Paper and wood products mills rely on biomass residuals from the manufacturing process for powering their operations or to sell electricity onto the grid. Regulating utilities as proposed would set an adverse precedent and potentially call into question the status of biogenic carbon dioxideemissions from paper and wood product facilities.

The DEQ should clearly exempt new and existing industrial boilers. Biogenic carbon dioxide emissions should be recognized as carbon neutral irrespective of whether the biomass is co-fired with fossil fuels.