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 Proposed
Comment Period Ended on 3/31/2023
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3/31/23  4:00 pm
Commenter: KC Bleile

RGGI Provides Extraordinary Benefits for Virginians


March 31, 2023

Karen G. Sabasteanski 

Virginia Department of Environmental Quality

1111 East Main Street, Suite 1400

Richmond, VA 23218

Viridiant supports Virginia’s continued participation in the Regional Greenhouse Gas Initiative (RGGI). Founded in 2006, Viridiant is a 501(c)(3) non-profit organization based in Richmond serving the Commonwealth and beyond with a mission to support sustainable building processes through education, policy, consultation, and certification.

RGGI provides a proven market-based tool for responsibly and incrementally reducing greenhouse gas emissions from Virginia’s electric power sector. Given the global trajectory of climate change and Virginia’s particular vulnerability to catastrophic disruptions from rising oceans and extreme weather events, RGGI offers meaningful reductions in our greenhouse gas emissions to aid in the Commonwealth’s resilience.

Further, RGGI provides these emission reductions in a way that provides immediate net economic benefits to communities in every region of the Commonwealth. As research from VCU’s Center for Urban and Regional Analysis cited by Dr. Damian Pitt has indicated, every RGGI dollar invested in low-income energy efficiency efforts should generate more than $1.60 in total economic activity, generating some 2,000 new jobs and increasing Virginia’s GDP by some $1.75B. These are jobs in every city and county that cannot be exported.

Specifically, Viridiant applauds Virginia’s Department of Housing and Community Development’s (DHCD) use of RGGI via the Home Innovation in Energy Efficiency (HIEE) program. Early deployment of HIEE funds helped qualify a backlog of deferred households for  federal funding and utility programs for weatherization assistance. Subsequent funding prioritized the supply of energy efficient newly construction or rehabilitated affordable housing primarily driven by Virginia Housing’s Low Income Housing Tax Credit Program and developers leveraging those credits.

RGGI has enabled thousands of homes to qualify for federal weatherization assistance, increased the supply of affordable housing, reduced household energy burdens, and  generated economic development across the Commonwealth. But the benefits don’t stop there. Improved comfort, better air quality, and the reduced stress of unpredictably high energy costs are proven to boost worker productivity, reduce school absenteeism, and strengthen communities. These “non-energy benefits” of residential weatherization work are well-documented by Oak Ridge National Lab.

In summary, we urge Virginia’s continued participation in RGGI to keep these extraordinary benefits flowing.



KC Bleile
Executive Director, Viridiant



CommentID: 216171