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  7:46 pm
Commenter: Stephanie Burns

Please keep Virginia in RGGI

As a Virginian who is deeply concerned about the impacts of climate change and flooding on our commonwealth, I strongly oppose the Governor's proposal to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI).

I do not even understand how it is legally possible to remove Virginia from RGGI without the General Assembly's approval. Virginia's participation in RGGI was legislated through the enactment of the Virginia Clean Economy Act and the Clean Energy and Flood Preparedness Act. So how is it possible to remove Virginia from RGGI without passing legislation?

In my opinion, not only is this proposal problematic from a legal standpoint, I believe it does not make sense economically or environmentally. The benefits of participating in RGGI far exceed the cost. For residential customers, the cost has only been about $2 per month on average. And Dominion is no longer collecting fees for RGGI on utility bills - so would ratepayers even see any noticeable difference in their utility bills if Virginia were to leave RGGI? And if the main goal is to minimize costs to ratepayers, why not look at reducing other fees that are built into Virginians' utility rates?

While the cost of RGGI participation has been low, the benefits have been significant. RGGI has generated $379 million in revenue for Virginia, which has funded flood resilience efforts and energy efficiency programs for low-income household. These programs help to lower costs for families. How will that funding be replaced in Virginia's budget? Will those programs continue? If not, what is the new plan to address our substantial flooding challenges in Virginia?

Participation in RGGI also makes it easier for Virginia to comply with the renewable energy targets in the Virginia Clean Economy Act. By putting a price on carbon pollution through a cap-and-trade system, it creates a market incentive to deploy more renewable energy and clean energy. So it is a complementary policy with Virginia's Renewable Portfolio Standard. Why would Virginia take an action that makes it harder to comply with our own laws?

Again, please do not remove Virginia from RGGI.

CommentID: 201523