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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4/4/18  3:27 pm
Commenter: Coleman Dickerson

Pro Carbon Cap and Trade: Initial Cap must be 33 Million Tons

This regulation needs to be put in place, but not without some changes which have to be made within the modeling process and general process of assumptions involved in its synthesis. As it stands now, the regulation grossly overestimates the projected growth in Virginia's future electricity consumption. This overestimation has emerged from both neglecting the strides the state has been making in increasing solar power prominence and neglecting the reduction of increasing electricity demand given a weakening stream of electricity imports. I insist that the projections for Virginia's future electricity demand be re-modeled and realistic expectations for this growth replace the 1.5% - 3% estimation given in the current report. Updating the models with more relevant and accurate information would provide evidence supporting the 33 million ton cap of CO2 emissions from power plants versus the 34 million ton cap. 

Setting the cap for CO2 emissions at 33 million tons as opposed to 34 million tons would provide a more accurate goal for the front end of this regulation's time allotment. Reaching the estimations for our 2030 cap is more feasible when the range between starting goal and ending goal is decreased. I support the carbon cap and trade regulation and expect the initial cap to be set at 33 million tons of CO2 given the overestimations the proposed regulation has made in regards to projected electricity consumption in Virginia. 

CommentID: 64520