Biomass from sustainably managed forests is a valuable, carbon-neutral resource and fuel supply that should be recognized as such by VDEQ. This is a renewable resource that promotes utilization of forest by products that do not contribute well to forest nutrition by being left onsite. Leaf litter and fine twigs do much better at nutrification than does larger woody debris that could be utilized to produce energy, thereby lowering the dependence on fossil fuels as industrial fuel.  

Being carbon neutral, I would hope and recommend that new and existing biomass fueled boilers should be exempted under this provision.

Thanks,

Billy Newman