Agencies | Governor
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 Ends 3/6/2019
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3/6/19  6:37 pm
Commenter: Brian Becker, The Center for Natural Capital

Comments regarding 9 VAC 5-140 Regulations of Emission Trading Programs

I strongly urge DEQ to recognize the biogenic carbon dioxide emissions from biomass fuels as carbon neutral (while the associated emissions from harvesting, transportation and processing should legitimately be counted).  Energy markets for biomass fuels are a necessary and important component of a sustainably managed forests system.  Energy markets create value for what would otherwise be low- or no-value wood derived from forest harvest operations and sustainable forest management.  Without energy markets, the biomass (e.g. tree tops, branches, poorly formed and damaged trees, invasive species and other wood that has no other market) would be left in the woods, decaying to methane or contributing to wildfires, generating greenhouse gas emissions with no societal benefit.  Without energy markets, management of mill residues (e.g. saw dust, chips and bark) become a waste disposal problem, increasing costs for the forest products industry, and will eventually either be buried, piled up and left to decay or open burned, again contributing to greenhouse gas emissions with no societal benefit.

It is widely recognized that sustainable managed forests will be an important and necessary component of a greenhouse gas mitigation strategy.  Young, vigorously growing trees sequester more carbon than mature trees.  The most effective strategy will be to sustainably manage our forests, converting trees into solid wood products and displacing fossil fuels and replanting or regenerating the forests.  It is also important to recognize that harvesting trees is not deforestation.  Deforestation is when forest lands are converted to other uses such as subdivisions or solar farms.  In conclusion, DEQ should recognize biogenic carbon dioxide emissions as carbon neutral irrespective of whether other fuels are co-fired.