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PPRC Comments to Virginia DEQ2F

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 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.

We appreciate your consideration of these comments and look forward to continuing our work with the Commonwealth of Virginia on this very important issue. If you have any questions, please do not hesitate to contact me.

Sincerely,

David M. Wise
Pulp and Paperworkers’ Resource Council
National Steering Committee Chairman
Southeast Region Director
POB 100544
Florence, SC 29502-544
david.wise@westrock.com
(843) 269-0164

National Administrative Positions

  • Information Technology Director
    David Cothren, USW Local 13-1149
    Graphic Packaging International
    Queen City, TX 75572
    David.Cothren@graphicpkg.com
  • Internal Communication Director
    Lloyd Allen, USW Local 9-983
    Clearwater Paper Company
    Augusta, GA 30906
    James.Allen@clearwaterpaper.com
  • External Communication Director
    Austin Wise, USW Local 1879
    Smurfit Westrock
    Florence, SC 29505
    Awise88@me.com
  • Scheduling Director
    William Schwalbach, USW Local 2-20
    Ahlstrom
    Kaukauna, WI 54130
    Pulpandpaperworkers@gmail.com

National Special Projects Coordinators at Large

  • Vince Geiser, NSC Recording Secretary
    IBEW Local 464
    Smurfit WestRock Company
    Covington, VA 24426
    james.geiser@smurfitwestrock.com
  • Scott Goins, IAM Local Lodge 1098
    Georgia Pacific
    Palatka, FL 32177
    scott.goins@gapac.com
  • Matt Hall NSC Chairman IBEW Local 464 
    Smurfit WestRock Company
    Covington, VA 24426
    matt.hall@smurfitwestrock.com 
  • Jason Etheridge NSC Vice Chairman USW Local 9-0425
    Smurfit WestRock Company
    Roanoke Rapids, NC 27870
    jasonetheridge78@yahoo.com

Executive Team

  • Clay Duke, Executive Director
    clay.duke@suzanopackaging.com | Pine Bluff, AR
  • Matt Hall, Chairman
    matt.hall@smurfitwestrock.com | Covington, VA
  • Jason Etheridge, Vice Chairman
    jasonetheridge78@yahoo.com | Roanoke Rapids, NC

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