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  6:33 pm
Commenter: Brian Stephenson

Request to Remain in RGGI

To Governor Youngkin,

you have correctly noted that the RGGI is akin to a carbon tax, but seem to misunderstand its merits. Presently, the marginal benefit to society (Virginia) of carbon powered (oil, coal, and gas) electricity is outweighed by the marginal social costs. Meaning, carbon powered electricity is too cheap, and as a result we are producing too much carbon dioxide (among other greenhouse gases). Carbon taxes (and by extension the RGGI) correct this market failure by internalizing the negative externalities of carbon powered electricity. This is not to say that too much electricity is bad, to the contrary, energy abundance is good, but it should be low-carbon. This goal actually aligns with your own goal of supporting nuclear power in Virginia. Remaining in the RGGI provides an extra incentive to expand Virginia's nuclear fleet.

If I could make one change to the RGGI, I would redistribute part of the carbon tax revenue, as a sort of reparation for the damage one does to each other via their carbon emissions. That, or using the revenue to invest in modern nuclear, to secure reliable clean energy for Virginia's future. I strongly encourage you to reconsider leaving the RGGI.

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