List:
Yesterday, I gave testimony in this week's EPA hearings on their Clean
Power Plan. I concentrated on just one proposed modification - that their
present four building blocks be expanded to include a fifth on CDR/NET - half
(?) of this list's territory. I had planned to do this only in writing, but I
stopped by the Denver hearings late in the day and had no trouble testifying
quickly (and not as well as I would have liked - so I have to also write now).
It is possible to testify today (5 minute max) also in Denver, Atlanta and
Washington DC - but also in Pittsburgh on Thursday and Friday. The fossil
industry is in this full force.
But mainly this note is to suggest this is a perfect time for everyone
on this list to make a written policy point about CDR/NET (I don't think SRM
would qualify). No prohibition I know of to prevent citizens of other
countries to write. We have until Oct. 16 (120 days after the June 18 first
official release).
The main point I will be making in writing is that a carbon negative
action could be disallowed unless the rules now specifically encourage this
fifth "negative emissions" block. That is - CO2 removal should be as much
encouraged as is CO2 reduction, and this should include CH4 and N2O. I fear
that half of the biomass carbon appearing as biochar could not receive the same
treatment as the half that is carbon neutral. I will not make this a biochar
issue - rather all of CDR/NET. I will be emphasizing the need to consider
getting to 350 ppm (Hansen and McKibben) and the need to promote hope and
reversibility. I have failed to find the "negativity" concept in the written
rules - which can be found at
http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule .
There are also a huge array of requested comments in the Federal
Register on June 18, especially around p 34839 on these "blocks". See:
http://www.gpo.gov/fdsys/pkg/FR-2014-06-18/html/2014-13726.htm
I wonder if anyone else on this list is following this path to make
CDR/NET better known at EPA?
Ron
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