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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4/9/18  2:17 pm
Commenter: Pulp & Paperworkers resource Council

Regulation for Emissions Trading

March 23, 2018



David K. Paylor, Director, Virginia Environmental Quality

Michael G. Dowd, Director, Air and Renewable Energy Division

Virginia Department of Environmental Quality

629 E. Main Street

Richmond, VA 23219



Dear Director Paylor and Director Dowd:


On behalf of the Pulp & Paperworkers’ Resource Council (PPRC), I appreciate the opportunity to comment on the Commonwealth of Virginia’s proposed “Regulation for Emissions Trading” for the CO2 Budget Trading Program.  


The PPRC is a non-profit grassroots organization made up of ground floor hourly union workers in the forest products industries. We come from across the United States. The PPRC is committed to educating our policy makers on issues of importance to the forest products industry and the impact policies have on our jobs and communities.


In Virginia, the forest products industry operates 46 manufacturing facilities and employs more than 27,000 individuals with an annual payroll of over $1.1 billion and produces $7.3 billion in product each year. The estimated state and local taxes paid by the Virginia forest products industry totals $155 million annually.


PPRC does not support Virginia joining RGGI because it will raise electric power prices and consequently cause Virginia-based businesses to become less competitive. However, if the state does join RGGI, we urge that DEQ maintain the exemption for industrial boilers and ensure that biogenic carbon dioxide emissions are considered carbon neutral.


Biogenic carbon dioxide emissions from forest-derived bioenergy categorically should be counted as making zero contribution to the build-up of greenhouse gases in the atmosphere where timberland carbon stocks are stable or increasing. Through the natural carbon cycle, growing forests sequester carbon as trees continually are replanted and grow through their lifecycles, even as some trees are being harvested. The most recent data from the U.S. Forest Service indicate that timberlands in Virginia, the U.S. South, and the entire U.S. have highly positive net growth vs. removal ratios.




David M. Wise


Pulp and Paperworkers’ Resource Council

National Steering Committee Chairman

Southeast Region Director

POB 100544

Florence, SC 29502-544


CommentID: 65197