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 Ended on 4/9/2018
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4/5/18  2:26 pm
Commenter: Chris Bolgiano, Environmental Writer

Include methane CO2 equivalents & biomass; revenue-producing auctions; add forest carbon offsets.

I support DEQ’s cap and trade proposal as at least a first step to addressing climate change.  However, it is so limited in scope that Gov. Northam should issue a new Exec Order and expand state authority to address the following 4 major shortcomings:

1.Methane:  The irony of the state facilitating fracked gas pipelines while promoting a cap and trade program for CO2 from fossil-fuel burning utilities is not lost on us. To avoid subverting the premise of addressing climate change, CO2 equivalents should be calculated for Net Emissions Impact of methane by fracked gas production and transport, based on metrics given in easily available scientific analyses. These methane-CO2 equivalents must then be included in the CO2 budgets and allowances, because utilities burning coal or oil will inevitably move to fracked gas to claim lower CO2 emissions.  A program based only on CO2 will simply stimulate fracking,  gas transport, and justification of the pipelines.  Emissions of methane are known to be a greater climate danger than CO2.  On May 12, 2017, as cited in: Background: AG opinion, State Air Pollution Control Board, “Carbon Dioxide Trading Program (Rev. C17),” p. 7, November 16, 2017, the Attorney General ruled that "The Board has the authority to establish a statewide cap on GHG emissions.”  GHG include methane.  As well-known climate activist and author Bill McKibben states in Yale University’s March, 2018 e360 publication, moving from coal and oil to gas “is as if we kicked our Oxycontin habit by taking up heroin instead.”


  1. Xiao-BingZhang and Jing Zu. “Optimal policies for climate change: A joint consideration of CO2 and methane.” Applied Energy, Vol. 211, 1. February 2018, Pages 1021-1029.  “Climate change mitigation requires the reduction of greenhouse gas (GHG) emissions. The majority of the discussions on climate change policy focus exclusively on the reduction of carbon dioxide (CO2) emissions but ignore other important GHGs such as methane. This paper investigates the optimal choice of policy instruments under the joint consideration of CO2 and methane in a dynamic setting with asymmetric information and pollutant correlations. We develop a dynamic programming model with two state variables and calibrate it to the global warming case. The results show that it is optimal to levy tax on both CO2 and methane. A mixed strategy that implements a tax on CO2 and a quota on methane is the second-ranked choice.


  1. Robert W. Howarth, Renee Santoro, & Anthony Ingraffea.  “Methane and the greenhouse-gas footprint of natural gas from shale formations.” Climatic Change  June 2011, 106:679. “Natural gas is composed largely of methane, and 3.6% to 7.9% of the methane from shale-gas production escapes to the atmosphere in venting and leaks over the life-time of a well. These methane emissions are at least 30% more than and perhaps more than twice as great as those from conventional gas. The higher emissions from shale gas occur at the time wells are hydraulically fractured—as methane escapes from flow-back return fluids—and during drill out following the fracturing. Methane is a powerful greenhouse gas, with a global warming potential that is far greater than that of carbon dioxide, particularly over the time horizon of the first few decades following emission. Methane contributes substantially to the greenhouse gas footprint of shale gas on shorter time scales, dominating it on a 20-year time horizon. The footprint for shale gas is greater than that for conventional gas or oil when viewed on any time horizon, but particularly so over 20 years. Compared to coal, the footprint of shale gas is at least 20% greater and perhaps more than twice as great on the 20-year horizon and is comparable when compared over 100 years.”
  1. Anna M. Robertson, et al.  “Variation in Methane Emission Rates from Well Pads in Four Oil and Gas Basins with Contrasting Production Volumes and Compositions. Environ. Sci. Technol.201751 (15), pp 8832–8840. 

2.Auctions of CO2 allowances: Fossil fuel utilities should pay Virginia for the privilege of damaging our environment and Virginia should apply those revenues toward climate solutions, as RGGI does. But according to an email from Karen Sabasteanski of DEQ’s Office of Regulatory Affairs (  “Unlike a conventional auction, such as the one RGGI manages, a consignment auction is revenue neutral, and will enable Virginia to link to RGGI while staying within the bounds of Virginia law.”  In addition she quotes a DEQ statement:  "Consignment auction" or "auction" means the CO2 auction conducted on a quarterly basis by RGGI, Inc., in which CO2 budget sources and DMME are allocated a share of allowances by the department that CO2 budget sources and the holder of a public contract with DMME consign into the auction, and auction revenue is returned to CO2 budget sources and the holder of a public contract with DMME in accordance with procedures established by the department.”    

