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 4/9/2018
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3/22/18  10:04 am
Commenter: William L. Braford

The Commonwealth of Virginia should not join RGGI

I am a small timberland owner, consultant forester, and beef cattle farmer.

Biogenic carbon emissions should be recognized as carbon neutral irrespective of whether other fuels are also co-fired.  Our biomass fuels are mostly produced by the sun in 1 to 100 years.  Fossil fuels are formed over thousands of years and are accepted as a true carbon sink.  Therefore, it seems counterproductive to discourage even a small percentage of biomass fuels in the mix with fossil fuels, which the RGGI does.

The DEQ should maintain the current exemption for industrial boilers?.  The market for biomass is critical (and currently underpriced in my opoinion) for small farm and forest landowners to market thier forest products (lumber- a carbon sink and biomass-relatively carbon neutral).

Climate change is a longterm issue.  We should be careful to avoid regulations that accidently run counter to our longterm goals.