Dear Director Paylor and Members of the Air Pollution Control Board,

Climate disruption poses increasing threats to Virginians' public health, national security, environment, and economy. Communities from Appalachia to the coast are already experiencing climate change impacts, from drought stress to regular flooding. Virginia must respond now in order to mitigate the worst impacts on our citizens. 

I support setting the strongest possible standard to cut carbon emissions from Virginia power plants through participation in a carbon market. This is a critically important step toward reducing carbon pollution.

DEQ should adopt and implement a final rule that:

• Caps carbon pollution in the 2020 base year between 30 and 32 million tons. While the draft rule proposes 33 or 34 million tons as a base year cap, Virginia’s carbon emissions have been below 33 million tons each year since 2010. The new rule should set a cap that is more ambitious, yet still achievable.

• Covers carbon pollution from biomass facilities. All carbon pollution adds to climate disruption, regardless of what fuel is used.

• Makes explicit that carbon pollution reductions will continue in Virginia after 2030.

• Closely monitors for instances of disproportionate burdens borne by low-income and vulnerable communities.

Thank you for your efforts to protect Virginia citizens and our natural resources.

Sincerely,

Steven Urquhart