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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8/29/23  9:23 pm
Commenter: Ken Sandler, PhD

An illegal, immoral and impractical proposal

The Youngkin administration’s proposal to pull Virginia out of the RGGI is unjustifiable from every reasonable perspective: Ii is illegal, immoral and impractical.

The proposal is illegal: the General Assembly ordered Virginia’s participation in RGGI and did not grant the executive branch the power to remove the state from it. The Commonwealth’s motto is “Sic semper tyrannis”, a reminder that in Virginia, the law is king, the king is not the law. No governor has the power to simply ignore the laws he is bound to follow.

The proposal is immoral: the impacts of the climate emergency on current and future generations keep becoming more and more clear and disturbing, as we see unprecedented wildfires, heat waves, floods, droughts, etc. erupt across the world. Virginia cannot fix this problem alone but we have a moral responsibility to be part of the solution, working with many others.

The proposal is impractical: we will lose hundreds of millions of dollars that the Commonwealth has invested in resilience, disaster recovery and energy efficiency aimed at low income residents.  The states already in RGGI have found spending on energy to have actually gone down during their membership terms thanks to the impacts of efficiency (  

RGGI works for the residents of its member states as well as for the rest of us who must suffer the impacts of climate change. Please end this assault on common sense and work with all sides to implement climate solutions rather than creating new problems.


CommentID: 219838