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  3:09 pm
Commenter: Virginia Petroleum and Convenience Marketers Association


Virginia Petroleum and Convenience Marketers Association (VPCMA) is a non-profit trade association founded in 1948 representing the interests of Virginia-based business women and men that operate convenience stores and also sell gasoline, diesel, lubricants, home heating oil, and propane.  Our customers include consumers, the military, first responders, agriculture, construction, watermen and others.  The members of VPCMA collectively employ 67,540 Virginians.

VPCMA shares the view of many of those commenting on the proposed regulation that environmental protection is vital to the future of our Commonwealth.  Our support is not conceptual.   For over 30 year the Virginia Petroleum Storage Tank Fund has assessed a per gallon fee on all petroleum sold in the Commonwealth.   Over that time the fund has financed over three quarters of a billion dollars to fund petroleum remediation and DEQ administration  across the state.   It stands as perhaps the most successful public-private partnership in Virginia history.  That success has only been achieved through the collaborative process which enacted it, and has since provided support and oversight with the continued participation from a diverse group of stakeholders.

Many of the comments on this regulation (we have read the majority of those that are not redundant) address the support that RGGI reportedly enjoys in public opinion polling.  Not one of these comments address the fact that the questions were apparently framed to produce a desired result.   Take for example the Wason Center poll of Virginians released on January 27, 2023.  It posed the following question:  "Virginia is a member of the Regional Greenhouse Gas Initiative (RGGI) which enters the Commonwealth into a carbon cap and trade local flood program with other states in the region to reduce carbon pollution.  Program revenues are then used for local flood prevention and energy efficiency.  Would you say that Virginia should stay in the Regional Greenhouse Gas Initiative, or should the state leave the program."

Unsurprisingly, the question does not identify the source of revenues (higher electric bills paid by Virginia consumers and businesses) nor the fact that instead of "other states in the region" Virginia is the only southern state to mandate RGGI on its residents.  The fact that 60 percent of respondents replied that Virginia should stay in REGI amounts to a self fulfilling prophecy.

The public comments demonstrate that many of the interest groups who lobbied for RGGI are now engaged in another campaign - this time to place as many comments as possible on the Regulatory Town Hall as possible opposing repeal.  For them its obvious that quantity far outweighs quality.  Not requiring names or addresses of those who wish to participate in the process fails Virginia.  Our comments are original.   Anonymous cut and paste jobs may serve to meet some groups quotas but do nothing to further public discourse.

It is a fact that RGGI was imposed by one party during the period of one party rule in Virginia.  VPCMA has a longstanding, demonstrated willingness to work with all parties to address the most vexing public policy issues facing our state.  Mandated electrification of the transportation and home comfort sectors must be a part of any future discussion on carbon reduction. 

We urge repeal and stand willing to work with all parties on an inclusive process that includes examination of the impact carbon reduction will have on in-state businesses, employees, homeowners, and Virginia's Transportation Trust Fund.

Thank you for the opportunity.


Michael J. O'Connor


Virginia Petroleum and Convenience Marketers Association

7275 Glen Forest Drive

Richmond, Virginia 23226






CommentID: 216154