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  4:57 pm
Commenter: Robert R Soule

I strong oppose the proposed rule to withdraw Virginia from the RGGI

I am writing to express my strong opposition to the proposed rule repealing Virginia’s participation in the Regional Greenhouse Gas Initiative (RGGI).  We are already behind schedule on reducing greenhouse gases, and the harmful effects of climate change are all around us, and more apparent with each passing day.  Climate change is the most critical issue affecting Virginia and the nation, and addressing this problem is vital to ensuring that my children and their children enjoy a stable climate and a prosperous future.  The RGGI was a positive step forward, and it is unimaginable to me that Virginia would take a step backward on a positive measure that is working.  There is absolutely no reason for Virginia to withdraw from the RGGI, and every reason to continue participation.

Moreover, this rule would directly contradict the specific and explicit will of the people of Virginia, who expressed their support for Virginia’s participation in the RGGI through their elected representatives in 2020.  It is entirely inappropriate, and possibly illegal, to overturn a decision by the elected legislature through regulatory action of this kind.
The proposed repeal is also both unnecessary and counterproductive to the interests of the people of Virginia.  The RGGI is working.  It lowers air pollution, which improves public health, including decreased asthma attacks, premature births, and missed days of school and work.  Since joining RGGI, Virginia’s power plant emissions have consistently decreased—by 12.5% between 2020 and 2021 and by nearly 8% between 2021 and 2022.
Virginia’s participation in the RGGI generates valuable funds. Virginia has already received more than $500 million from RGGI. Those funds provide a dedicated funding source for localities to plan for and prevent flooding.  With climate change comes increased flooding, and preventative measures are essential to prevent massive economic losses from flooding, which could cost Virginia an estimated $80 billion if left unchecked.  RGGI funding also supports efforts to provide safe, affordable, and energy-efficient homes to low-income families.
By gradually reducing the reliance of Virginia’s power plants on fossil fuels, RGGI also helps protect utility customers from higher bills caused by the volatility of fossil fuel prices, which are impacted by global market conditions, such as the supply disruptions associated with the war in Ukraine.
In short, the RGGI is working.  It is reducing our reliance on fossil fuels and providing valuable benefits in the process.  There is no reason to break something that is working, especially in opposition to the expressed will of the people and legislature of Virginia.  This is the most important issue for me and my family, and we expect this proposed rule to be withdrawn.
CommentID: 216224