REJECT the proposed Regulation for Emissions Trading 9VAC5-140 and do NOT attempt to illegally withdraw Virginia from the Regional Greenhouse Gas Initiative (“RGGI”).

First, RGGI has worked to “abate, control, and prohibit air pollution.”  The proposed regulation would increase air pollution in Virginia, something that has been significantly decreased under the RGGI program. It is short sighted to not weigh in the huge benefits of clean air---and the huge long term costs of air pollution. 

Also, the Board lacks the authority to erase the existing RGGI regulations, under the terms of the RGGI law itself. Virginia’s RGGI law clearly states the Air Board “shall” join RGGI, a clear mandate from the legislature that the DEQ fact sheet fails to address.

Third, RGGI has provided lowered energy costs to low-income Virginians and flooding protection benefits. The new proposal does not.

RGGI is a successful regional program that needs to be continued.