Narissa Turner, Climate & Energy Policy Manager: Virginia’s Emissions Reduction Program is benefitting all Virginians in numerous ways:

1. Through its proven market-based mechanism, the program is working to drive down air pollution and improve public health;
2. Continued participation in RGGI will help protect customers from rising fossil fuel prices as power plant owners reduce reliance on fossil fuels;
3. Low-income households are getting their homes weatherized, finally getting the energy bill relief they need;
4. Highly efficient affordable-housing units are under construction to help fill the severe affordable-housing gap with units that will come with low energy bills for tenants;
5. And localities finally have access to a dedicated state fund to help address the increasingly devastating flooding that is happening all across the Commonwealth.

Jay Ford, Virginia Policy and Grassroots Advisor: Climate change impacts such as sea level rise and increased rainfall intensity are already impacting the daily lives of Virginians, but these rising waters are also increasing nutrient and sediment loads to the Chesapeake Bay. Additionally, increases in water temperature are reducing the Bay’s ability to hold dissolved oxygen. Virginia’s Phase III Watershed Implementation Plan estimates 9 million pounds in additional nitrogen reductions will be needed throughout the watershed to keep pace with climate impacts through 2025. As we look past 2025, sea level rise and rainfall intensity will continue to increase, bringing additional pollution loads into our waters. Virginia must do its part to reduce global emissions and the RGGI cap and trade approach ensures our numbers will continue to decline in the years ahead.

Andrew Payton, Chair: We provided two opinion pieces addressing our substantive concerns with the proposal for Virginia to withdraw from RGGI. Our January 26, 2022 piece argued that Virginia Should Remain In Regional Greenhouse Gas Initiative; our March 25, 2022 open letter to Valley Legislators pointed out that there is no logical reason to withdraw Virginia from RGGI and, further, that the decision to do so must come from the legislature. We stand by our previous opinions and hereby incorporate them into these comments.

Victoria Higgins, Virginia Director: The proposed action by the air board offends our democratic norms and the rule of law, bypassing the will of the people and their chosen representatives in the General Assembly. HB 981, the Clean Energy and Community Flood Preparedness Act, requires Virginia to participate in the allowance auction process through RGGI. This year, 61 legislators affirmed that HB 981 requires Virginia to participate in RGGI, and that removal via the air board is “improper and illegal.” HB 981 is not a vague directive for state agencies to administer RGGI when and as they see fit. It is a mandate. This effort to dress up a political directive in the guise of legitimacy by following the Administrative Procedure Act process does not change the powers bestowed upon the Board.

Caroline Jones, Mandy Warner, and Peter Daigle: The relevant agencies’ authority and actions around exiting the RGGI program are bound by Virginia’s statutory requirements — requirements that only both houses of the General Assembly and the governor, acting in concert, may alter. This unnecessary and ill-advised process is at the expense of Virginians who are being harmed by the impacts of climate change on a daily basis.

Andrea McGimsey, Executive Director: We are submitting for the public record an opinion piece penned by two of our faith leaders, published in The Washington Post.

Your board is charged with controlling air pollution. Please stop your efforts to pull us out of a successful, bipartisan program that controls air pollution. We respectfully ask that you do the job that you were actually appointed to do — control air pollution — and put a halt to any action to pull Virginia out of the Regional Greenhouse Gas Initiative.

Brent Hunsinger, State Policy Coordinator: We also oppose this process as 45% of all RGGI auction proceeds go to the Community Flood Preparedness Fund (CFPF) and this is the sole source of funding to the CFPF. Many localities in the Rappahannock watershed face increased risks from riverine and tidal flooding. These localities have applied for, received and will continue to benefit from CFPF funds for planning/capacity building and project construction that enable them to be more resilient to flooding events. To date localities and PDC’s in the Rappahannock watershed have received over $540,000 in funds from the CFPF. This is only the beginning with many millions of dollars more needed.

