Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
Board
Air Pollution Control Board
chapter
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 4/9/2018
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3/11/18  10:45 pm
Commenter: Gianluigi Ciovati

Support for the proposed regulation
 

I fully support the adoption of such regulation, which allows Virginia to join the RGGI. I would encourage the DEQ to adopt the most stringent base budget of 33 million ton. I would further request DEQ to apply the requirements from this regulation to any and all fossil fuel power generating units. I would also request DEQ to include biomass into the fossil fuel category as recent expansion of such power generating units highlighted the issues of the very long timeframe required to capture the emitted CO2 by re-forestation and that, in order to meet increasing demand, not all the material used to make the fuel (wood pellets) comes from waste but from an increasing fraction is coming from tree logging (https://e360.yale.edu/features/wood_pellets_green_energy_or_new_source_of_co2_emissions).
I would like further to comment on the adoption of the proposed regulation resulting in a greater economic benefit than cost: energy efficiency is the lowest cost resource to reduce CO2 pollution while meeting energy demand. Dominion Energy ranks 50th in efficiency efforts among the 51 largest electric utilities in the nation. Strong energy efficiency policies would result in close to 40,000 new job in this sector by 2030 (http://vaeec.org/wp-content/uploads/2017/05/VAEEC-2017-Report-FINAL.pdf). Several more tens of thousands of jobs are predicted to be created by further increase in true renewable energy sources such as wind and solar, which the DEQ regulation being discussed would help stimulate.
As the disruptive effects of climate change on human life and civilization are becoming more and more evident and the greenhouse effect of CO2 has been know since the end of the 19th century (https://history.aip.org/climate/co2.htm), the risk and the cost of inaction on reducing CO2 emission is too high and the proposed DEQ regulation is a positive first step in the right direction.