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  10:12 am
Commenter: Carolyn Mulligan, American Forest Management, Inc.

9VAC5-140, Regulation for Emissions Trading Program

I have worked over 25 years as a forestry consultant for American Forest Management (AFM).  AFM oversees forest management operations for landowners across the country, and we know that biomass from sustainably managed forests is a valuable, carbon neutral resource and fuel supply.   

I am responding to the re-proposed 9VAC5-140, “Regulation for Emissions Trading Program” for the CO2 Budget Trading Program, intended to facilitate Virginia’s entry into the Regional Greenhouse Gas Initiative.

I urge DEQ to revise the regulation to clarify that it only regulates greenhouse gas emissions from fossil fuel combustion, and that new and existing industrial facilities are exempt from any allowance obligations. The regulation should apply only to GHG emissions from fossil-fuel combustion and not to emissions from biomass combustion. 

In summary, please exempt new and existing industrial boilers and recognize biogenic carbon dioxide emissions as carbon neutral irrespective of whether other fuels are co-fired.

Thank you for your attention to this very important issue.