I oppose RGGI. The DEQ should clearly exempt new and existing industrial boilers. And biogenic carbon dioxide emissions should be recognized as carbon neutral irrespective of whether the biomass is co-fired with fossil fuels.

Paper and wood products mills rely on biomass residuals from the manufacturing process for powering their operations or to sell electricity onto the grid. Regulating utilities as proposed would set an adverse precedent and potentially call into question the status of biogenic carbon dioxide emissions from paper and wood product facilities.

There is strong consensus that the use of biomass residuals and biowastes for energy has significant GHG reduction benefits and emissions from the use of residuals or biowastes for energy should not be subject to the regulation.

In addition, biogenic carbon dioxide emissions from other forest-derived bioenergy categorically should be counted as making zero contribution to the build-up of GHGs in the atmosphere where forest carbon stocks are stable or increasing, as they are in Virginia.

The carbon profile of biomass is not altered in any way simply because it is co-fired with other fuels.

Existing industry facilities would face severe economic impacts if they are regulated as utilities and regulating new industrial facilities would be a barrier to creating new high-paying jobs in the Commonwealth.