|Action||Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)|
|Comment Period||Ends 4/9/2018|
Office of Regulatory Affairs
Department of Environmental Quality
PO Box 1105
Richmond, VA 23218
Re: Regulation for Emissions Trading, CO2 Budget Trading Program, Part VII of 9VAC5-140
Dear Ms. Sabasteanski,
The following constitute the preliminary comments of Wild Virginia on proposed Regulation for Emissions Trading, CO2 Budget Trading Program, Part VII of 9VAC5-140.
Article 1 of the proposed regulation states that the trading program is “designed to reduce anthropogenic emissions of CO2.” However, if the rule applies only to “fossil fuels” and not to other significant carbon emitting generation stations in the Commonwealth, it cannot hope to achieve its stated goal.
According to the EPA, in 2016, total CO2 emissions from the burning of woody biomass in the US electric power sector was 22,900,000 metric tons. 
Currently, the proposed regulation as written does not apply to emissions of CO2 from biomass fired electric generating facilities or municipal waste burning facilities and applies only to fossil fuels. The program would not cover carbon emissions from wood-burning — “biomass” — power plants, allowing Virginia’s several wood-burners to continue polluting without regulation and rewarding coal-fired power plants that switch to burning wood from forests.
Science shows that burning trees and wood to produce electricity actually increases carbon dioxide and particulate emissions compared with fossil fuels contributing adding more CO2 to the atmosphere.  Besides undermining efforts to expand clean, renewable and low-carbon energy sources, such as solar and wind, burning forests for energy destroys intact forest ecosystems which are one of our best defenses against climate change.
Adopting these regulations as is could encourage more biomass generators to be implemented in the Commonwealth, through creation of new facilities or conversion of old ones. Already their impact is extremely significant.
Westrock operates the world’s largest solid bleached sulfate board paper mill on the banks of the Jackson River in Covington, VA. It is powered by their biomass boiler and a 75-megawatt steam turbine generator which are major sources of carbon emissions. In 2016, the Westrock facility emitted 2,020,927 metric tons of carbon dioxide. 
NOVEC’s South Boston plant in Halifax county generates 50 MW of energy, sourcing wood and whole trees from a 75-mile radius while claiming that their energy is “carbon neutral.”
The 585 MW Virginia City Hybrid Energy Center in Wise County co-fires coal with 20% wood. It is one of the Commonwealth’s largest sources of atmospheric CO2, with 3,101,460 metric tons of CO2 emitted in 2016. 
Dominion’s 83 MW Pittsylvania Power Station, in Hurt, Virginia, unloads an estimated 3,300 tons of wood daily which translates to about 150 truckloads of carbon rich fuel.
Dominion’s Altavista biomass incinerator turns up to 100 tractor-trailers of wood pellets, chips, logging slash/tops, or whole trees into 51 megawatts of energy, 24 hours a day, 7 days a week. In 2015, the Altavista facility was responsible for releasing 393,183 metric tons of CO2 into the atmosphere. 
Dominion Energy has received regional renewable-energy and federal incentives for bioenergy by converting three nearly mothballed coal-fired power plants to burn wood.  In 2016, Dominion’s conversion of two “part time” coalburners into full-time wood burners in Hopewell and Southhampton has more than doubled the carbon emissions from those two electrical generating facilities. In 2016, these facilities together emitted a total of 885,063 metric tons of carbon dioxide. 
Wood-burning power plants are not climate-friendly, pumping about 50% more carbon pollution per megawatt-hour into the atmosphere than coal plant. Combined, Virginia’s wood-pellet manufacturing and wood-burning power plants send more than 5 million tons of carbon dioxide mostly from forest wood straight into the atmosphere each year.
Power-plant carbon pollution warms the climate just as effectively whether it comes from burning trees or fossil fuels, which highlights the critical fallacy of treating biomass power plants as “carbon-neutral.”
Virginia’s carbon-trading plan isn’t unique in ignoring emissions from wood-burning plants. The problem also exists with California’s cap-and-trade plan, the Northeastern and Mid-Atlantic states’ Regional Greenhouse Gas Initiative (in which Virginia may participate) and the European Union trading program.
The E.U. demonstrates clearly what can happen when wood-burning power plants are counted as having zero carbon emissions.
Much of the emissions “reductions” claimed by the E.U. and United Kingdom come from converting coal plants to burn wood pellets imported from the United States and Canada, then assuming the emissions will be offset by future tree growth. As a direct result of this fallacy, millions of tons of North American trees are harvested, pelletized and shipped overseas as fuel each year. The pellet industry, built entirely on the “carbon-neutral” fallacy, is responsible for logging tens of thousands of forest acres throughout the South each year, including Virginia. 
Burning of municipal waste is also a large emitter of atmospheric carbon. For example, the Hampton/NASA Steam Plant in Hampton released 24,653 metric tons of carbon in 2016. 
Regulations could potentially reduce greenhouse-gas emissions, but they will only work best if all major emitting sources are covered
The Commonwealth cannot afford a dishonest carbon accounting program that allows for increased carbon pollution that is not included in this proposal. We request that these regulations include carbon accounting for all large scale industrial emitters of atmospheric carbon, including biomass and solid waste burning energy producing facilities.
Thank you for the opportunity to comment.
P.O. Box 1065
Charlottesville, VA. 22902
 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2016, U S Environmental Protection Agency, February 6, 2018.
 Not carbon neutral: Assessing the net emissions impact of residues burned for bioenergy, Mary S. Booth, Environmental Research Letters, January 25, 2018.
 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015, www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2015.
 2016 Greenhouse Gas Emissions from Large Facilities, United States Environmental Protection Agency, https://ghgdata.epa.gov/ghgp/main.do#/facility/.
 Trees, Trash, and Toxics: How Biomass Energy Has Become the New Coal, Mary S. Booth, PhD, Partnership for Policy Integrity, April 2, 2014
 Sustaining Our Defense Southern Forests, Carbon & the Fight Against Global Climate Change, Dogwood Alliance, www.dogwoodalliance.org/wp-content/uploads/2012/08/SustainingOurDefense.pdf.
 EPA, ibid.