Support Cap & Trade for VA Power Plants


The Climate Action Alliance of the Valley joins Sierra Club/Virginia Chapter, Appalachian Voices, the Virginia League of Conservation Voters, Virginia Interfaith and Light, and the Chesapeake Climate Action Network among other organizations, in urging you to raise your voice in support of the proposed regulations to establish a carbon reduction program for the Commonwealth. There are several ways you can make sure your concerns are heard.

1.      You can attend the Virginia Department of Environmental Quality (DEQ) public hearing at 4411 Early Rd, Harrisonburg, on March 14, from 5 to 7 pm and make your comments in person.

2.      You can go online and offer written comments to DEQ by April 9 or

3.      You can express yourself—and inform your Facebook friends:

4.      You can sign a petition:

5.      You can write a letter to the editor (LTE).

What’s very important is that you speak up—and do so SOON. The Clean Power Plan is pretty much dead for the next several years. There will likely be little if any effort at the federal level any time soon to lower carbon emissions and there will no doubt be federal actions to increase carbon emissions.  The VA General Assembly (GA) has declined to enact carbon reduction legislation that has been proposed during the last three sessions (including 2018). DEQ’s regulations represent the only viable avenue now available for Virginia to act.

Former Governor McAuliffe issued Executive Directive 11 ( ) in May 2017 directing DEQ to develop regulations that they issued in draft, for public comment, in Jan 2018 ( In brief, “ED11, or the VA Carbon Reduction Plan, is designed to reduce carbon dioxide (CO2) emissions from fossil fuel-burning power plants by 30% by the year 2030, and give rise to a generation of clean energy jobs. ED11’s approach is the same one that is being successfully used in 9 other states that are a part of the Regional Greenhouse Gas Initiative (RGGI).” [Sierra Club VA Chapter] The draft regulations provide a way “to ensure that Virginia’s regulation is ‘trading-ready’ to allow for the use of market-based mechanisms and the trading of carbon allowances through a multi-state trading program.” [Appalachian Voices, Lena Lewis]

To help you offer your comments, we’ve provided talking points, background information, a list of the areas DEQ wants addressed, and sample LTEs below. Be sure to include your own personal statement as to why you believe these regulations are needed–i.e., why and how reduced carbon emissions will benefit you and your family.


– Joy Loving
Chair, Legislative and Elections Committee
Climate Action Alliance of the Valley

Background information

Appalachian Voices Front Porch Blog: Virginia inches closer to a carbon market
By Lena Lewis, student in the Master of Public Policy program at the Batten School for Leadership and Public Policy, University of Virginia, July 2017

The Daily News-Record‘s Nolan Stout covers the issue in this March 7, 2018, article: Carbon Emissions Hearing On Tap

This Augusta Free Press article from March 7, 2018, gives more viewpoints: DEQ public hearings to cut carbon in Virginia

Environmental journalist Chris Bolgiano lays out the case for why forest carbon offsets should be part of the VA cap-and-trade plan in the March-April issue of Virginia Wildlife Magazine: Seeing the Forest for the Carbon

Concerns that cap-and-trade plans promote fracking are described here: Don’t Let RGGI Frack Us Over

Carbon Cap-and-Trade Talking Points by Lena Lewis

Carbon Cap-and-Trade creates a financial incentive to reduce carbon dioxide pollution. Businesses that reduce their carbon emissions can earn revenue, while polluters have to pay.

How Cap-and-Trade Works

1. CAP: The Department of Environmental Quality (DEQ) sets a cap, or limit, on the total carbon emissions allowed by power plants.

2. ALLOWANCES: The DEQ creates allowances to emit carbon. Each allowance permits its owner to emit one ton of carbon dioxide. Then that allowance is used up.

3. ALLOCATION/DISTRIBUTION: The DEQ distributes allowances. In most cap-and- trade programs, this is done through an auction. The price determined by the auction is the “clearing price” which all bidders pay for their allowances.

4. TRADE: Allowance holders can buy and sell allowances. This creates an incentive to lower carbon emissions. If a power plant can reduce its carbon emissions, it can sell its allowances to increase revenue. If a power plant emits a lot of carbon, it loses profit because it has to buy more allowances.

5. LOWER THE CAP: Each year, the DEQ lowers the amount of emissions allowed and offers fewer allowances. This raises the price of allowances, and creates even more incentive for power plants to reduce their carbon emissions.

Virginia could reduce carbon emissions from our power plants by 30% over 10 years.

The nine member states of the Regional Greenhouse Gas Initiative (RGGI) cap-and-trade program have set a goal of reducing their power plant emissions by 30% of 2020 levels by the year 2030. If Virginia links with RGGI, we would lower our cap at the same rate as RGGI states.

RGGI states have already reduced their power plant carbon emissions by 30% since the program began in 2008. They have achieved this goal while their economy has increased faster than the rest of the country (25% economic growth in RGGI states compared to 21% in other states). RGGI states have also lowered their average electricity rates by 3.4% while the rest of the country’s electricity bills have increased by an average of 7.2%.1

Carbon Cap-and-Trade levels the playing field for zero-carbon and low-carbon energy sources.

Fossil fuels have so far had an unfair advantage in the competition with zero-carbon energy sources: they have not had to pay for the damages caused by their carbon pollution. Putting a price on carbon levels the playing field for solar, wind, and other zero-carbon energy sources.

Carbon Cap-and-Trade is simple and reduces the need for government intervention.

Carbon Cap-and-Trade works to lower carbon emissions without the need for further government regulation of carbon emitted by power plants. With a cap-and-trade program in place, we do not need a Renewable Portfolio Standard (RPS) to mandate that a certain percent of electricity be produced by renewable sources. An RPS would be redundant, because the incentive to reduce carbon is already created through cap-and trade.

