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  8:05 pm
Commenter: Stephen D'Alessio

Virginia Should Stay in the RGGI

I am writing today to urge the Virginia state government not to leave the Regional Greenhouse Gas Initiative  (RGGI). Climate change has the potential to completely end human existence. Now is not the same time to indulge in short-sighted, misguided thinking and avoid the issue. The RGGI has been a great means of stopping global warming and moving to a decarbonized economy:

• It benefits incumbent utilities with a flexible and responsibly paced instrument for  decarbonizing its energy resources that is cost-neutral to the utility

• RGGI’s market-based approach to reduce GHG emissions allows utilities to meet  electricity demands without requiring a specific mix of generation sources, while  allowing for flexible decision-making. Utilities can meet the environmental  performance requirements of the program in the most cost-effective manner with  the flexibility to plan and phase implementation in a responsible path toward a  clean energy resource portfolio. 

• The allowance market enables utilities to optimize their approach to decarbonization, encouraging early GHG reductions through allowance banking and multi-year compliance periods. 

• The cost containment reserve mechanism of RGGI mitigates any risk associated  with high allowance costs, thus limiting price volatility so utilities can plan energy  generating resources for the future with limited uncertainty. 

• At the same time, RGGI is a tailored, mission-specific program that will cease  operation once decarbonization goals and defined outcomes are achieved.

I strongly urge the state government to put a halt to this process of exiting Virginia from the RGGI immediately!

CommentID: 216434