Columbia Gas of Virginia submits these comments concerning the Proposed Regulation for the Amendment and Repeal of 9 VAC 5-140 Regulation for Emissions Trading (Proposed Repeal) for your consideration.  Columbia Gas strongly supports the Proposed Repeal. 

Environmental management and the making and moving of energy, products, and people are linked.  Economic prosperity, environmental protection, business consumption and human health are interdependent necessities of the U.S. economy.  Federal and state-administered climate programs and policies designed to address global warming should carefully balance these competing necessities by applying rigorous scientific and economic standards. 

Columbia Gas’ large industrial customers are subject to air permitting requirements under 9 VAC 5-140 Regulation for Emissions Trading, commonly known as the Virginia Regional Greenhouse Gas Initiative (RGGI) Rule (the Rule), along with our electric utility customers.  However, all of our customers have been affected by RGGI due to the costs it imposes upon Virginia electricity ratepayers.  As such, we support the Youngkin Administration’s efforts to repeal 9 VAC 5-140 (RGGI) for the following reasons:

1. RGGI is unnecessary and redundant to decarbonize Virginia’s electricity generation.  The Virginia Clean Economy Act will accomplish this goal through its renewable portfolio standards.
2. RGGI does not operate like a Clean Air Act regulation.  RGGI does not mandate CO2 emission reductions and has no National Ambient Air Quality Standards,  measurements, or monitoring to determine its effectiveness.
3. RGGI operates like a tax on electric utility consumers. Dominion Energy projects the RGGI cost to comply is $723 million from 2021 through December 2023.  Of that amount, $373 million is the estimated price tag for August 1, 2022 through December 31, 2023.  For a high-usage, high-load factor industrial customer, the increase could be more than $80,000 each month, which is the equivalent to 12 full-time production positions with full health benefits, paid time off, and retirement.
4. Virginia should address resiliency infrastructure through General Fund appropriation and accountability.

In closing, VCEA is the proper regulatory approach to mandating the reduction of CO2 emissions from the electric utility industry.  RGGI is an additional tax that will make the cost of electricity more expensive and Virginia less competitive.  Columbia Gas appreciates your consideration of these comments in support of the repeal.

Brent Archer

President and COO

Columbia Gas of Virginia