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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3/1/19  8:56 am
Commenter: Stephen Prisley

Exempt Biomass Emissions

I strongly urge the Air Pollution Control Board to ensure that biomass emissions are exempted from the Regulations for Emissions Trading, which are aimed at lowering fossil fuel emissions from electricity generation in the Commonwealth.

I speak from over 30 years of experience in the forestry sector, with 13 years as an employee of forest products companies and 17 years as a professor of forestry at Virginia Tech. For the past three years, I have been employed by a nonprofit research institute focusing on environmental issues related to forestry and forest products manufacturing.  My area of expertise is forest inventory and forest carbon accounting; in this capacity, I have served as a chapter lead author for two Intergovernmental Panel on Climate Change (IPCC) special reports on forestry and land use change. In addition, I have served on USDA and USEPA technical panels responding to forest carbon and biomass emissions issues.

At Virginia Tech, I led the formation of the Center for Natural Resources Assessment and Decision Support, where I worked closely with the Virginia Department of Forestry and key forestry stakeholders in the Commonwealth to assess and project forest conditions under growing demands for forest products, including woody biomass for energy. Our assessments demonstrated that Virginia is in an excellent position to continue to provide a sustainable supply of wood to the wide array of existing forest products manufacturers as well as a growing supply of wood fiber for biomass energy.

In the two decades that I have been studying the role of forests in the global carbon cycle, it has become clear that forests can play a key role in mitigating climate change through sequestration of carbon, and in providing a low-impact substitute for fossil fuels that could be critical as we transition to low-carbon reliable energy sources. Meanwhile, these same forests provide clean air and water, wildlife and recreation- Virginia’s forests continue to grow more wood than is harvested on an annual basis.

The regulations in their current form could hamper progress in providing renewable energy that replaces consumption of fossil fuels.  The regulatory burden added to our nascent biomass energy industry will remove the incentive to use renewable resources that lead to quick recapture of CO2 from the atmosphere as our forests regrow.  The mere presence of a market for woody biomass has been shown by multiple researchers to result in more forests and more forest productivity, not less.

There are compelling scientific and social reasons to promote, not hinder, the use of biomass for energy production.  The Regulations for Emissions Trading are an excellent place to make a clear distinction between renewable and fossil fuels by exempting emissions from biomass feedstocks.