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The BioEnergy Producers Association is a coalition of private and
public entities dedicated to the development and commercialization
of environmentally preferable industries that produce renewable
sources of power, fuels and chemicals from agricultural, forestry
and urban biomass.  Our membership includes bioenergy firms,
electric utilities and waste management companies.

We welcome the opportunity to comment on the revised draft cap and
trade regulations.  The BioEnergy Producers Association strongly
supports the revision to Section 95852.2 (a)(7)(B) on page A-91 of
the revised regulations ("Municipal Solid Waste"), which deletes
the language following subsection (B), "Conversion to a clean
burning fuel."  Retention of the original language, which is
derived verbatim from a scientifically inaccurate definition of
"gasification" in PRC 40117, would have effectively eliminated
"conversion to a clean burning fuel" from eligibility by requiring
qualifying conversion processes to have zero emissions.