I oppose the rule as written, because it would include emissions from non-fossil fuel sources such as biomass, which plays a critical role in Virginia’s forestry economy. The rule should be amended to specifically exclude emissions from sources such as biomass, which are widely acknowledged to be carbon neutral. The rule should also be limited to electric utilities, and exclude industrial boilers.

It would seem to me that the goal here would be to encourage the use of biomass rather than natural gas, fuel oil, etc. since biomass is a renewable natural resource.  In our business, we must use everything that comes out of the trees we process in order to stay viable  We use the sawdust from our operations (rather than fossil fuels) as the sole source of fuel for the small boiler that fires the kilns dry the lumber we produce.  Any further expense or undue regulatory burden would obviously have an adverse affect on our business - which directly employs 40+ people and indirectly supports countless others.

Thank you for your consideration,

Carter Flippo, VP