We are eager to see the McAuliffe/Northam carbon reduction cap and trade plan improved and put into effect so that Virginia can at last reduce carbon pollution from power plants and level the playing field for carbon-free energy from solar and wind. The health of the human and natural environments will greatly benefit.  It could reduce electric costs for consumers too.  Joining RGGI could greatly magnify the effect of the plan, broadening the east coast area that is taking measures to fight climate change, whose effects are certainly very evident in our coastal areas, but also in parts of our forests and agricultural lands as rain patterns change and severe drought expands.

But please don’t exempt plants that burn biofuels.    Exempting them would be a powerful incentive to cut and burn more trees. As we still have no carbon sequestration more efficient than that trees and other green plants do for us, free of charge, I hope you will take this seriously.  Trees are being massively harvested now  throughout the southeast for biofuel use in Europe, on the premise that is renewable energy. And It is.  We can plant more trees.  But you have to discount the fact it will take 30-100 years to grow to the size of the trees that are being cut and turned into pellets, then shipped to Europe for heating and power plants.  Biomass burning is NOT carbon-neutral unless you ignore the damage to the US.  Per ton, it may release more CO2 than coal in part because of the CO2 generated in harvesting and processing wood to pellets, quite aside from those generated by cross-Atlantic shipping. Even those who claim to burn only slash remains of logging have little or no evidence that the process is carbon neutral.  The science is incomplete.  The point is urgent, because the US House of Representatives earlier this year passed a spending bill that directed the EPA to establish policies to encourage private investment in the forest biomass supply chain.

In conclusion, I request that Virginia join RGGI and that the DEQ use its authority to adopt and implement a final standard that  caps and reduces carbon pollution as rapidly as possible, with an initial cap no higher than 32 million tons, and covers biomass facilities as well as fossil fuel facilities and finally that requires close monitoring  to prevent further burdens to low income communities            Thank you.