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  4:12 pm
Commenter: International Paper


Good Day,

My name is Jim Yarborough and I live and work in Franklin, Virginia and have for the last 34 years.  I have worked for International Paper Company for all of those years.

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

Existing facilities like International Paper's Franklin, VA mill rely on biomass residuals to power our operations and any such regulation thatimpacts that use could be very costly and have adverse consequences on the mill's operations today and in the future.

The requlation 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 ans 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, it's Franklin, Virginia Mill to:

1. Clearly exempt new and and existing industrial boilers and

2. Ensure that biogenic carbon dioxide emissions be recognized as carbon neutral regardless of whether the biomass is co-fired with fossil fuels.



Jim Yarborough