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  5:02 pm
Commenter: Peter Gates Cville100

Be Responsible

Dear Air Board Members,

         As you are aware, RGGI has brought in many millions of dollars in revenue since Virginia has started participating, and those funds have been applied to programs improving flood resiliency (over 20 projects in the Charlottesville/Albemarle Area, where I live) and energy efficiency for low-income households (unfortunately the # of these projects not as robust in this Area as the flood protection programs). As a renter, the lack of energy-efficiency subsidies hits particularly acutely; does the State government have a reasonable alternative to RGGI monies for such programs (a rhetorical question)? Is the alternative to RGGI monies in the realm of flood resiliency adequate as well? Lending poignancy to that last question are the results of a recent research study in Nature Climate Change by Princeton University investigators projected that back-to-back hurricanes, those striking the same general area along the U.S. East and Gulf Coasts within 15 days of each other, will increase in frequency by 30-fold under even moderate intensity GHG emission reduction efforts. 

           Beyond the fact of necessary revenue streams, RGGI directly incentivizes GHG emission reductions, unlike other State programs. I have spoken of resiliency efforts, but the State also need to focus on climate-change mitigation. Yesterday, a report was published in Nature showing that the Antarctic Ocean Overturning Circulation, the analogous circulation to the Atlantic Meridional Overturning Circulation keeping Europe temperate and stabilizing our climate in North America, is starting to collapse, with incredibly profound implications for global climate stability and oceanic ecological productivity. Is there a serious plan for GHG mitigation in Virginia that doesn't involve RGGI participation?

          A third study I want to mention concerns the socioeconomic and racial disparities of particulate air pollution; this New England Journal of Medicine article by Harvard University School of Public Health researchers showed very significant drops in expected death rates with stricter 2.5 micron particle emission standards, particularly within historically marginalized populations. Of course, as you are aware, GHG emitting sources such as coal-and gas-fired power plants are heavy contributors to this pollution issue. Switching to renewable energy sources in the State could help alleviate this historic environmental injustice, and RGGI participation incentivizes this positive outcome.

          We have only a decade or two to seriously address this issue before increasingly grave environmental and economic damage is locked in for multiple generations, with all the political and social instability that portends. Please do not leave your children and grandchildren this terrible burden. I believe that God calls us to be responsible stewards of Creation, and we owe it to the Lord, humanity, and our fellow creatures to strive to fulfill  this imperative.


Peter Gates




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