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  10:32 am
Commenter: Ray R. Hicks

Carbon status of wood residues

Forest product industries' burning wood residues to produce power and/or heat for wood processing is essentially the same as burning wood pellets in a power plant, which, with appropriate deductions for energy used in harvesting and transporting the residues is essentially carbon neutral. Therefore any unused power returned to the grid should be treated as such. A major difference between burning wood by forest industries and the burning of wood pellets for power or heat is that the residues are already at the mill site, being transported there along with the material that ends up in the finished wood product, whereas pellets are the product and their harvesting, transportation and processing is necessary to produce them. All biological carbon is part of the global carbon cycle, so if wood residues are not used for energy, their carbon will eventually enter the atmosphere through biological processes such as decay. The alternatives of using other materials (metals, plastics, bamboo, etc) in place of wood products all come with their own advantages and disadvantages, but from an American perspective, wood is abundant, renewable and contributes to our own economy. With good management forests can sustainably supply a significant proportion of our needs for building materials, energy and other specialty products while maintaining high environmental and aesthetic standards.

I am a retired Professor of Forest Ecology from West Virginia University and after retirement I worked for two years with the Sustainable Forestry Initiative's certification program.

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