My name is Adam Wiliams and I work at International Paper Company as an Area Leader for the Franklin 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 recognize the carbon neutrality of biomass emissions and does not clearly exempt existing industrial boilers. Existing facilities like International Paper’s Franklin, Virginia mill rely on biomass residuals to power their 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. Livelihood of communtities like Franklin and many in Hampton Roads depend on indutries like ours and this regulation threatens these industries' viability and threatens the jobs they create.
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.
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
