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
Previous Comment     Next Comment     Back to List of Comments
3/31/23  10:15 pm
Commenter: M. Lindemann

Staying in RGGI is the RIGHT THING TO DO for Virginia and Virginians

I sincerely appreciate this opportunity to assert my strong opposition to pulling Virginia from the Regional Greenhouse Gas Initiative (RGGI) program, now or at any time in the foreseeable future.


Virginia must stay in RGGI.


A Virginia native and current resident, I am a lover of both the Chesapeake Bay and our glorious mountains, as well as the beautiful land and waters in between. Professionally, I am also: a former award-winning NASA engineer; a serial entrepreneur; and an award-winning sustainable development pioneer. With my credentials, I could justifiably cite detailed verifiable scientific and legal reasons as to why Virginia should not be pulled from RGGI. Given that other commenters are providing such rationale, however, I shall refrain from repeating their claims, though I wholly concur with them.


I am instead writing to offer a range of other tangible albeit less technical reasons herein, as additional valid and applicable justification for why Virginia must stay in RGGI:


1. Some in our current Administration have promoted the false claim that removing Virginia from RGGI will stop unfair regressive charges for energy use by Dominion customers. In fact – and independent of RGGI altogether -- not only are Dominion’s charges by their design regressive in that higher-use/wealthier customers are given discounts not offered to their lower-use/poorer customers, removing the RGGI program’s real offerings of energy efficiency improvements and carbon emission reductions would be drastically regressive actions as their removal would affect most deleteriously those least resourced and most vulnerable of Virginia’s citizens. Even worse, removing Virginia from RGGI would not stop the regressive discriminatory discounts alluded to above in Dominion’s charge structure.


2. The Governor has, as of the last week in March 2023, formally agreed in principle to legislation passed in the 2023 General Assembly that effectively reduces Dominion’s utility charges on a statewide basis, obviating further the aforementioned (false) energy cost justification for removing Virginia from RGGI.


3. Moving on to a matter of critical importance: the need to provide flood preventative and protective measures throughout the State is both profoundly urgent, and vast. Our coastal, mountainous, river, and estuarine communities – all – are at extreme risk, with that risk by all empirical and theoretical measures increasing dramatically into and beyond the foreseeable future. This is true regardless of what one believes – or not – to be the cause. Only RGGI through its Community Flood Prevention Program provides funding for such prevention. To remove this essential and critically needed protective resource would be folly, and a permanent stain into perpetuity for any agent that should do so.


4. Moreover, while there has been some effort to stand up a separate and independent revolving loan fund to provide loan funding for flood “aftermaths,” it not only:

a) is not currently functional;

b) if ever functional, would not address flood prevention;

c) if ever functional, would at most provide loans (NOT grants) that would be an entire order or magnitude LESS (i.e., one/tenth or less) than that RGGI already offers as grant funding;

d) by virtue of being a loan fund rather than a grant fund, would require the applicant to be resourced, which automatically means it – unlike RGGI – would be another regressive source of funding, that by design benefits only those who have resources and not those who don’t. In other words, the “average” citizen or community, if ravaged by flooding, would likely not even qualify for this loan fund aid.


5. Of additional consideration: RGGI, as a grant source, provides funding that can in turn be used as critically scarce “match funding” for additional Federal sources of support that no other conduit available to Virginians – including the aforementioned revolving loan fund – can offer.


6. RGGI also is the largest, most accessible source of grant funding available to Virginians for obtaining the physical means to improve the energy efficiency of their residences at a significant scale. Such improvements save money, reduce energy consumption, and are better for our environment and health.


7. RGGI is designed to, over time, reduce carbon emissions, as has already been demonstrated to be successfully occurring in practice.


Each of the above points matters, but I’ll close with this: Cleaning up after the devastation of just one major flood in our ever increasingly developed State can not just wipe out our State’s budget surplus, but more deeply wreak havoc on all State programs and their funding… not to mention, destroy communities, lives and dreams. No one in our State is immune to the ravages of flooding. With extreme storms occurring ever more frequently, and of greater and more devastating strength, being given a path to prevention and resilience as is granted solely through RGGI’s Community Flood Preparedness Program – and not by any other mechanism in our State – must be allowed to continue.


Virginia must stay in RGGI.


Thank you for this opportunity to provide input.



CommentID: 216455