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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3/4/19  10:59 am
Commenter: Pulp and Paperworkers' Resource Council

Oppose the RGGI

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March 6, 2019



Ms. Karen G. Sabasteanski

Office of Regulatory Affairs, Virginia Department of Environmental Quality

P.O. Box 1105

Richmond, Virginia 23218


RE: Opposition to the Regulation for Emissions Trading


Dear Ms. Sabasteanski:


On behalf of the Pulp and Paper Resource Council (PPRC), a grassroots labor organization led by hourly employees advocating for the U.S. forest products industry that supports policies that encourage economic growth, abundant and sustainable fiber supply, and sensible science-based environmental policies – we are writing to oppose the Commonwealth of Virginia’s re-proposed “Regulation for Emissions Trading.”

Our comments request that the Regulation be revised to make clear that it only regulates greenhouse gas (GHG) emissions from fossil fuel combustion, and that new and existing industrial facilities are clearly exempt from any allowance obligations. 

The U.S. forest products industry is vitally important to our nation’s economy, employing approximately 950,000 people. We rank among the top 10 manufacturers in 45 states and represent four percent of the total U.S. manufacturing gross domestic product (GDP).

The WestRock Paper Mill in Covington is a significant economic driver for our communities, providing over 1100 jobs and supporting over $200M in local investment through supplier purchases, payroll, and taxes every year.  If care is not taken, the proposed regulations could have a serious and negative impact on the mill.  One of our chief concerns is the treatment of energy from biomass, which is critical to the mill’s operation.

We are opposed to the rule as it is currently drafted and encourage DEQ include in the rule a clear and specific exemption for CO2 emissions from non-fossil fuel sources, such as biomass. Additionally, we believe that the regulation should be amended to allow new industrial facilities to qualify for an exemption, as well as existing facilities, to allow for continued growth in our communities. 

Thank you for your consideration of these comments.


Matthew Hall

PPRC National Special Projects Coordinator, Covington VA  Mill

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