I appreciate the opportunity to submit these comments on behalf of Friends of the Rappahannock (FOR). FOR is a watershed group whose mission is to be a voice and active force a healthy and scenic Rappahannock River.

FOR opposes this regulatory process effort to remove Virginia from the Regional Greenhouse Gas Initiative (RGGI). We believe this effort is unlawful as the 2020 law mandates participation in RGGI. Any effort to remove Virginia from participation in RGGI would have to be done through the legislative process.

We also oppose this process as 45% of all RGGI auction proceeds go to the Community Flood Preparedness Fund (CFPF) and this is the sole source of funding to the CFPF. Many localities in the Rappahannock watershed face increased risks from riverine and tidal flooding. These localities have applied for, received and will continue to benefit from CFPF funds for planning/capacity building and project construction that enable them to be more resilient to flooding events. To date localities and PDC's in the Rappahannock watershed have received over $540,000 in funds from the CFPF. This is only the beginning with many millions of dollars more needed.