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)
Stage Proposed
Comment Period Ended on 3/31/2023
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3/31/23  1:54 pm
Commenter: Kevin Doyle, Consumer Energy Alliance

Proposed Regulation for the Amendment and Repeal of 9 VAC 5-140

The Honorable Glenn Youngkin
Commonwealth of Virginia
PO Box 1475
Richmond, VA 23218

RE: Proposed Regulation for the Amendment and Repeal of 9 VAC 5-140

Dear Governor Youngkin:

On behalf of Consumer Energy Alliance (CEA), I write to commend you on your efforts to support policies that promote affordable and reliable energy which protect families, manufacturers, small businesses, and farmers. Whenever initiatives such as the Regional Greenhouse Gas Initiative (RGGI) are proposed, we always ask what the potential financial impact might be on not only the broader population, but especially on those who can least afford higher energy bills.

Founded in 2006, CEA is a nonpartisan, nonprofit organization advocating for balanced energy and environmental policies and responsible access to resources. CEA represents virtually every sector of the U.S. economy – from the iron and steel industry to truckers, airlines, agriculture, labor organizations, restaurants, chemical manufacturers, small businesses, and families all across the nation – that are concerned about U.S. energy policies, energy security, and long-term price and supply stability. CEA has more than 550,000 individual members and almost 400 academic, non-profit, corporate, and union affiliates throughout the United States.

Our members support a rational, all-of-the-above energy policy that utilizes all our domestic natural resources – both traditional and renewable – while ensuring commonsense environmental protections are in place.

In 2020, we shared our concerns with your predecessor regarding the fundamental altering of Virginia’s energy landscape with the passage of HB 981 which, according to an analysis conducted by the State Corporation Commission could see increases in residential energy bills. Unfortunately, those concerns went unheeded but the projections are proving to be accurate, with new compliance cost projections being estimated to be $723 million from 2021 through December 2023 alone.

We have already proven that America can lead the world in energy development while at the same time also leading the world environmental stewardship. America has also shown that we can do both without excessive government regulation – a lesson which is relevant to Virginia. We believe Virginia can continue to realize significant emissions reductions without the burdensome and poorly crafted regional planning mechanism that several other states have adopted. While a worthy idea in concept, as currently designed the regional plan would significantly increase energy cost, hinder reliability and offer little real-world emission reduction.

Again, we thank you for your continued championing of energy policies that help support the people of Virginia by ensuring access to affordable, reliable, and resilient energy.

Kevin Doyle
Executive Director – Southeast
Consumer Energy Alliance

CommentID: 216132