On behalf of the nearly 1,100 employees of WestRock’s Covington, Virginia paper mill, I appreciate the opportunity to provide comments to the Department of Environmental Quality and the Air Pollution Board regarding the Commonwealth of Virginia’s proposed “Regulation for Emissions Trading.”

In addition to the jobs the mill provides, and the hundreds more it supports, the mill contributes over $270,000,000 to Virginia’s economy through local purchases, and roughly $11,000,000 in property and sales tax payments every year. The products we make at Covington are exported around the world, primarily through the Port of Virginia. Papermaking is an energy-intensive process, and the mill produces a significant portion of its own power, primarily through the use of renewable biomass.

We believe the proposed regulations should be amended to treat all biomass as carbon-neutral so long as carbon stocks are stable or increasing. The use of biomass is recognized as carbon-neutral by well-supported science, regardless of whether or not it is co-fired with a fossil fuel source. The failure to recognize our primary fuel source as carbon neutral would deviate from the practice of other states that participate in the Regional Greenhouse Gas Initiative, as well as widely accepted international carbon accounting protocols, and could have negative long-term consequences.

The Regulation consistently has been aimed at reducing GHG emissions from only “fossil fuel” combustion like all other RGGII states.  We recommend that regardless of how “fossil-fuel fired” is defined, and whether a unit co-fires biomass with fossil fuel, the Regulation should be explicit in that allowances are only required for emissions from the combustion of fossil fuel and that none are required for emissions from combustion of biomass fuel. This change will provide necessary clarity and prevent unintended consequences that might result from a misinterpretation.

In light of the competitive disadvantage that Virginia industrial facilities would face if they were subject to the Regulation, it should clearly exempt those facilities from the applicability requirements. Our facilities are subject to Clean Air Act (CAA) and other federal and state regulatory programs which impose stringent standards and permitting requirements.  Those costly investments have dramatically reduced emissions and we often exceed the standard requirements.

While the Regulation includes an exemption for certain existing industrial facilities, it only applies to units in service as of 2019. That limitation should be removed, as there is no reason that new industrial facilities in Virginia should subject to the adverse economic impact of having to obtain allowances for their emissions. Again, this would put those facilities at a serious competitive disadvantage and will make it much more difficult to attract new investments to the Commonwealth.

If the limitation is retained, the Regulation should be clear that any modifications or replacements of machinery and equipment do not cause the facility to lose the exemption.

In summary, we request that the Regulation apply only to GHG emissions from fossil-fuel combustion, and that new and existing units at industrial facilities be clearly exempt from the Regulation.

Thank you for your consideration.