As a consulting forester, representing over 700 landowners on nearly 100,000 acres of timberland in Eastern Virginia and as a forest landowner myself, I urge DEQ to revise the regulation to clarify that it only regulates greenhouse gas (GHG) emissions from fossil fuel combustion, and that new and existing industrial facilities should be clearly exempt from any allowance obligations. Furthermore, the regulation should apply only to GHG emissions from fossil-fuel combustion and not to emissions from biomass combustion.

Since wood material is carbon neutral irrespective of whether other fuels are co-fired, DEQ should recognize the sustainable nature of burning wood.  Biomass from sustainably managed forests is a valuable, carbon neutral resource and fuel supply.

Please revise and clarify GHG emmission regulation that supports biomass energy as a sustainable and carbon neutral fuel source.  Thank you.