First, I would like to say that, as a fellow Virginian, I am in favor of passing this regulation to cap CO2 emissions for Virginia. However, I wanted to point out some information that the DEQ failed to utilize in their models when coming up with a cap of 33-34 million tons. This information, if implemented, would further reduce the proposed cap below 33 million tons.

To start, the models did not accurately depict the amount of current solar power and amount of future solar power used in Virginia. The state already has more than 360 MW of solar power, even though the model used a current estimate of 274 MW. In additon, the model used to calculate a reasonable cap had an extremely slow growth rate for solar energy in Virginia; however, the amount of solar energy in queue for the next few years will increase the total output by at least 1000 MW, including a 500 MW plant that is being built in Spotsylvania. 

In addition, DEQ assumes a growth rate in electricity demand of 1.9-3%, but the expected demand growth over the next 15 years is only roughly 1%. This is part to more energy-efficient appliances being used throughout the state. Also, the DEQ is using the information that power plant CO2 emissions have been overall increasing since 2012, but there are several complications that can disprove this assumption. As 2012 was an anomoly in terms of weather, the year included a relatively warm winter and cool summer, which means the overall enery consumption would be low compared to other years; therefore, the total power plant CO2 emissions would be lower relative to neighboring years. Virginia has also reduced the amount of electricity imports from other states by creating more power plants in the state; because of this, Virginia is now responsible for these emissions since the electricity was made in-state versuse out-of-state, which would result in skewed data and growth. 

As a result of these inaccurate models, either new models should be created or the regulation should include an even lower cap than 33 million tons of CO2.