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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8/30/23  1:34 pm
Commenter: Joy Loving, Climate Action Alliance of the Valley

CAAV Opposes This "Final" Regulation

Climate Action Alliance of the Valley (CAAV) has repeatedly and consistently opposed this shameful series of actions by the current Governor and his appointed Air Quality Control Board to withdraw Virginia from the Regional Greenhouse Gas Initiative (RGGI). CAAV reiterates its opposition to this “final” regulation, and those actions leading to it, regarding them as shameful and illegal because …


  1. The publication represents an abuse of authority (that is, fortunately, being legally challenged). RGGI is law: Virginia couldn’t participate without legislative authority and it can’t withdraw from its participation without legislative authority. This regulatory action isn't supported by law.
  2. Come January 2024, many Virginians, who greatly need and could have benefited from the programs RGGI was designed to fund (and has funded), may no longer be aided in bringing down their energy bills and making their communities more flood resilient. The needs are great and will continue in the absence of specific and sufficient funding. Hopefully, RGGI funding will not cease.  In the meantime, we call on the Governor to replace the funding and ensure the RGGI programs around energy efficiency and community flood resiliency preparedness continue to operate without any interruption.
  3. Virginia has public officials who acted deliberately and willfully in the face of massive opposition by many, many Virginians all over the state, and without any competent or logical reasoning offered during the regulatory process. The Governor and the Air Board made the DEQ reverse its previous assertions, reasoning, conclusions and bases for actions, greatly reducing its—and their-- already strained credibility.


CAAV looks forward to a successful outcome to the legal challenge now underway, to Virginia’s continued participation in RGGI, and to the current Administration's ongoing funding of the RGGI programs.

CommentID: 219929