I am writing to provide comments in opposition to the Department of Environmental Quality
(DEQs) and the Air Pollution Board regarding the Commonwealth of Virginia's re-proposed
"Regulation for Emissions Trading" for the CO2 Budget Trading Program as it is currently drafted.

I work at the WestRock Paper Mill in Covington, which has been in operation for over 100 years. The Mill is the economic backbone of our community, supporting over 1000 jobs and injecting hundreds of millions of dollars a year into our local economy. I am concerned that the proposed regulations, and specifically the treatment of biomass, could have a serious and negative impact on the mill.

DEQ has said that the intent of the rule is to focus on fossil fuels, but as written, it would apply to biomass (and other non-fossil fuel sources) when they are cofired with fossil fuels. Biomass is a carbon-neutral fuel source, and it should not be included in a rule designed to deal with fossil fuels. With that in mind, the rule should be amended to specifically exclude non-fossil fuel emissions.

Additionally, the exemption for industrial facilities should not be restricted to existing facilities. If the restriction remains, the rule should have language that clearly allows for exempted facilities to conduct maintenance and upgrades without losing their exemption.

I appreciate the opportunity to comment.