My name is Gregory L. Gambrel, and I have worked in the forest products industry in Virginia for over 25 years.  I am concerned that the Commonwealth has not fully considered the benefits of energy produced from biomass.  This proposed DEQ regulation clearly shows that “clean energy” consideration has not been given to biomass-based energy production, nor has consideration been given to existing facilities in the Commonwealth that have utilized energy produced from biomass for many years. 

I oppose the regulation as currently written, and I urge DEQ to amend the proposed regulation:

- Clearly state that emission restrictions ONLY apply to fossil fuel based energy production

- Clearly state that biomass based energy production emits carbon-neutral biogenic CO2 which should NOT be subject to regulation whether it is produced on its own or co-fired with another fuel source.

- Exempt both existing AND new industrial wood-fired boilers

thank you,

Gregory L. Gambrel