Submitted by:

 

Primary Power International

168 E. Center St.

Ithaca, MI 48847

989.875.3822

Fax 989.875.3906

 

Gary Melow,

Special Projects Coordinator

 

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Primary Power International is an independent power producer with seven
(7) biomass electrical power plants in the U.S. and Canada capable of
producing 144 megawatts (MW) of renewable energy. Our fuel source is
wood diverted from the waste stream.

 

Primary Power International has been generating clean, renewable energy
since 1992, annually diverting about 1 million tonnes of wood away from
landfills where it would have decomposed into methane, a potent
greenhouse gas.

 

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COMMENTS:

 

**§300.2 Definitions, "Avoided emissions"**

Primary Power International proposes that this definition be expanded to
include the diversion of waste materials away from landfills, "avoiding"
the creation of methane (CH4).

 

As proposed, this definition is limited to the "generation and sale of
electricity, steam, hot water or chilled water produced from energy
sources that emit fewer greenhouse gases per unit than other competing
sources of these forms of distributed energy."

 

The use of biomass, such as wood, provides two (2) GHG reduction
benefits: It offsets higher-emission system electricity as described in
the current definition of "avoidance," and it prevents the development
of methane because the biomass was combusted instead of landfilled. In
other words, converting waste wood to CO2 by combustion rather than
methane through landfill decomposition provides significant GHG
reduction benefit.

 

This statement is validated by the Intergovernmental Panel on Climate
Change (1997), which shows that methane (CH4) has a global warming
potential (GWP) that is 21 times greater than that of CO2 (see Table 1).

 

**Table 1: Global Warming Potentials and Atmospheric Lifetimes**

  ------------- ---------------------- -------- ---------------------- -------- ---------------------- ---
                **Gas**                         **GWP**                         **Approximate          
                                                                                Atmospheric Lifetime   
                                                                                (Years)**              

  CO2                                  1                               50-200                           

  CH4                                  21                              12                               

  N2O                                  310                             120                              

  HFC-23                               11,700                          264                              

  HFC-125                              2,800                           32.6                             

  HFC-134a                             1,300                           14.6                             

  HFC-143a                             3,800                           48.3                             

  HFC-152a                             140                             1.5                              

  HFC-227ea                            2,900                           36.5                             

  HFC-236fa                            6,300                           209                              

  HFC-4310mee                          1,300                           17.1                             

  CF4                                  6,500                           50,000                           

  C2F6                                 9,200                           10,000                           

  C4F10                                7,000                           2,600                            

  C6F14                                7,400                           3,200                            

  SF6                                  23,900                          3,200                            

                                                                                                        
  ------------- ---------------------- -------- ---------------------- -------- ---------------------- ---

 

In 2002 Primary Power International commissioned ICF Consultants, an
internationally recognized engineering firm, to conduct an emissions
inventory of our facilities in which direct and indirect GHGs associated
with electrical production were compared to system power and the impact
of avoided methane. Sec. 1.2.5. of that study, Avoided Landfill
Emissions, demonstrates how this GHG reduction works:

 

**1.2.5 Avoided Landfill Emissions**

***1.2.5.1 Calculations***

When wood, or any organic matter, is deposited in a landfill, the
anaerobic decomposition

process will produce CH4 (methane). The production of CH4 is dependent
on factors such as the landfill

characteristics (e.g., moisture content, temperature, size of waste).
The emission of CH4 to the

atmosphere is dependent on factors such as landfill gas collection
systems and the oxidation rate.

(A portion of the CH4 is oxidized to CO2, which is considered biogenic).
IPCC includes a

methodology for calculating methane emissions from landfills. This
methodology was adopted

for wood waste in a managed landfill. Actual landfill characteristics
would influence specific

factors.

 

Further, the methane emissions are converted to CO2 emissions with the
GWP factor of 21.

Therefore, the methane emission factor is 1.89 tonnes of CO2e per tonne
of wood. These factors

have been used to estimate Primary Power\'s assets associated with
avoided landfill emissions

as shown in Equation 6. These emissions are summarized in Appendix A.

**Equation 6 Calculation of avoided landfill emissions**

EF(CH4) X Wood = E(CH4)

> Where:
>
> **EF(CH4)** = the tonnes of CO2e emissions from a quantity of wood
> decomposed in landfill (tonne CO2e / tonne of wood)
>
> **Wood** = the quantity of wood (tonne)
>
> **E(CH4)** = the GHG emissions avoided by diverting wood from
> landfills each year (tonnes)
>
>  
>
> Source: ICF Emissions Inventory, Primary Power International, 2002
>
>  

As an example, our Genesee Power Station in Flint, Michigan consumed
more than 300,000 tonnes of green wood waste in 2001, producing nearly
217,000 megawatt hours (MWh) of electricity and less than 11,700 tonnes
of CO2e. This same production of electricity through Michigan system
power would have produced 151,567 tonnes of CO2e. In addition, the
combustion of wood to produce electricity avoided the production of
578,368 tonnes of CO2e methane had that wood waste been landfilled.

 

These figures could be revised upward because biomass combustion is
considered biogenic, and therefore is recommended by the IPCC (1996)
that the CO2 generated in this manner not be calculated as a debit. It
is, instead, considered part of a natural, closed-loop carbon cycle that
does not significantly contribute to global warming. The CO2 is ingested
by the biomass, which sequesters the carbon until it is combusted and
the cycle is repeated with the next generation of biomass.

 

Biomass co-generation leads a double life: clean, renewable energy
generation and environmentally sound waste management services that
have, and will continue to have, a vital role in the reduction of GHGs.

 

Therefore, we recommend that the definition of "avoided emissions" in
§300.2 Definitions not be limited the sale and generation of electricity
and other energies, but be expanded to include avoidance of methane
development in landfills.