Virginia should not join the RGGI and the DEQ shoud maintain the current exemption for industrial boilers. Biogenic carbon emissions shoiuld be recognized as carbon neutral regardless of whether other fuels are also co-fired.

• Paper and wood mills rely on biomass residuals from the manufacturing process to power their operations and sell electricity onto the grid. The proposed regulation of these utilities would potentially call into question the status of emissions from paper and wood product facilities.
• There is a strong consensus that using residuals and bio-wastes for energy actually has significant GHG reduction benefits.
• Biogenic carbon dioxide emissions from forest-derived bioenergy do not contribute to the build-up of GHG in atmosphere. Also, the carbon profile of biomass is not altered when co-fired with other fuels.