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.
David M. Wise
Pulp and Paperworkers’ Resource Council
National Steering Committee Chairman
Southeast Region Director
Florence, SC 29502-544