Michael cc List
1. Thanks for this addition. I believe your parallel (fuels, not
electric power) analogy has merit and I will include in my (still far off)
letter to EPA.
2. I just found a website with a lot of useful information on
macroalgae, especially the salt water varieties. See a dedicated macroalgae
center at James Cook University in Australia:
http://research.jcu.edu.au/macro/publications. Are there any other University
macro algae centers?
Macroalgae looks potentially superior to land based biomass growth, as
I think you and several other ocean-biomass advocates believe. Raises the
issue of whether a US utility could use biochar or BECCS in Australia (or
maybe better a developing country with lower labor costs and greater need for
soil improvement) to satisfy the proposed EPA rules under discussion this week.
Ron
On Jul 30, 2014, at 12:53 PM, Michael Hayes <[email protected]> wrote:
> One way CDR/NET fuels can be injected into the debate is to point out that
> the Renewable Fuel Standard (RFS) mandates that a percentage of renewable
> fuels be used and that currently the EPA has not been able to achieve the
> mandated percentage. Further, the Energy Independence and Security Act (EISA)
> of 2007, which governs the RFS, commits the EPA to:
>
> EPA is committed to developing, implementing, and revising both regulations
> and voluntary programs under the following subtitles in EISA, among others:
> Increased Corporate Average Fuel Economy Standards
> Federal Vehicle Fleets
> Renewable Fuel Standard
> Biofuels Infrastructure
> Carbon Capture and Sequestration
>
> Thus, Ron's goal of gaining substantial recognition of CDR/NET, within the
> current EPA rules development work, is not just justifiable on the STEM level
> but is actually mandated by Congress. For the EPA to view one issue (Clean
> Power Plan) as separate from the other (EISA) is contrary to the sprite and
> letter of the law (IMMHO).
>
> Best regards,
>
> Michael
>
> On Wednesday, July 30, 2014 11:35:10 AM UTC-7, David Hawkins 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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