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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4/9/18  4:38 pm
Commenter: Jonathan Miles, Ph.D., James Madison University

Regulation must include Set-Aside, otherwise could present barrier to renewble energy projects

I serve as Professor of Integrated Science and Technology, and as Principal Investigator on a sponsored project funded by USDA and the Commonwealth to advance distributed-scale wind projects on agricultural lands and at rural small businesses throughout the state.

The CO2 Budget Trading Program as written will not provide any avenues for voluntary market customers to ensure that their renewable energy purchase contributes to emissions reductions beyond the cap set by the program.  All RGGI states (with the exception of Delaware) and California have implemented voluntary renewable energy set-aside mechanisms in order to support voluntary market demand.  Without the set-aside, Virginia generation would be ineligible for participation in the Green-e Energy market, meaning that regional voluntary market customers would have to invest in renewable energy in nearby states rather than Virginia in order to have the renewable energy Green-e Energy certified.  This would in fact benefit neighboring states and would discourage increased investment in renewable energy in Virginia.  The set-aside mechanism is important to continue to stimulate private investment in renewable energy in Virginia, which in turn will promote local jobs and businesses, and further reduce greenhouse gas emissions generated in the state.

I strongly encourage the inclusion of the voluntary renewable energy market set-aside allocation mechanism (“set-aside mechanism”) from Section XX-5.3(l) of the RGGI Model Rule ( in the CO2 Budget Trading Program regulation.


CommentID: 65204