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Proposed Virginia DEQ forest biomass regulation must reflect carbon reality

Proposed Virginia DEQ forest biomass regulation must reflect carbon reality

Forest biomass powers Virginia’s economy. More than 27,000 Virginians make a living in the commonwealth’s forestry and forest products industry, which includes manufacturers of pulp, paper, packaging, tissue, and wood products. They make nearly $7.4 billion in products, earn a total payroll of almost $1.5 billion a year, and generate annual state and local tax revenue of $155 million. Forest biomass also powers many of the facilities in which this economic activity takes place.

Consistent with the United Nations’ Kyoto Protocol and the policies of other nations around the world, biomass energy should be considered carbon neutral. Data from the U.S. Forest Service indicate that timberlands in Virginia grew more than twice as much wood as was harvested in 2016 — wood that is sequestering carbon — while the U.S. as a whole also grew nearly twice as much wood as was harvested. These sustainable manufacturing practices should be rewarded, not penalized.

Virginia’s DEQ seems to be moving in the opposite direction. A draft regulation from the DEQ’s Air Pollution Control Board would, for the first time in any state, classify an electric generating facility as fossil fuel-fired and subject to additional regulations if just over 10 percent of the fuel mix it uses is fossil fuel and the remainder is forest biomass.

This approach is not supported by science, is inconsistent with the model rule of the Regional Greenhouse Gas Initiative (RGGI), which is what prompted this regulation in the first place, and would set a dangerous precedent for other states considering how best to support carbon-neutral energy.

DEQ can and should do better by using a science-based approach that acknowledges the real-world attributes of forest biomass and its contribution to carbon-neutral power generation. The proposed regulation should be updated to reflect the reality that the carbon profile of biomass has no credible connection to the amount of fossil fuels that may or may not be fired in the same generator. The proposed regulation can be improved further by removing language stipulating that Virginia join RGGI — a legislative question, not a regulatory one. Also, the proposed regulation should indicate clearly that the DEQ maintains the current exemption for industrial boilers.

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