Dave: cc list
Suppose a biomass plant is planned to backup a wind or solar generator
(for some reason preferable to natural gas, batteries, or pumped hydro, etc).
I (and many others) feel that there is greater social benefit (food, soil C
leading to greater NPP, water, fertilizer, etc) if that biomass plant consumes
twice as much biomass to make biochar. Roughly half (rather than all) the
initial carbon would then be classified as CDR (carbon negative). Would you
argue that this "removal" half of biochar should not be counted as complying
with the proposed standards?
Ron
On Jul 30, 2014, at 11:38 AM, Hawkins, Dave <[email protected]> wrote:
> Because this standard is a sector-specific (fossil electric power generating
> units) emission reduction program, EPA is constrained by the Clean Air Act to
> allow only this techniques that result in emission reductions from the
> regulated fossil electric generating units to be counted in complying with
> the standards. EPA's proposal does allow actions that occur outside the
> generating plant boundaries to count -- including shifting generation to
> zero-carbon and lower-carbon sources, as well as demand-side measures that
> reduce total demand. These techniques are within the scope of Clean Air Act
> allowable measures because they all result in emission reductions at the
> regulated source category.
> Techniques like CDR, while desirable as part of a broader mitigation effort,
> are not within the scope of this sector-specific standard.
>
> Sent from my iPad
>
> On Jul 30, 2014, at 1:29 PM, "Ronal W. Larson"
> <[email protected]<mailto:[email protected]>> wrote:
>
> 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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