Wondering why the limitations to 5megawatt?  Seems arbitrary.

further, I love the idea to test the biomass prior to usage as fuel to estimate expected emissions, and then test stack emissions to verify.  That's the smart way to learn!

Jon R. Patrick
Husband, Father, Lover, <a rel="nofollow" x="http://JonRPatrick.com">Mandura</a> Rep. helping others start their own home-based Personal Franchises

When speaking with DEQ Staff on Wednesday, Dec. 1st about the Biomass Energy Generator General Permit for a Pilot Test Facility, I was told that the Technical Advisory Committee recommended that the generator label should be 5 MW, yet when reading the regulation, the energy limit is 5 MW per year, indicating a generator label of 570.78 kW (Proof:  5,000,000 kWh per year / 8,760 hours per year).   Which figure is actually being proposed?  Afterall, there is a huge difference.  

I see no problem with interpreting 5 MW as the nameplate capacity of the generator, but there is conflicting wording within the definition of Qualified Energy Generator.  Subsection "i" states "with the capacity annually to generate no more than five megawatts (MW) of electricity...." yet the last sentence states:  "For the purpose of this chapter, the phrase "capacity annually to generate no more than 5 MW of electricity" shall mean a nameplate capacity equal to or less than 5 MW that is operated in conjunction with a biomasss pilot test facility."  I would recommend that the wording within 'i" of the definition of Qualified Energy Generator be reworked to include the phrase "5 MW nameplate capacity."  I would recommend that the last sentence within the defiintion be allowed to remain.

I fully agree with Steve Versen's comments that a farmer or the operator of a biomass energy generation facility should be able to switch between approved fuels with minimal requirements imposed.