Commenter:
Stephen Versen, Virginia Dept. of Agriculture & Consumer Services (VDACS)
Allow easy switching between approved fuels
We believe the permitting regulation should take into account the potential that an applicant might use different feedstocks in the conversion facility at different times during the year and that it should make the switching between allowable feedstocks as easy as is reasonable. One could imagine a scenario where a farmer would use wheat straw in the Spring, corn stover in the Fall, and wood chips in the winter. Provided that each feedstock to be used has been approved for use in the conversion facility, switching between them should not require additional, significant submissions by the applicant.
