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  6:18 pm
Commenter: Benjamin Hoyne

ED 11

Executive Directive 11 is a strong first step towards lowering carbon emissions in order to increase renewable energy utilization, which has numerous benefits, including significant health, economic, and work force benefits for residents of Virginia and beyond.

According to ABT Associates, between 2009-2014 the states that participated in RGGI received incredible health benefits due to their carbon emissions reductions. Those avoided health benefits include:

  • 300-830 Premature Adult Deaths
  • 35-390 Non-Fatal Heart Attacks
  • 420-510 Cases of Acute Bronchitis
  • 8,200-9,900 Asthma Exacerbations
  • 13,000-16,000 Respiratory Symptoms
  • 180-220 Hospital Admissions
  • 200-230 Asthma ER Visits
  • 39,000-47,000 Lost Work Days
  • 240,000-280,000 Days of Minor Restricted Activity

The cost savings of the avoided health effects is estimated to be between $3 Billion and $8.3 Billion. Reducing carbon emissions has an incredibly positive impact on public health.

With regard to the initial cap on emissions, I suggest a cap of 33-34 million tons is too high. Other than a few variations attributable to weather, CO2 emissions from power plants in Virginia have held steady around 30 million tons over the past 9 years. In order to reduce emissions from historical levels, the initial cap must be below set below 30 million tons. DEQ should revise its modeling now that more 2017 data is available.

As energy demand in Virginia is not rising significantly, I would suggest that the baseline growth rate for demand be capped at 1% per year. Additionally the calculations in maximum renewable energy deployment need to be refigured. The actual solar capacity for 2017 is 360 MW, yet the DEQ projections suggest a maximum capacity of 274 MW in 2017 and 344MW in 2020. With the 2020 capacity estimates being lower than the actual 2017 levels, the calculations must be revised significantly to ensure the cap is at an acceptable level for the RGGI market.

I applaud former Governor McAuliffe, Governor Northam, the Department of Environmental Quality, and citizens of Virginia for moving the Commonwealth towards a cleaner and healthier future.

In Good Health,

Ben Hoyne, MA, MBA

CommentID: 65064