REJECT the proposed Regulation for Emissions Trading 9VAC5-140 and do NOT attempt to illegally withdraw Virginia from the Regional Greenhouse Gas Initiative (“RGGI”).

First, the RGGI program works to advance the Air Board’s own mission to “abate, control, and prohibit air pollution.”  The proposed regulation would do the opposite -- increase air pollution -- in open contravention of Virginia law.  What is more, air pollution in Virginia has been significantly decreased under the program (in both 2021 and in 2022, the first two years of the program), a benefit the proposed regulation and DEQ fact sheet fail to address.  

Second, the Board lacks the authority to erase the existing RGGI regulations, under the terms of the RGGI law itself. Virginia’s RGGI law clearly states the Air Board “shall” join RGGI, a clear mandate from the legislature that the DEQ fact sheet fails to address.

Third, DEQ’s fact sheet fails to mention the lowered energy costs to low-income Virginians and the flooding protection benefits that RGGI provides Virginia, making the justification for the proposed regulation incomplete.

I hope that you listen to the vast majority of Virginians who support this key climate program and reject this regulation to withdraw from RGGI once and for all.