I am just addressing the legal constraints the EPA operates under when using its authority under the Clean Air Act. It is possible to construct a broad range of scenarios that would rely on systems that cross industrial categories to achieve GHG reductions but when EPA adopts rules under particular provisions of the a Act, it has to respect the restrictions placed on those provisions by Congress. I don't see how EPA could incorporate the effects of biochar production into a standard that limits pounds of CO2 per megawatt hour of electricity production.
Sent from my iPad > On Jul 30, 2014, at 1:58 PM, "Ronal W. Larson" <[email protected]> > wrote: > > 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 >> >> -- >> You received this message because you are subscribed to the Google Groups >> "geoengineering" group. >> To unsubscribe from this group and stop receiving emails from it, send an >> email to >> [email protected]<mailto:[email protected]>. >> To post to this group, send email to >> [email protected]<mailto:[email protected]>. >> Visit this group at http://groups.google.com/group/geoengineering. >> For more options, visit https://groups.google.com/d/optout. > -- You received this message because you are subscribed to the Google Groups "geoengineering" group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected]. To post to this group, send email to [email protected]. Visit this group at http://groups.google.com/group/geoengineering. For more options, visit https://groups.google.com/d/optout.
