Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
Stage Proposed
Comment Period Ended on 4/9/2018
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4/8/18  10:49 pm
Commenter: Dana Schroeder / University of Virginia Office for Sustainability

Support for legislation - lower emissions cap recommended

I write today to show support for the proposed legislation which would result in Virginia cutting carbon emissions by joining the RGGI network for emissions trading. I would like to add comments on a few specific parts of the proposed legislation:

I support output-based updating of allowance allocations (9VAC5-140-6215) because this would prevent "leakage" of emissions to other states that aren't part of RGGI.

I support an emissions containment reserve as a way to adjust the emissions cap in the case that allowances are over-allocated initially.

Finally, I feel that the initial cap should be 33 million tons OR LESS. A cap of any more than 33 million tons would almost certainly be much too easy to meet, especially given recent growth in solar energy generation capacity that has not been factored into the model used to formulate possible initial caps.

Many thanks for your consideration.

CommentID: 65178