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  6:58 pm
Commenter: Gus Hollberg

Lower the Carbon Cap to 33 million tons

If Virginia joins RGGI with the current regulations that would be a great success. However, I think DEQ should push for a lower initial cap or an earlier start date (2019 vs 2020) because of poor assumptions made in predicting CO2 generation.

I believe that DEQ’s estimates for our current and projected CO2 emissions are too high. Firstly, DEQ largely neglected the effect that new (and currently under construction) solar power plants would have to lower Virginia’s CO2 emissions while maintaining energy supply. Secondly, DEQ does not adequately model is the expected growth in electricity demand. While DEQ models the yearly rate of growth as high at 3%, a more realistic number in keeping with historical growth rates would be about 1%. Although, Virginia over the past few years has been reducing its electricity imports thus leading to more demand for electricity generation in-state, that transition is almost complete. It would be inaccurate to base projected growth in electricity demand on this ephemeral trend.

The current plan is to start the cap and trade program in 2020 because that is when the new RGGI rules are implemented. That seems to me like a reason out of convenience not necessity. Therefore, the cap should at the very least be lowered to 33 million tons since under the 34 million ton plan, the cap after one year would lower to 32.98 million tons. If Virginia could emit 34 million tons of carbon in 2019 and 33 million tons in 2020, the initial cap should reasonably begin at 33 million tons.

CommentID: 65213