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  5:23 pm
Commenter: BREDL, FWW, PDAction, Preserve Floyd and REEVA

Coalition Comment on Proposed Regulation for Emissions Trading

Karen G. Sabasteanski

Department of Environmental Quality

1111 East Main Street, Suite 1400

P.O. Box 1105 

Richmond, VA 23218


April 9, 2018

RE: Regulation for Emissions Trading (9VAC5-140)

To view the full submission, please go to:


Dear Ms. Sabasteanski:

On behalf of the Blue Ridge Environmental Defense League, Food & Water Watch, People Demanding Action, Preserve Floyd and the Renewable Energy & Electric Vehicle Association (REEVA), we welcome the opportunity to submit comments in opposition to the Virginia State Air Pollution Control Board’s proposed “Regulation for Emissions Trading Programs” (9 VAC 5-140), published January 8, 2018. 

The Blue Ridge Environmental Defense League is a regional, community-based, non-profit environmental organization. Our founding principles are earth stewardship, environmental democracy, social justice, and community empowerment. Food & Water Watch is a national advocacy organization that champions healthy food and clean water for all with over 23,000 supporters in Virginia. People Demanding Action is a mass-based political movement and network rebuilding a populist coalition representing 8,500 Virginians to protect and preserve the dreams of our children and the coming generations. Preserve Floyd is working to prohibit the proposed Mountain Valley Pipeline and Atlantic Coast Pipeline from coming through the Appalachians and protecting and preserving our community. REEVA helps local Southwest Virginia members install renewable energy and build electric vehicles. 

The proposal aims to cap and reduce carbon dioxide (CO2) emissions from fossil fuel-fired electric power generating facilities by having the state join an interstate trading program known as Regional Greenhouse Gas Initiative (RGGI). Virginia’s participation in a cap-and-trade program like RGGI is not the answer. 

RGGI allows polluters to buy and sell allowances in lieu of direct emissions controls. RGGI’s inherently flawed and harmful approach has not been proven to reduce CO2 emissions and has encouraged the shift to natural-gas fired power plants, increasing dependence on gas from hydraulic fracturing (or fracking) at the expense of renewable energy while allowing accompanying methane emissions to continue unabated. Moreover, RGGI is essentially a pay-to-pollute structure that enables polluters to simply buy allowances for the right to pollute rather than decrease their emissions, which effectively encourages more pollution in lower-income areas and communities of color, exacerbating underlying environmental justice disparities. And the program’s seemingly most attractive feature as a state revenue raiser for environmental initiatives has been undercut as states regularly raid these funds to fill coffers and satisfy budget deficits.   

Former Governor McAuliffe’s Executive Directive 11 (2017), “Reducing Carbon Dioxide Emissions from the Electric Power Sector and Growing Virginia’s Clean Energy Economy,” unambiguously states that the Commonwealth of Virginia is under threat from climate change and necessitates action. Across the state, increasing temperatures and rising sea levels due to climate change has already resulted in saltwater intrusion, disappearing beaches and more intense storms and floods. Economic losses and damage to both the environment and human health are expected to worsen.  Urgent action is needed to reduce greenhouse gas emissions that contribute to climate change and lessen the severity of these impacts. 

While it is promising to see Governor Northam move to take action to mitigate Virginia’s climate change risks and control CO2 emissions from the electric power sector in accordance with Governor McAuliffe’s directive, the proposal to join RGGI will not and cannot achieve the directive’s goals to curb greenhouse gas emissions. We oppose market-based schemes like RGGI that purportedly protect the environment by pricing and trading pollution, but actually exacerbate pollution and climate change. 



Louis Zeller, Executive Director, Blue Ridge Environmental Defense League

Wenonah Hauter, Executive Director, Food & Water Watch

Andrea Miller, Executive Director, People Demanding Action

Mara Robbins, Community Organizer, Preserve Floyd

Mark Laity-Snyder, Vice President, Renewable Energy & Electric Vehicle Association



CommentID: 65211