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  4:55 pm
Commenter: Christina Luman-Bailey, City Council of Hopewell, VA and Chair, GoGreen VA

Proposed Regulation and percentage threshold for biomass

I am concerned that the industry exemption barely passed;  although I agree that all major carbon emittors should be held accountable, it is typically the coal-burning utilities sector which is the biggest offender and has a monopoly on the customer market, whereas industry must face more competition and may need more flexibility re cost of production in order to compete in the private sector.  Also, the minimum threshold of 90% biomass in order to claim carbon-neutral seems unreasonable.  Basing the credit for carbon neutral on the percentage of biomass (whether it be 90% or 40%) makes for a more reasonable, scientifically-based formula and is fair.  I am glad to see the DEQ moving forward with air pollution controls, but I think that a more reasonable, scientifically-based proposal will be more accepted by all and therefore more successful.


CommentID: 65206