Pamela Goddard, Senior Program Director, Mid-Atlantic Region: Virginia is fortunate to host 22 national park sites, some established to celebrate their natural beauty like Shenandoah National Park, and others to commemorate our nation’s history like Colonial National Historical Park. Over 20 million visitors come to national parks in Virginia and contribute over $1.5 billion in economic benefit from tourism. Our parks must have clean healthy air to thrive. RGGI reduces greenhouse gas emissions and improves air quality. Decreased pollution translates into public health benefits for all Virginians.

Lena Lewis, Energy and Climate Policy Manager: We have outlined four major benefits from RGGI energy efficiency revenue: less air pollution, lower energy bills, better health outcomes, and more local jobs. 

The longer Virginia stays in RGGI and puts RGGI revenue to work as designed, the more these benefits will accrue for society.  That’s important, because the need to improve energy efficiency for low-income households is huge, and the benefits extend beyond the families living in them.  There are no other sources of funds that comes close to matching RGGI if these funds are revoked.  In fact, in 2021, the RGGI auctions brought in millions of dollars more than every other energy efficiency program in the state – combined.

Sheri Shannon, Co-Founder: The fact is that RGGI is working for Virginia. Carbon emissions have declined, and decreasing air pollution is a benefit for public health, especially for children and other vulnerable populations. The program ensures that polluters have to pay for the damage they cause to communities, and reinvests that money into helping people. Please do not repeal our participation in this program and instead focus on the environmental, health, and economic benefits RGGI brings to all Virginians.

John Bagwell, Executive Director: Virginia Clinicians for Climate Action (VCCA) was founded in 2017 in order to bring the health voice to climate change advocacy in the state of Virginia. On behalf of VCCA and our nearly 500 Virginia health professional members, we submit this statement in support of Virginia’s ongoing participation in the Regional Greenhouse Gas Initiative (RGGI). RGGI effectively protects the health of Virginia residents from climate change and air pollution. As such, VCCA strongly opposes efforts to remove Virginia from the program.

Rev. Dr. Faith Harris, Executive Director: RGGI is the most rapid pathway for Virginia to reduce its carbon emissions from energy production over the next decade because it incentivizes polluters to find alternative sources for energy production. I hope you agree that we want to encourage transitioning to renewables, like wind, as quickly as possible. Without the reductions from RGGI, we cannot meet our overall goal of 100% renewable or net zero carbon emissions by 2045.

Christopher Leyen, Policy Director: Comparing EPA data from 2020 to 2021, Virginia’s Virginia’s RGGI program slashed energy sector air pollution by 14% in its first year alone. What’s more, while Virginia is a relative newcomer to RGGI, in the decade-plus the program has been in operation, RGGI states have reduced climate-warming emissions reduced power plant carbon emissions by 50 percent, 90% faster than the rest of the country – while seeing 31% faster economic growth than non-RGGI states.

William “Skip” Stiles Jr., Executive Director: Wetlands Watch strongly opposes this proposal because neither the Air Pollution Control Board (“Air Board”) nor DEQ has the power to remove Virginia from the Emissions Reduction Program. The General Assembly mandated Virginia’s participation in the Regional Greenhouse Gas Initiative (“RGGI”). Therefore, the Air Board and DEQ cannot override this legislative mandate through the NOIRA regulatory process.

Ann Creasy, Acting Deputy Director: We don’t have to sacrifice the health of our planet to grow our economy. A dozen major businesses with operations and employees throughout Virginia and across the U.S. have submitted letters in support of Virginia’s entering RGGI, urging Virginia leaders to follow through on adopting regulations to reduce carbon pollution in the Commonwealth. RGGI has generated hundreds-of-millions in funds going towards lowering energy bills for low-income households while creating good, local jobs, and providing dedicated funding to localities to plan for and prevent recurrent flooding. RGGI reduces carbon emissions. RGGI benefits public health and produces major savings on health costs associated with impacts of air pollution to include asthma attacks, premature births, and missed days of school/work.