Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
Board
Air Pollution Control Board
chapter
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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3/4/19  9:12 am
Commenter: Tim Lass, International Paper

Opposed to RGGI Regulation as Drafted
 

As part of the Commonwealth of Virginia’s plan to join the Regional Greenhouse Gas Initiative (RGGI), a “cap and trade” program to reduce greenhouse gas emissions (GHG) from fossil fuel fired utilities, the Virginia Department of Environmental Quality (DEQ) is proposing a draft regulation that directly regulates International Paper’s manufacturing process of using biomass residuals to generate the energy needed to make its forest by-products at the Franklin, VA Mill.  The proposed rule would negatively impact the Franklin Mill.

While the regulation is intended to reduce GHG emissions from fossil fuel-fired utilities, the way it is drafted would also apply to biomass-fueled utilities that co-fire biomass with more than 5% fossil fuel because the regulation does not recognize biomass-based emissions from facilities that co-fire as “carbon neutral”. Carbon neutrality means that the biomass-based emissions should be counted as making zero contribution to the build-up of GHGs in the atmosphere. Therefore, the regulation would erroneously regulate existing and new industrial boilers (in companies like International Paper) that burn carbon neutral biomass.  

For the Franklin Mill to avoid being unfairly regulated, the regulation should clarify that biomass-based carbon dioxide emissions from such facilities be treated as carbon neutral and that all existing and new industrial boilers be clearly made exempt from this regulation.  The Virginia Department of Environmental Quality should clearly exempt existing and new industrial boilers from its final regulation; and (2) recognize biogenic carbon dioxide emissions as “carbon neutral” whether or not biomass is co-fired with fossil fuels.

Successful industry is one key to Virginia's future economic wealth, and opposition to this regulation is key to keeping Virginia's industries viable and successful.