Dave cc list
1. Acknowledge helpful addition from Michael Hayes this past hour.
Will respond separately.
2. I really appreciate your advance rebuttals I/we might find from
legal experts at EPA or elsewhere. This is exactly why I wrote this AM. I
claim zero legal expertise.
3. I now have to read a lot more on the Clean Air Act (CAA), but my
initial reading doesn't yet support the view that the CAA precludes counting
CDR/NET. I like your emphasis (below) on pounds CO2 per MWh - and see no
reason those pounds can't be carbon negative. Both carbon neutral and carbon
negative MWh's can lead to identical amounts of atmospheric CO2 in 2030. If
anyone can supply a specific CAA cite that excludes CDR/NET, I would love to
read it.
4. New issue: I believe we should be talking CO2eq, not CO2. Biochar
can provide a large reduction of atmospheric N2O (and lesser CH4). If not in
the present hearings, I feel equivalents should be under discussion, not only
CO2. Aren't N2O and CH4 easier to justify in regulations? Does it make sense
that N2O benefits of biochar would be included but not CO2?
5. Broadening CDR/NET: Afforestation (the main approach of Jim
Hansen) and BECCS would seem to be either half or fully excluded as well as for
biochar This should bother the large community out there favoring rapid
endorsement of 350 (or lower) ppm CO2.
6. I conclude that you (Dave) believe that the backup biopower/biochar
example I gave would result in EPA allowing only roughly half of the credit
that a biochar supporter would like. If you or anyone can suggest a way around
this problem, I think the future of CDR would be much brighter.
Ron
On Jul 30, 2014, at 12:35 PM, Hawkins, Dave <[email protected]> wrote:
> 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
>>>
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