The Commonwealth of Virginia should not join the Regional Greenhouse Gas Initiative (RGGI) to reduce greenhouse gas emissions from utilities.

Biogenic carbon dioxide emissions from forest-derived bioenergy do not contribute to the build-up of GHG in the atmosphere.  Also, the carbon profile of biomass is not altered when co-fired with other fuels.  There is a strong consensus that using residuals and bio-wastes for energy actually has significant GHG reduction benefits.  Biogenic carbon emissions should be recognized as carbon neutral irrespective of whether other fuels also are co-fired.