|Action||Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)|
|Comment Period||Ends 3/6/2019|
opposition to the RGGE rule as written at this time
We are company that helps manage timber land for private and industrial landowners in the Piedmont area of Virginia, and oppose the new RGGI rule including emissions from non fossil fuel sources such as biomass. Biomass uses in producing heat for industrial facilities or electricity is important, because much of the waste created in the forest industry would go unused and left to rot. Biomass left to rot releases about 90 percent of it's mass back onto the atmosphere (mostly as CO2), and only around 10 percent is left as organic matter, so why waste all this energy? Planted and managed forest are also 10 times more productive than forest left to natural regeneration at reducing CO2 levels. The RGGI rule including biomass, could cause some landowners to be less proactive in their forest management, an in that case there would be less managed forest reducing CO2. We hope you decide exclude biomass from being treated like fossil fuels.
I love to speak on this subject
thank you: John Jones