Action | Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22) |
Stage | NOIRA |
Comment Period | Ended on 10/26/2022 |
The repeal of the regulation implementing the Regional Greenhouse Gas Initiative (RGGI) participation must be analyzed both for the benefits and costs of repeal and the benefits and costs of no action, which is to continue participation. This analysis must recognize time horizons to 2050 as the Virginia Clean Energy Act, the law that requires participation in RGGI, used this year as a benchmark. The analysis must also consider a social discount rate to recognize the impact of the regulation on my children and their potential children. A comprehensive analysis will almost certainly demonstrate the long-term broad and individual net economic benefits of taking no action and remaining in the program.
The analyzed benefits and costs of no action must include:
The analysis must recognize the actual (not modeled) impact of RGGI on rate costs in other states and discuss the mitigation of RGGI on other energy cost factors, including the long-run electricity cost reductions associated with renewables development. The analysis must describe the incremental cost impact of RGGI in context, not of the nation as a whole, but instead similar economic and energy systems. Any cumulative energy cost impact analysis must describe the synergistic connection between any energy projects used to consider cumulative cost impacts to rate payers. For instance:
The analysis must provide evidence or references that indicate Virginia is less competitive with other states, as was stated without reference or citation in the notice. Any reductions in competition claimed must use metrics that show Virginia’s economic decline relative to other states due to the participation in RGGI.