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  10:37 pm
Commenter: Jason Halbert

Withdraw NOIRA to repeal VA's participation in RGGI

October 26, 2022



Ms. Karen Sabasteanski

VA Department of Environmental Quality

PO Box 1105

Richmond, VA 23219

VIA Townhall website

RE: Comments on NOIRA to repeal Virginia’s rules on participation in the Regional Greenhouse Gas Initiative (RGGI)


Dear DEQ/Ms. Sabasteanski:

Please accept my comments and enter them into the record for this matter.

I am opposed to the proposed effort to repeal the regulations governing Virginia’s participation in RGGI. The intended regulatory action and Executive Order #9 are plainly illegal.  The Governor and the State Air Pollution Control Board have no constitutional authority to repeal laws passed by the General Assembly. The 2020 General Assembly passed and then Governor Northam signed the Clean Energy and Community Flood Preparedness Act. It had bipartisan support. The law requires Virginia’s participation in RGGI. Therefore, the proposed actions are illegal.

The value of Virginia’s participation in RGGI is enormous.  The market-based mechanism to reduce carbon emissions from stationary electric power sources is proven to work. All of the states participating have reduced their emissions while generating dollars for public benefit. In Virginia, some of those benefits are:

  • the creation of hundreds of jobs in the energy efficiency sector
  • the reduction of hundreds of thousands of tons to carbon pollution from fossil fuel sources
  • the elimination of millions of pounds of air pollution, which improves public and environmental health
  • the generation of millions of dollars directed toward community flood preparedness and energy efficiency projects to benefit low-income people
  • establishing Virginia as a national leader in our collective effort to halt climate change and reverse the devastating trends related to global warming.

For these reasons and more, I strongly oppose Governor Youngkin’s illogical, illegal, and ill-advised effort to repeal RGGI.  Withdraw the rulemaking. If you want to reduce electric bills, force the investor-owned utilities to undergo SCC review of their base rates and their over-earnings. You’ll find billions of dollars that has been legally fleeced from ratepayers. That’s the real tragedy here. If you don’t like how our monopoly utilities govern themselves, then change the business model to one where the incentives are not constantly directed toward bilking captive ratepayers for never-ending fossil fuel projects (Wise County coal plant, new gas turbines, gold-plated “grid transformation” and on and on).  We have the technology today to greatly reduce and eventually eliminate all fossil fuel use. We should be united as a Commonwealth in that effort. It’s time the Governor and state agencies start leading instead of denying reality and taking us in the wrong direction.  Withdraw the rulemaking.


Jason Halbert

CommentID: 202570