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 Final
Comment Period Ended on 8/30/2023
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8/25/23  10:53 pm
Commenter: Roy N. Gamse

Stay in RGGI to Protect Virginia's Economic and Environmental Interests



I am Roy Gamse, a resident of Arlington, VA. I am vehemently opposed on both environmental and economic grounds to the proposal to withdraw Virginia from the Regional Greenhouse Gas Initiative.


For background, I am a former Deputy Assistant Administrator (DAA) and Acting Assistant Administrator of US EPA. I served under Presidents Nixon, Ford, Carter, and Reagan. My responsibility as DAA of Planning and Evaluation was to ensure that costs, benefits (quantified and monetized to the extent feasible), economic impacts, cost-effectiveness, and cost-benefit comparisons of proposed EPA regulations were competently analyzed and considered within the legal constraints of governing legislation. My group was the advocate for proper balancing of environmental benefits and economic impacts of EPA rules.  I hope that the Governor and the Air Pollution Control Board would bring the same concern for proper analysis and balancing to this proposal.


Here is why I strongly oppose withdrawing Virginia from RGGI:


Damages from climate change are real.  Despite claims of a few isolated naysayers, there is widespread global consensus that climate change is real. The Paris climate agreement is a legally binding treaty that was agreed to by 196 countries in 2015 and has now been signed by all but one country in the world. The evidence of damages from climate change are now exceeding those on which the treaty was based. They are evident worldwide, all over the U.S., and in Virginia, particularly in Virginia’s coastal areas.  This summer’s nationwide climate disasters reinforce the evidence of the mounting damages from climate 


Climate change is now affecting and will affect Virginia.  Coastal flooding is a serious concern, particularly in the Hampton Roads area, but elsewhere as well (even Arlington has suffered unplanned-for flooding). Prudent communities in Virginia are making and implementing plans to avert the damages from flooding resulting from climate change. Damages from dramatic climate events across the country illustrate the risks to Virginia. For example, the city of Miami has a $3.8 billion plan to combat the risks of sea-level rise and flooding. The APCB and Virginia must be realistic about the threat to Virginia, particularly its coastal areas. Virginia has already used RGGI funds to help communities affected by flooding over the summer.


Withdrawing from RGGI will exacerbate damages from climate change in Virginia and nearby states. Climate-affecting pollution and its environmental and economic impacts do not respect state boundaries.  Virginia today suffers from pollution originating in other states, just as pollution from Virginia affects nearby states. RGGI has established an effective way for the participating states to work together to reduce climate-affecting pollution and protect against the damages it will increasingly cause.


Withdrawing from RGGI is economically foolhardy. RGGI has already raised more than $580 million for Virginia, which can be used to help communities most harmed by flooding and other impacts of climate change. And it can be used to help families lower electricity bills, if that is your concern. The proposal to withdraw from RGGI says nothing about how Virginia will replace these funds, especially as the need for protecting against the negative effects of rising sea level and flooding increases.  Denying the reality of climate change and its negative economic impacts and then walking away from the funds to avert or repair the greater damages that result is fiscally irresponsible.


RGGI costs need not increase electricity costs to residents. RGGI doesn’t require that fees on climate pollution be passed on to Dominion Energy’s customers. That is a choice that Dominion has made in passing on a small administrative cost.  States participating in RGGI have largely experienced a drop in electricity prices (up to 6%), while non-RGGI states have experienced increases (up to 9%).  RGGI has led to 45,000 jobs in participating states, and those states have experienced economic growth 31% greater than non-RGGI states (at the same time as RGGI states reduced their climate-warming emissions 90% faster than non-RGGI states). To drop out of RGGI supposedly to avoid significant electricity cost increases and economic impacts is fantasy that just ignores the factual real-world experience.


More than two-thirds of Virginians support RGGI. The Christopher Newport University poll released February 21 shows 67% of Virginians favor remaining in RGGI, while only 26% favor withdrawing.  Of the public comments filed on the proposal earlier this year, 93% opposed withdrawal  from RGGI and only 7% supported withdrawal [730 against and only 51 in favor of withdrawal by the APCB count (which did not count thousands of comments in opposition)]. How can four new APCB members just blatantly ignore such overwhelming citizen opposition to the proposed withdrawal??


You have to ask: whom does the Air Pollution Control Board represent? It appears to me as if the four new APCB members are blindly following political views and ignoring the environmental and economic facts.  The new APCB members should live up to their oaths of office and represent the interests of Virginia citizens, not the political dictates they seem to be following.


The Governor and the Air Pollution Control Board cannot legally remove Virginia from RGGI.  Virginia’s participation in RGGI stems from a law passed by the Virginia state legislature and signed by the governor. Neither this governor nor the APCB has the authority to unilaterally withdraw from RGGI. 



It is time for the APCB to recognize the overwhelming environmental and economic benefits of RGGI participation for Virginia and shelve this illogical ideological plan to drop out.

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