Virginia Manufacturers Association

Comments on the Proposed Amendment and Repeal of 9 VAC 5-140

Regulation for Emissions Trading

          The Virginia Manufacturers Association (VMA) submits these comments concerning the Proposed Regulation for the Amendment and Repeal of 9 VAC 5-140 Regulation for Emissions Trading (Proposed Repeal) for your consideration.  VMA strongly supports the Proposed Repeal, as more fully discussed below. 

I.        The Virginia Manufacturers Association.

          VMA represents the 6,700 manufacturers across the Commonwealth that employ over 230,000 individuals.  Virginia’s manufacturing sector contributes $47 billion to the gross state product and accounts for over 80% of the state’s goods exports to the global economy. The manufacturing sector is also energy-intensive and particularly sensitive to the costs associated with environmental regulations and taxes on energy. 

          Environmental management and the making and moving of energy, products, and people are linked.  Economic prosperity, environmental protection, business consumption and human health are interdependent necessities of the U.S. economy.  Federal and state-administered climate programs and policies designed to address global warming should carefully balance these competing necessities by applying rigorous scientific and economic standards.  

VMA’s electric generating unit (EGU) members are directly impacted by the requirements of 9 VAC 5-140 Regulation for Emissions Trading, commonly known as the Virginia Regional Greenhouse Gas Initiative (RGGI) rule.  In addition, larger manufacturing members are subject to air permitting requirements under these provisions.  However, all of our members have been and, without this repeal, will continue to be negatively affected by RGGI due to the staggering costs it imposes upon Virginia electricity ratepayers.  VMA has been an active opponent of Virginia joining RGGI since its inception, foreshadowing the cost burden, ineffectiveness of the program, and unlawful hidden extra-territorial tax on Virginians.  We applaud the Youngkin Administration’s efforts to reveal the ineffectiveness for reduction of CO2 and the overly burdensome costs of RGGI and proceed with the repeal of 9 VAC 5-140 (the RGGI rule) for the following reasons:

1. RGGI is unnecessary and redundant to decarbonize Virginia’s electricity generation.  It is important to note that CO2 emissions in Virginia have steadily dropped.
2. RGGI does not operate like a Clean Air Act regulation and contravenes the Code of Virginia.
3. RGGI is an economically harmful and non-transparent tax on electric utility consumers.
4. Virginia has the means and opportunity to address resiliency infrastructure in other ways that will be significantly more effective than RGGI.