Agencies | Governor
Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
Stage Proposed
Comment Period Ends 3/6/2019
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2/23/19  1:10 pm
Commenter: Bill

Support; VA Energy Plan should be part of a comprehensive Credible Climate Plan

I support the intent and actions contained in Virginia’s Carbon Action Plan including joining the Regional Greenhouse Gas Initiative (RGGI), and more broadly I support Virginia’s committing itself to more aggressive action on reducing its Greenhouse Gas (GHG) footprint than it has to date.  This should include removing regulatory/legislative barriers to increasing cleaner energy as a greater percentage of power provided in the state.

It would serve the State and its citizens well, if the Commonwealth would voice its support of the federal Energy Innovation and Carbon Dividend Act (H.R. 763) currently before Congress.  This legislation would be synergistic in its intent and desired outcomes to what Virginia is attempting to do by joining the Regional Greenhouse Gas Initiative (RGGI), would deliver significantly more CO2 reductions than the cap provided in Virginia’s Plan, and would address concerns about Virginia disadvantaging itself vs other states by leveling the Carbon Emission Reduction playing field nationally.

I am confident that the state has the expertise to assess the many options available to it to achieve greater energy efficiencies as well as other ways to significantly lower its GHG footprint.  The range of these is extremely far ranging including things as varied as setting its own auto fuel efficiency standards, requiring Leeds certifications or solar installation for future commercial and residential construction, setting its own cost of carbon/carbon tax on operations in the state or alternatively offering a low carbon tax break, improving mass transit, increasing the gasoline tax and using the funds for GHG reducing investments, etc.  I believe that the state, following the lead of many other entities, should commit itself to the U.S. Paris Agreement targets despite the fact that the President unwisely made us the only country on earth not party to that Agreement.  

I would also respectfully request that the State Carbon Action Plan be explicitly prepared in such a way that it is a part of a complete Statewide Credible Climate Carbon Reduction and Energy Plan.  I would like to offer a Framework for what is required for it to meet that objective.

The following link will take you to a paper presented in June at the Annual Conference of the Air and Waste Management Association on “A Framework for Credible 2 Degree Celsius Climate Planning”. fault/files/Fact%20Sheets%20or %20misc%20files/AWMA%20June%20 2018%20Conference%20Paper_A%20 Framework%20for%20Credible%202 %20Degree%20Celsius%20Climate% 20Planning.pdf

The Framework is illustrated with industry examples but is equally applicable to a State Climate and Energy Plan. I hope that you will read the entire paper and consider its use in your planning process, but I would like to highlight a few points from the 11 Elements in the Framework that I believe are vital for you to address in your Plan.

-        You must prepare and document the FULL GHG inventory for the state from some year you intend to use as a baseline.  This includes ALL GHG emissions that occur in the state regardless of who has direct control of them. This should include both absolute emissions and normalized emissions (this may require you to partition the absolute emissions into several categories suitable for a similar normalization factor.)  

-        You must state a target for your emissions reductions (both absolute and normalized) and the timeframe to accomplish it.

-        You must commit to specific quantifiable actions that will be taken to achieve those targets, AND project what those actions can realistically be expected to deliver, by when.  Reductions based actions committed to rather than on items under consideration or in process of being legislated should be addressed, but not relied upon to meet targets.

-        You must document and communicate progress annually, and identify steps to make up gaps between your target and what the plan is delivering.  

We stand little to no chance of succeeding in our effort to meaningfully address global warming, unless ALL stakeholders become engaged. This includes energy suppliers, energy users, government, investors, and the voting public.  It will not matter if tremendous efforts are made by, or against the fossil fuel industry, unless the market rewards those companies attempting to reduce their GHG impacts rather than punishes them, and unless the demand for their products is reduced.  If the market votes against climate friendly actions by selling stock, a company will correct its behavior in response to shareholder expectations.  If demand remains unchanged, it will make NO difference to GHG emissions if one company becomes a renewable leader, while other companies still sell the fossil fuel demanded by the market.  

This brings to the fore the crucial role of government fulfilling its responsibility to it’s citizens, and to humankind worldwide, to use both carrots and sticks to encourage the other stakeholders to act in ways that ensure that their actions are consistent with the Paris Agreement goal of seeking to hold temperature rise to no more than 2 degrees Celsius (though with progress to date, even that may soon be out of reach, if it is not already).  Virginia is responsible to its citizens to take such actions for their long-term wellbeing.  It cannot be argued that all action should stop and await action by the federal government, while that government it is shirking its responsibility for protecting the interests of all Americans by playing politics with the issue of global warming.

I would be happy to discuss the Framework with those preparing your plan if that would be of help to you/them.  I can also provide you the PowerPoint slides from the presentation if those would be of use. 

CommentID: 69251