My name is Maurice Savage and I work at International Paper Company as the Fluff Machine Operations Maintenance Coordinator for the company’s Franklin, Virginia Mill.

I am writing to urge you to OPPOSE Virginia DEQ’s proposed regulation to join the Regional Greenhouse Gas Initiative (RGGI) because it does not clearly recognize the carbon neutrality of biomass emissions and does not clearly exempt existing industrial boilers.

Modifying this legislation would remedy the strong opposition from people at our mill and other industry partners.

Existing facilities like International Paper’s Franklin, Virginia mill rely on biomass residuals to power our 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.

I rely on this mill for my source of income, and I am proud that we make a sustainable product out of a renewable resource with a significant portion of our energy usage sourced from biomass combustion.

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 bio-wastes 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