Carbon Cap-and-Trade works to lower carbon emissions without mandating how revenue from allowances sales is spent. Though it is tempting to demand that revenue be spent on investment in zero-carbon energy, such mandates are not necessary to reduce carbon. Companies already have the incentive to invest in more zero-carbon energy because doing so makes good business sense.

Carbon Cap-and-Trade is not a magic solution for everything.

A cap on carbon emissions from power plants does nothing to limit carbon emissions from transportation and other sources. We need to work toward comprehensive limits on all sources of carbon dioxide and other greenhouse gases.

Reducing carbon emissions has the additional benefit of reducing other types of pollution and environmental destruction caused by the fossil fuel industry. However, a cap on carbon may not be sufficient to limit those negative impacts. A cap on carbon does not excuse the power sector from limiting other pollutants and environmental degradation. Communities near power plants will not be harmed by carbon cap-and-trade, and will likely enjoy cleaner air as a result. Yet we need to remain steadfast in our insistence that these communities and others affected by fossil fuel extraction have the right to clean air and safe neighborhoods.

Allowances should be distributed based on energy output, not historic carbon emissions.

Creating carbon allowances turns something that was once free into something that can be sold. Carbon allowances become a valuable commodity and an additional source of revenue. If allowances are given to power plants based on historic carbon emissions, it will still achieve the goal of carbon emissions. But it will not provide a new source of income to zero-carbon energy generators. Instead, allowances should be distributed based on updated energy output. This method gives some allowances to zero-carbon energy sources, who can sell the allowances as a new source of revenue.
1 Source: Acadia Center. Regional Greenhouse Gas Initiative Status Report. July, 2016

Written by Lena Lewis, who is researching carbon market policy while earning her master’s degree at the Frank Batten School for Leadership and Public Policy at the University of Virginia. Lena [at]

Sample Comment by Becca Summers, Virginia League of Conservation Voters

Background: Virginia is working on a plan to cut carbon pollution from power plants and invest in clean energy – the Clean Energy Virginia Initiative, commonly referred to as Executive Directive 11. Six public hearings are being held across the state, giving us an opportunity to make our voices heard for a clean energy future in Virginia.

We need to pack the house at these hearings to counter the influence of Virginia’s utilities, and show overwhelming public support for Virginia’s plan to cut carbon pollution from power-plants.

Suggested Language: ‘I’m writing today to voice my support of a regulation in Virginia that cuts carbon pollution from power plants and allows us to trade carbon allowances with other states.

With no help coming from the federal level in addressing climate change, it’s up to states like Virginia to act. By cutting carbon emissions in Virginia, we have the opportunity to protect public health and safety while also creating jobs in the carbon-neutral renewable energy and energy efficiency sectors.

And because we’re joining up with a coalition of other states with carbon caps, action we take here in Virginia is greater than the sum of its parts.

I urge you to proceed with a strong regulation that shows Virginia is a leader in addressing climate change and takes its responsibility seriously.’

Burning fossil fuels has left a toxic legacy of pollution across Virginia’s land, air and water. Reducing carbon emissions from power plants and incentivizing renewable energy will lower electric bills, create jobs, improve air quality, improve public health and protect and preserve Virginia’s environment.

Sierra Club Guidance on What DEQ and VA Air Quality Control Board Want from Public Comments

Whether the initial Virginia CO2 Budget Trading Program base budget for 2020 should be 33 million tons or 34 million tons, and declining accordingly by 3% per year.
● Whether any fossil fuel power generating unit owned by an individual facility and located at that individual facility that generates electricity and heat from fossil fuel for the primary use of operation of the facility should be exempt from the requirements of the regulation.
● The potential for DEQ to directly auction carbon allowances in addition to the proposed consignment auction format.
● The costs and benefits of the proposal, the potential impacts of this regulatory proposal and any impacts of the regulation on farm and forest land preservation.
Impacts on small businesses as defined in § 2.2-4007.1 of the Code of Virginia. Information may include 1) projected reporting, recordkeeping and other administrative costs, 2) probable effect of the regulation on affected small businesses, and 3) description of less intrusive or costly alternative methods of achieving the purpose of the regulation.

Sample Letter to the Editor and LTE Talking Points
In the Daily Press, February 12, 2018

Follow Northam’s lead

As a native Virginian and former elected official who cares deeply about the impacts of global warming on our beautiful state, it was refreshing to see Gov. Ralph Northam, tweet about climate change during his first days in office:

“As a native of the Eastern Shore, a scientist, and a resident of Hampton Roads, I can tell you personally that, no matter what politicians in Washington say, climate change is real. Sea levels are rising. It affects us every day.”

According to the U.S. Geological Survey, the southern Chesapeake Bay region is sinking, making it one of the most vulnerable in the nation to the rising seas. Gov. Northam clearly understands these problems.

He and his predecessor, Gov. Terry McAuliffe, proposed a legislative agenda that would enable Virginia to join a multi-state effort which has cut global warming pollution in half since 2005. This bipartisan partnership, led by five Republican governors and four Democratic governors, has cleaned up the air, invested billions in the clean energy revolution, and lowered utility bills throughout the Northeast and the Mid-Atlantic regions.

Unfortunately, there are some lawmakers in the General Assembly who are attempting to derail climate process by thwarting the governor’s plans to link Virginia with this successful climate program. We need our elected leaders to follow Gov. Northam’s actions to cut the pollution that is putting our communities at risk.

Andrea McGimsey
Global Warming Director
Environment Virginia

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