My name is Charro Gaulden and I work at International Paper Company as the Environmental Health and Safety Manager for the company’s Franklin, VA 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.

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 biowastes for energy has significant GHG reduction benefits and emissions and should not be subject to the regulation.