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  6:09 pm
Commenter: William Nuckols / Town of Colonial Beach Planning Commission

RGGI and the Flood Preparedness Fund matter to the Town of Colonial Beach, Virginia

As a part of my work as a Commissioner on the Planning Commission for the Town of Colonial Beach in Westmorland County, Virginia, I also head up our Resilience Committee, and as such I’ve come to know of the great disparity between the need and the ability to fund projects relating to resiliency, particularly those relating to planning and addressing persistent problems of erosion and flooding in our community.

I write in support of the continuation of Virginia’s participation in the Regional Greenhouse Gas Initiative (RGGI) as I find the linkage between the funding made available from the RGGI auctions and the funds distributed from the State to address serious funding shortfalls for resilience projects to be both logical and appropriate.

Here in the Town of Colonial Beach we have not yet been in a place to receive RGGI funds.  This is not because The Town does not need the funding support.  Quite to the contrary, our needs as a coastal town to be resilient in the face of changing conditions is great.  Our lack of RGGI awards is solely because our professional staff is significantly smaller than some of the larger cities who have already been awarded funds to address their coastal resiliency issues.  Our town may have not yet been in a place to request funding from the State thus far, but intend to do so if the RGGI funding continues. 

Removing the state of Virginia from the RGGI agreement will eliminate a crucial funding stream that can be applied to address the needs of the Town of Colonial Beach and numerous small to medium size coastal communities like ours.  While there are smaller programs that can help communities such as ours, none operate at the scale of that the RGGI fund can support.  Our needs are in the millions, and so far only the RGGI program is operating at a scale that can address that level of need.

I find the linkage between the rationale for the RGGI collection of funds and the use of those funds as administered by DCR.  The linkage between the RGGI auctions and the resulting funds raised to address strengthening Virginia’s resilience is both strong and appropriate. What I contend is not appropriate is the termination of the RGGI program in Virginia before less affluent towns and counties have even had a chance to apply for RGGI funding support.  The Town needs both time to apply and the continuation of the increases to the fund from RGGI auctions. The Governor’s Executive Order 9 penned in January poses that “benefits of RGGI have not materialized,” and while that statement may be accurate in some sense, in large part it is because not enough time has passed to allow the need of impacted communities to receive the impact funds from the RGGI program in terms of shovel in the ground projects.  Cutting off participation in RGGI now leaves our town, and small to mid-size communities like it, without any opportunity to realize the benefits of RGGI.  Don’t kill the program before it matures enough to have a positive impact on communities such as ours.

I have associated concerns regarding the Governor’s call to remove Virginia from RGGI. I remain  worried that while the Governor is proposing to end Virginia’s association with RGGI, neither the Director of the Department of Environmental Quality, the Secretary of Natural and Historic Resources, nor the Governor’s office have made any indications where the loss of funding from the RGGI auctions will be made up. Will there be proposals forthcoming to increase the tax burden on Virginians to made up for the loss in RGGI funds, or is the likely outcome that much needed funding for coastal resilience and flood prevention will simply dramatically shrink, leaving our people and our economy more vulnerable as a result?  I fear that without RGGI there simply is no funding source available at the scale required to address the threats to Virginia from an evolving level of threats that the RGGI funds could mitigate.

For the sake of our citizens, I ask that you please reconsider any decisions that would remove Virginia from RGGI and thereby cut off the funding stream that is so greatly needed to address a multitude of projects our town needs to complete to ensure the sustainability of our historic coastal community.


William Nuckols
Town of Colonial Beach, Virginia

CommentID: 201147