvious that Governor Youngkin lacks the authority to take us out of RGGI through the regulatory process - our participation in RGGI is mandated by policies the General Assembly passed in 2020 and only our General Assembly can legally take us back out.

For all the reasons outlined above, I respectfully urge the Administration to cease this repeal process.

CommentID: 197583