|Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
|Ended on 4/9/2018
Dear Ms. Sabasteanski:
Thank you for the opportunity to comment on the proposed regulation for the Commonwealth to enter carbon emissions trading as a means for reducing the greenhouse gas contribution of coal-fired power plants of a certain size.
In general, I wholeheartedly support movement in this direction. As a global concern, the rapidly warming temperatures of our planet and the impact this has on climate, on sea levels, on ocean temperatures and acidity, and on severe weather events is deeply concerning for both human and ecologic reasons.
The approach of this proposed rule is strong – leveraging market forces as a means to create a lowerable cap on carbon emissions of our coal-fired power plants provides flexibility for the utilities impacted that strict regulations would not allow. Utilities will have the choice of to which power plants they will focus their resources for reducing carbon emissions as well as by what means they will do so, allowing for the most economically efficient path for achieving the cap. In addition, linking this rule to RGGI saves tax dollars by utilizing an existing market and not incurring the costs of having to create a market specific to Virginia.
I do, however, have a few concerns and suggestions that would improve this proposed rule that largely draw from the AEE STEER model for the Commonwealth (https://info.aee.net/steer-virginia).
Again, thank you for the opportunity to comment. I look forward to piloting the approach with suggested changes made and then expanding the program to additional GHGs and/or CO2 sources once the program proves successful.