# From: Ben.Lawless@lw.com [mailto:Ben.Lawless@lw.com]

Sent: Friday, April 25, 2014 3:17 PM

To: Wayland, Robertj

Cc: claudia.o'brien@lw.com

Subject: RePower South OMB Meeting Presentation

Dr. Wayland,

Please find attached a .pdf copy of RePower South’s presentation for the 4:00 PM meeting with the

Office of Budget Management.

Best,

Benjamin M. Lawless

LATHAM & WATKINS LLP

555 Eleventh Street, NW

Suite 1000

Washington, D.C. 20004-1304

Direct Dial: +1.202.637.2170

Fax: +1.202.637.2201

Email: ben.lawless@lw.com

http://www.lw.com

<< RePower South OMB Presentation - Final.pdf >>RePower South: ABFuelTMBenefitsMeeting With OMB on EPA’s GHG Rule for ExistingPower PlantsApril 25, 2014•ABFuel will allow existing coal-fired power plants toreduce GHG emissions while reducing costs•Capable of 10% reductions or more depending on co-firingrate•ABFuel can be deployed in 18 months and requiresminimal changes to plant operations•ABFuel can be broadly deployed in areas withsufficient waste and coal-generated electricity•ABFuel can be easily financed without externalincentives1Intro: ABFuelTMIs A Low Cost Compliance ToolWhat is ABFuel?2•ABFuel is an advanced fueltechnology that harnessesthe energy content ofdiscrete components ofmunicipal solid waste(MSW)•ABFuel is a primarilybiogenic fuel that lowersGHG emissions andcontrols criteria andhazardous air pollutantsMinimumFiberVariableMinimumplasticsPercentage by Weight(not including sorbents)•On a delivered MMBTU basis, ABFuel offered at a10% discount to the energy cost of coal•Increased plant efficiency further reduces LCOE•Cost and allocation of renewable attributes and GHGreductions negotiated with each facility – varies bystate under current law•On balance, ABFuel offers greater than 10% GHGreductions at a cost below LCOE of existing coal firedfacilities before application of green attributes3ABFuel is a Low-Cost Compliance Tool•ABFuelproduction technology dramatically reduces netGHG emissions*Developed from EPA Warm Model Version 12 June 20134ABFuel GHG ReductionsAnnual Current MSW ABFuelTMPotential• 329,000 tpy MSW GeneratedAnnual• 22,961 tpy Recycled, 17,000 tpyComposted• Zero Energy Recovery• 288,784 tpy Landfilled• 329,000 tpy MSW Generated• 83,093 tpy Recycled; 17,220 tpyComposted• 139,640 tpy Energy Recovery• 89,012 tpy LandfilledBaseline Emissions: 127,997MTCO2EAlternative Emissions: (-175,311)MTCO2ENET GHG EMISSIONS REDUCTION PER YEAR: 303,308 MTCO2E*10% reduction for a typical 600 MW coal power plant at ~ 60% CF•WARM model does not capture full GHG reductionbenefits of ABFuel:•Assumes co-firing with minimally processed refuse-derivedfuel•Assumes conversion efficiency of 16-17% in the RDF andmass burn facilities – likely target plant in Charleston had a35% efficiency in 2012•ABFuel can improve boiler efficiency by 1-2% and also reducedemand for coal and the resulting fossil CO2emissions•ABFuel reduces fossil CO2and methane emissions due toboth direct combustion of coal and the associated mining andtransportation•Thus, ABFuel’s true emissions reductions aresignificantly greater than the WARM model reflects5ABFuel GHG Reductions•When 50% of theprospective RePowerSouth facilities areoperating, we estimateannual GHG reductions of3.6 MTCO2E6Regional Impact of ABFuel•RePower South will receive revenues from incomingMSW stream•Tipping fees per load and recycling revenues•RePower South will receive revenues from sale ofABFuel•Dual long-term revenue streams with credit-worthycounterparties make RePower South facilitiesattractive investments•State and federal environmental benefits provideadditional revenues that will be allocated on a facilityby-facility basis7ABFuel Is Financeable Without Subsidies•ABFuel can be broadly deployed in areas where theresufficient waste and coal-generated electricity•ABFuel technology can be deployed in every state•Multi-material processing and advanced manufacturing ensureconsistent emission reductions across waste sheds•Potential for widespread international deployment•South Africa – 93% of electricity generated by coal•China – 79% of electricity generated by coal•India – 68% of electricity generated by coal•Australia – 78% of electricity generated by coal (IEA 2012)8ABFuel Is Broadly Deployable•Reduces cost of compliance with MATS and CSAPR•Improves plant efficiency and decreases coal consumption•Reduces direct and lifecycle fossil and non-fossil (e.g.landfillmethane) GHG emissions, criteria pollutants, and HAPs•Significantly expands total waste stream recyclingpenetration and landfill diversion•Broadly deployable in areas with sufficient waste andcoal-generated electricity•Reduces health and environmental impacts inenvironmental justice communities•Generates revenue and creates long-term local jobs9ABFuel – Additional Benefits Beyond GHGs10An Example of ABFuel’s Waste-Shed ImpactMorethan85%CurrentlyDiscardedCurrentlyRecoveredCurrentDispositionofMSW(Charleston,S.C.)CurrentlyCompostedLessthan30%DiscardedtoLandfillsRecyclingEnergyRecoveryasABFTMCompostedWithABFuelTMTechnology•ABFuel can be optimizedfor plant-specificemissions reductions•SO2, SO3, HCl, and Hg•Additives can also beused to improve unitoperating efficiency•ABFuel treats the fullemission stream11Firing at 8-13% energy substitution level(Based on Oct. 2013 full scale test at Scana’sCanadys Power Plant)Traditional & Hazardous Air Pollution ControlSO259%to70%Hg32%to54%21%to57%HCl96%to99%SO3•Key regulatory features that can encourage thedeployment of beneficial alternative fuels like ABFuel:•Allow states the flexibility to credit the full lifecyclebenefits of co-fired alternative fuels•Allow compliance credits for reductions both insideand outside the fence line•Encourage early compliance and over-compliance•Allow credits to be traded among electricgenerators that supply the state12EPA GHG Rules For Existing Plants