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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10/26/22  12:51 pm
Commenter: Nate Benforado, Southern Environmental Law Center

No Authority for RGGI Repeal - SELC Comments on Behalf of AECP, VAIPL, Wetlands Watch, and AppVoices

Ms. Sabasteanski,

On behalf of the Association of Energy Conservation Professionals, Virginia Interfaith Power & Light, Wetlands Watch, and Appalachian Voices, the Southern Environmental Law Center opposes the proposed repeal of Virginia's CO2 budget trading program set forth in the NOIRA. The administration has no authority to repeal this important program and doing so would not only be unlawful, but harmful to Virginians. We have submitted a detailed comment letter via email to, along with 48 attachments.

We request that the comment letter and attachments be made part of the public record.


Nate Benforado

Senior Attorney

Southern Environmental Law Center

CommentID: 198831