I support setting the strongest possible standard to cut Virginia emissions from power plants through participation in a carbon market. This is a critically important step toward carbon pollution reductions. I support the revised, lower base year emission cap and appreciate that the Department of Environmental Quality included environmental justice as a consideration with regards to program evaluation and monitoring. However, I have serious concerns about the biomass exemption and I would like to see specific recommendations for how environmental justice will be considered in program evaluation and monitoring. 

  I request that DEQ use its authority to adopt and implement a final standard that:

1. Retains the currently-proposed base year emission cap of 28 million tons

2. Fully covers carbon pollution from biomass facilities, which can be more climate polluting than fossil fuel power plants. Virginia’s first ever plan to reduce carbon pollution from power plants shouldn’t be weakened by special interests! Exempting biomass makes Virginia’s carbon program less effective and gives monopoly utilities like Dominion even more of an unfair economic advantage. 

3. More fully articulates plans for environmental justice considerations for program monitoring and evaluation, and requires DEQ to include mitigation measures for any adverse program impacts on vulnerable, environmental justice and under served communities that are identified through the Department’s evaluation of the program.

4. More fully articulates the Department’s plan for increasing participation of environmental justice communities in the review of impacts of the program on those communities. This plan should be consistent with the National Environmental Justice Advisory Council’s Model Guidelines for Public Participation.

Best,

Nick

P.S. NO PIPELINE

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