Having learned about Governor McAuliffe's Executive Directive 11 and attended last weeks public policy forum on RGGI in Richmond, I am writing to express my initial views. It's imperative that, finally, Virginia is planning to cut carbon pollution; such efforts would be in compliance with the Paris Climate Accord. As a resident of the Commonwealth and native Virginian, I very much want my state to create a plan that provides an equitable and just cap that will significantly reduce greenhouse gas emissions. To ensure that the policy best benefit Virginians, following are high priority actions and goals for the DEQ to address in its draft rules:

1. Create a rule based on the strongest available science that significantly reduces carbon pollution from Virginia’s new and existing power plants.
2. Ensure that Virginians — not utilities — benefit from any profits from carbon regulations, especially our front-line communities and those disproportionately adversely impacted by the move away from fossil fuel production and operations (i.e., Virginia's "coal counties").
3. Address the disproportionate environmental effects experienced by our most vulnerable communities and populations (e.g., low income, minorities, coastal, those in path of proposed pipelines).
4. Grow the economy and reduce carbon pollution by maximizing investments in zero-carbon wind, solar, and energy efficiency.
5. Provide a transparent and accessible public hearing process where all concerned Virginians can fully participate in the rule-making process.

With respect to these priorities, monies derived from the cap must not go to the utilities, with the following exceptions:
A. The regulations specify that the funds be specifically designated for programs through which utilities will provide direct fuel assistance to those in need (the regulations would need to define "need"/eligibility requirements).; and/or
B. The regulations require utilities to establish and maintain effective energy efficiency programs enabling customers to cost-effectively reduce their energy usage; such programs should provide on-bill financing for such customers and should provide to those in need no/low cost energy efficiency upgrades (using definition similar to A.); and/or
C. The regulations require utilities to establish programs to offer Virginians options for choose renewable energy to meet their electricity needs, including customer-owned community solar and other distributed renewable energy methods (e.g., rooftop, residential, commercial, agricultural wind and solar). The regulations authorize utilities to facilitate customer participation through such mechanisms as on-bill financing; and/or
D. The regulations require utilities to sponsor and fund community resilience programs to enable coastal locations and other vulnerable communities to prepare for and ameliorate the worst effects of severe weather and other consequences of climate disruption.
E. The regulations require utilities to establish re-training to employees displaced by the transition from fossil fuel to renewable programs, by sponsoring and funding educational opportunities in affected communities, working through the Virginia Community Colleges and Universities; and/or

With respect to these exception categories, the regulations must provide that the utilities cannot charge customers who participate in any of these programs "extra" fees such as standby charges, net metering caps, and/or similar disincentives.

If monies from the cap don't flow to utilities, then the state of Virginia should establish the programs described in A through F above.

Finally, because I understand that, in the past, DEQ has dismissed comments offered through organizations such as CCAN, I am taking the liberty of also sending these comments individually, as a Virginia citizen, as part of the public comment process. I will provide additional comments about Virginia's joining of RGGI or other regional fee and dividend programs.