Comment on FR Doc # 2010-02556

The BCAP Program should be continued. It will enhance all the biomass plants that are being built and planned for. A 1:1 subsidy is not needed to make wood competitive with many of the other fossil fuels. A subsidy in the range of 1:2 or 1:3 is more appropriate. Criticisms of including merchantable material such as pulp wood in the BCAP Program are understandable, and we understand the concern within the forest products industry about including pulpwood sized material in the BCAP. However, we do think that pulpwood material should be included in the program, especially in the areas where there is little or no demand for pulpwood such as the case in the lower peninsula of Michigan where we have lost four of five of the pulp mills that existed 10 years ago. There is virtually no demand for pulpwood in lower peninsula of Michigan. Having a wood fuel market that would provide a market for logging slash and pulpwood would be a boon to our state and the logging and forest products industry that is in severe decline. We also feel that urban wood waste should be including in BCAP. There is a significant amount of urban tree waste that there is little or no market for. Having a BCAP subsidy would allow for the utilization of this material supporting collection yards and subsidizing the additional trucking costs that may be required to transport the material to biomass energy facilities.