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 Ended on 4/9/2018
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3/22/18  9:55 am
Commenter: Danny Norman, Virginia Forestry Association member

RGGI and Biogenic Carbon Emissions

As a former Virginia resident and natural resorce manager, I support the following points for direction of the Virginia Department of Environmental Quality:


  1. Biogenic carbon emissions should be recognized as carbon neutral irrespective of whether other fuels also are co-fired;
  2. The DEQ should maintain the current exemption for industrial boilers; and
  3. The Commonwealth of Virginia should not join RGGI.

The use of biomass from sustainably managed forest as a fuel supply is a renewable product and should continue to be recognized as such. The forest industry has operated with biomass as a fuel supply since the advent of steam power and should be lauded that.

CommentID: 63934