Dear Ms. Karen G. Sabasteanski,

RE: Support for 9VAC5-140. Proposed Regulation for Emissions Trading Programs.

On behalf of the U.S. Green Building Council (USGBC), a non?profit organization with a strong community in Virginia, we are pleased to provide our support for the re proposed Carbon Emissions Trading Programs Regulation and urge timely adoption after consideration of public comments.

The Commonwealth is a leader in green buildings as a 2018 top ten state for LEED with certificated buildings spanning the commercial, residential, healthcare, educational, retail and public space. Virginia is also home to over 100 USGBC member organizations encompassing architecture and engineering firms, product manufacturers, realtors, contractor and building companies, educational institutions and government agencies, as well as nearly 5,300 individual members. 

On behalf of these member organizations and credentialed professionals in Virginia, we wish to make the following comments:

1. We support the new proposed baseline emissions cap of 28 million tons. With the significant renewable energy and energy efficiency programs set forth in SB 966, this lower cap is needed to help ensure the proposed rule will meet its goals of reducing carbon emissions and pollution in the Commonwealth.
2. USGBC also applauds the Department’s effort to evaluate the program’s impacts on vulnerable and underserved communities. We urge the Department to more fully articulate the plan for increasing participation of these underserved communities in the review of the program’s impacts on their communities. It is well established that disadvantaged populations are disproportionately impacted by air pollution, including traditional pollutants such as particulate matter.

Thank you again for your leadership and commitment to our shared goal to protect and enhance the future economic health and resilience of Virginia by moving Virginia forward to becoming the first southern state to cap carbon pollution from power plants. 

Sincerely,

Elizabeth Beardsley, Senior Policy Counsel, U.S. Green Building Council 

cc Maren Taylor, Advocacy and Policy Associate, U.S. Green Building Council