Agencies | Governor
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 Ends 3/6/2019
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3/1/19  3:49 pm
Commenter: Paula Wood

Oppose VA RGGI Greenhouse Gas Reduction Regulation

My name is Paula Wood and I’m the Mill Manager at International Paper Company in Franklin, VA.  I’m writing to urge you to OPPOSE Virginia DEQ’s proposed regulation to join the Regional Greenhouse Gas Initiative.

The Franklin Mill was shutdown in 2009 due to a declining market for copy paper.  In 2012, International Paper was able to bring a small portion of the jobs back to the community after significant investment to repurpose the mill to produce Fluff Pulp.  This regulation is another threat to an already battered community.

RGGI doesn't recognize the carbon neutrality of biomass emissions and does not clearly exempt existing industrial boilers. Existing facilities like International Paper’s Franklin, Virginia mill rely on biomass residuals to power their operations and any such regulation that impacts that use could be costly and have adverse consequences on the mill’s operations today and in the future.The regulation should apply only to GHG emissions from fossil-fuel combustion and not to emissions from biomass combustion.  There is strong consensus that the use of biomass residuals and biowastes for energy has significant GHG reduction benefits and emissions and should not be subject to the regulation.

  •  I respectfully urge DEQ in order to avoid unintended consequences that would be of detriment to International Paper and more specifically, its Franklin, Virginia mill, to:
  • Clearly exempt new and existing industrial boilers; and

  • Ensure that biogenic carbon dioxide emissions be recognized as carbon neutral regardless of whether the biomass is co-fired with fossil fuels


Paula Wood