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  4:49 pm
Commenter: Victoria Higgins, Chesapeake Climate Action Network

Chesapeake Climate Action Network comments in support of RGGI

Chesapeake Climate Action Network

Victoria Higgins, Virginia Director


Chesapeake Climate Action Network is a grassroots organization dedicated to fighting climate change in Virginia, as well as Maryland and DC. I write these comments on behalf of over 33,000 members in Virginia and in support of our continued participation in the Regional Greenhouse Gas Initiative. 


Powers of the Board


The proposed action by the air board offends our democratic norms and the rule of law, bypassing the will of the people and their chosen representatives in the General Assembly. HB 981, the Clean Energy and Community Flood Preparedness Act, requires Virginia to participate in the allowance auction process through RGGI. This year, 61 legislators affirmed that HB 981 requires Virginia to participate in RGGI, and that removal via the air board is “improper and illegal.” HB 981 is not a vague directive for state agencies to administer RGGI when and as they see fit. It is a mandate. This effort to dress up a political directive in the guise of legitimacy by following an Administrative Procedure Act does not change the powers bestowed upon the Board. 


Duties of the Board


Moreover, members of the Air Board are not intended to be political pawns at the whim of the Governor. What, then, is the charter of the Air Pollution Control Board? Pursuant to the Code of Virginia § 10.1-1302, members are to fairly represent the interests of conservation, public health, business, and agriculture, without regard for political affiliation. This action by the Board represents the interests of only one business: the fossil fuel industry. And it is expressly political in nature, being carried out solely based on campaign promises made by the Governor. This action violates the duties and distorts the character of the Air Board. It is a dangerous precedent to set that should alarm all parties invested in the existence of nonpartisan Citizen Boards which fairly administer the regulations of the Commonwealth.


Climate Benefits 


Participation in RGGI directly and significantly reduces greenhouse gas emissions and is necessary to meet the emissions reduction goals laid out in the Virginia Clean Economy Act (VCEA). Since RGGI was founded, emissions from power plants in RGGI states have dropped by 50%, double the amount that emissions have dropped in non-RGGI states. This is clear evidence that nationwide trends of fuel switching from coal to methane gas, or improvements in energy efficiency, cannot account for the reductions achieved by RGGI states. 


It is also self-evident that RGGI reduces emissions, because that is precisely its mechanism: over time, there are fewer and fewer carbon allowances available to fossil fuel generators. It is disingenuous and plainly wrong to argue that RGGI does not result in emissions reductions.  


Meeting these climate goals is paramount to protecting Virginia’s lands, peoples, and economy. Without significant emissions reductions worldwide, the flooding associated with sea level rise will inflict $79 billion worth of damages to Virginia, the equivalent of losing one in every ten dollars. As the first southern state to join RGGI, Virginia set an example that may inspite neighboring states to follow, facilitating a drop in regional emissions reductions that can make a meaningful difference in our effort to avert catastrophic sea level rise. 


Health Benefits


The emissions reductions caused by RGGI are proven to have tangible health benefits. Even just in its initial 5 years, when only a handful of states participated and allowances were more freely given, up to 830 lives were saved, over 8000 asthma attacks were avoided, and nearly 40,000 lost work days were avoided. It is further estimated that hundreds of preterm deaths were avoided due to RGGI. This resulted in over $5.7 billion in benefits to participating states. With stricter emissions caps nearly a decade later, the health and associated economic benefits are far greater. 


Benefits of the Community Flood Preparedness Fund


Virginians across the Commonwealth experience catastrophic flooding on a regular basis, flooding which will be made worse by the effects of climate change. The first phase of the Coastal Resilience Master Plan, looking only at Virginia’s coastal region, found that 360,000 Virginians live in homes subject to coastal flooding, a number which will increase by 160% to 943,000 by 2080. The number of non-coastal residents who have and will experience flooding is not included in this number, but devastating floods in Southwest Virginia these past two summers demonstrate that flooding is a statewide issue. Thankfully, we currently have plans to invest significantly in resilience efforts through the Community Flood Preparedness Fund.


In hardly two years, participation in RGGI has accrued over $203 million for the CFPF, which allows localities to design projects that best protect communities from current and future flooding. Much of this funding is yet to be distributed, but the first three rounds of CFPF grants have touched every corner of the Commonwealth – from Buchanan to Norfolk to Richmond to Alexandria. In Alexandria, over 100 local residents signed a petition in just the past two weeks in support of RGGI – because they saw the benefits of nearby projects. Right now, numerous Alexandria residents south of Four Mile Run Park report that they are unable to use their basements due to recurrent flooding. Over time, RGGI funding can restore their full access to their homes. Restaurant workers and owners on King Street report that they regularly receive bad reviews because delivery drivers are delayed by funding. If Virginia stays in RGGI, those restaurants can be insulated from flooding and regular delivery routes can be restored. 


RGGI is the only source of revenue that pro-actively prepares for flooding, rather than simply providing relief after the damage has already occurred. An earnest effort to improve the state’s resilience to flooding must include maintained participation in RGGI and CFPF. 


Benefits of the Energy Efficiency Program


At a time when soaring methane gas prices have inflated energy bills in Virginia and across the country, the best way to save money – and cut carbon – is to use less energy. Virginia is also in an affordable housing crisis that has left us 200,000 units short in both rural and urban areas. RGGI has generated more than $226 million for energy efficient affordable housing and bill-slashing weatherization projects, 25% of which are ear-marked for low-income households. 


This program has changed lives for Virginians who would otherwise have to abandon their homes. Community Housing Partners is a weatherization company based in Christiansburg, Virginia, which has borne witness to the transformative effects of RGGI funding. 


“Weatherization helps correct environmental injustices and saves folks money on their utility expenses. It improves the indoor environmental quality of their home, their health and safety, makes them proud of their home and their community. There are so many benefits,” said one employee.


RGGI funding allows CHP to add as many as 2000 additional homes to their roster each year. One such home is that of 61-year old Dorothy Carter, who has lived in her home in Elkton, Virginia for 43 years. For years, sewage leaked throughout the basement and rain came in through holes in the roof, endangering her health and making winters difficult to bear. Prior to receiving RGGI funding, she was regularly paying $700 to fill her oil heater. Her life has been transformed by RGGI’s low-income weatherization program. With a new electric heat pump in place, she is able to keep her home and purchase basic necessities she was not able to afford, like a washer and dryer.   




Despite persistent false claims by the Governor’s administration, RGGI is popular. An independent study confirmed that 67% of voters support the Commonwealth’s participation in RGGI, compared to 26% who do not. Clearly, RGGI’s benefits are appreciated by Virginians of all political stripes. It is disheartening that a popular, commonsense policy that delivers real climate, health, economic, and resilience benefits to Virginians has become an arena for political games. CCAN recommends that the Board give up this politicized, illegitimate effort to repeal RGGI. 


CommentID: 200076