If VA state law prohibits the return of auction revenues to the state, or if the General Assembly must approve revenue-positive auctions, then DEQ should outline the appropriate steps to overcome these obstacles and Gov. Northam should take them, because RGGI states gain billions of dollars from auctions which are then used for climate solutions.  From ):  “States sell nearly all emission allowances through auctions and invest proceeds in energy efficiency, renewable energy, and other consumer benefit programs. These programs are spurring innovation in the clean energy economy and creating green jobs in the RGGI states.”   RGGI’s March 14, 2018 auction: “CO2 Allowances Sold for $3.79 in 39th RGGI Auction; $51.4 Million Raised for Reinvestment in First Auction of 2018 (at  Total Cumulative Proceeds: $2,887,234,068.02 (

3.Forest Sequestration:  The single most powerful natural climate solution, as stated by hundreds of scientists in dozens of peer-reviewed journals, is forest conservation. Because trees take in CO2 during photosynthesis steadily for as long as they live, which for most of the hardwoods that constitute the majority of Virginia’s forests is at least four centuries, trees are the best technology yet discovered for carbon capture and storage.  According to the 2009 book, Old Growth Forests:  Function, Fate, and Value (Wirth, C., et al, eds.  Berlin, Heidelberg: Springer), “Old-growth forests remain carbon sinks and exhibit the same carbon sink strength as younger developmental stages… [and] generally lock up more carbon that any other forest stage or alternative ecosystem.”   Yet this proposal does not include forest carbon offset credits, which RGGI allows up to 3% of CO2 emissions, and the mandatory California market allows up to 6%.  Given that 62% of Virginia’s land base is in forest, and most of that acreage is owned by more than 400,000 private individuals and families, this incentive toward sustainable carbon forestry would benefit all Virginians not only with climate change mitigation but also by long-term, verified protection of water and air quality.  To omit forest carbon offsets from this proposal, and thereby to miss the opportunity to encourage and support retaining existing forests for the carbon they have already locked up and the significant future amounts they would continue to sequester under carbon forestry management, which does not preclude harvests, would be a massive and fundamental strategic mistake if reduction of CO2 is truly the purpose.

4. Biomass burning.  Furthermore, counting biomass burning as carbon neutral is another huge mistake and fundamental strategic error.  In fact, burning biomass is worse that fossil fuels in several ways.  In a letter last November to Gov. Cooper of NC concerning the rapid increase of biomass burning, more than 100 prominent scientists stated:
       “Biomass plants emit more carbon dioxide emissions per unit of electricity than coal or gas plants. In addition, it releases harmful particulate matter and smog precursors.… Removing the carbon dioxide emitted from burning trees for electricity requires waiting decades to a century for trees to regrow. Forests in the U.S. South are logged at a rate four times that of South American rainforests. A 2016 study showed that logging reduced the potential of the U.S. forest carbon sink by approximately 35 percent.  Increasing carbon sinks by way of forest conservation and restoration plays a significant role in emissions reduction.”  

Scientists from MIT, Univ. of Massachusetts, and the nonprofit Climate Interactive released a report on Jan. 16, 2018 titled “Displacing coal with wood for power generation will worsen climate change.”  

And on Feb. 21, 2018, the journal Environmental Research Letters, vol. 13, no. 3, published a paper titled “Not carbon neutral:  Assessing the net emissions impact of residues burned for bioenergy,”

While logging residues would give off CO2 during decay if left on site, removing them for burning depletes soil by removing nutrients, thereby degrading forest productivity for the long term including the regrowth of very trees supposed to balance emissions from burning.  Plus, there is solid documentation that whole trees are being harvested in the Southeast for pellets for export, an industry that has degraded forests in the Southeast and is now moving into Virginia to destroy our single best carbon sink, namely our forests. There is no mechanism to verify or enforce that trees do regrow on site, and in fact cutover forests are ripe for subdivisions and other development.  Even if trees do regrow on site, decades and even centuries are required for such forests to capture and store as much CO2 as was emitted by burning, and during that time if biomass burning continues, CO2 emissions will increase because trees can’t grow fast enough to offset them. This proposal covers only one facility that co-fires coal and biomass but at a minimum should also include the five others that burn only biomass, and ideally would not allow burning biomass at all because of the obvious contradiction with the value of forest conservation.  Burning trees to reduce atmospheric CO2 is like burning your sleeping bag to stay warm for a night. 


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