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  6:37 pm
Commenter: John Clewett, Faith Alliance for Climate Solutions

Virginia Must Remain in RGGI, and Benefits Greatly From Its Participation

Virginia should remain in the Regional Greenhouse Gas Initiative (RGGI).  Turning our backs on RGGI would be a foolish self-inflicted injury, harming the Commonwealth and its citizens.


RGGI benefits the Commonwealth and its people in numerous ways.  For example:

  • By incentivizing utilities to more cleanly generate electricity, RGGI reduces air pollution, and thereby not only improves public health by reducing asthma attacks and other health problems, but also reduces the number of missed days of work or school.
  • By incentivizing a shift from high-cost polluting fuels to lower-cost renewable energy sources, RGGI promotes lower energy bills for all ratepayers across the Commonwealth.
  • By incentivizing this shift away from high-carbon fuels that experience extreme price volatility, RGGI promotes energy price stability, and keeps Virginia dollars in Virginia instead of shipping them out of state and overseas to pay for fossil fuels.
  • By funding energy efficiency measures for low-income residents, RGGI permanently lowers their energy costs.
  • By funding flood preparedness efforts, RGGI saves property and human lives throughout the Commonwealth, from mountain areas prone to flash floods to coastal areas facing rising sea levels and subsiding land.
  • By funding these programs, RGGI generates lots of good-paying jobs for Virginians, jobs that cannot be outsourced.


These benefits are clear.  As Virginia’s Department of Environmental Quality (DEQ) has said, RGGI has “a long track record of emission reductions since the beginning of the program.”  In fact, compared to non-RGGI states, RGGI states have not only reduced power plant carbon emissions 90% faster, but also have benefited from more than 30% faster economic growth!  These environmental, health and economic benefits also have multiplier effects, by making Virginia a more attractive location for businesses seeking to relocate.  We have already seen examples of this positive effect.


Turning our backs on all these benefits would be pure folly, especially since the argument for doing so boils down to an entirely speculative assumption that utilities would voluntarily lower (by a very small amount) what they charge ratepayers if RGGI did not exist.  Elected and appointed leaders owe a duty of responsible action to the current – and future – residents of the Commonwealth, and seeking to destroy such a successful program as RGGI would be petty, short-sighted, and counterproductive.


Moreover, neither the Governor, nor the DEQ, nor the Air Pollution Control Board has the power to contravene Virginia law.  In 2020, the Virginia General Assembly enacted the Clean Energy and Community Flood Preparedness Act (SB 1027), which mandated Virginia’s participation in RGGI.  Until and unless this law is repealed, the Governor has the sworn obligation to ensure the faithful execution of its provisions, and in like fashion, no administrative agency or other entity has the power to flout the law.  


For all of these legal, prudential, economic, health, safety, and economic reasons, Virginia should and must remain a good-faith participant in the Regional Greenhouse Gas Initiative.

CommentID: 201253