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: ABFuelTM Bene

Meeting With OMB on EPA’s GHG Rule for ExPower PlantsApril 25, 2014 
• ABFuel will allow existing coal-fired power pla

reduce GHG emissions while reducing costs

• Capable of 10% reductions or more depending on 

rate

• ABFuel can be deployed in 18 months and re

minimal changes to plant operations

• ABFuel can be broadly deployed in areas wit

sufficient waste and coal-generated electricity

• ABFuel can be easily financed without extern

incentives

Intro: ABFuelTM Is A Low Cost Compliance 
What is ABFuel? 

• ABFuel is an advanced fuel 

technology that harnesses the energy content of discrete components of municipal solid waste (MSW)

• ABFuel is a primarily 

biogenic fuel that lowers GHG emissions and controls criteria and hazardous air pollutants

M

Variable

Minimum 

plastics

Percentage by We

(not including sorbents
• On a delivered MMBTU basis, ABFuel offered 

10% discount to the energy cost of coal

• Increased plant efficiency further reduces LC• Cost and allocation of renewable attributes an

reductions negotiated with each facility – varistate under current law

• On balance, ABFuel offers greater than 10% 

reductions at a cost below LCOE of existing cfacilities before application of green attributes

ABFuel is a Low-Cost Compliance T
• ABFuelproduction technology dramatically reduce

GHG emissions

*Developed from EPA Warm Model Version 

ABFuel GHG Reductions

Annual Current MSW ABFuelTM Potent

• 329,000 tpy MSW Generated 

Annual

• 22,961 tpy Recycled, 17,000 tpy

Composted

• Zero Energy Recovery• 288,784 tpy Landfilled

• 329,000 tpy MSW Gene• 83,093 tpy Recycled; 17

Composted 

• 139,640 tpy Energy Rec• 89,012 tpy Landfilled

Baseline Emissions: 127,997 MTCO2E

Alternative Emissions: (-17MTCO2E

NET GHG EMISSIONS REDUCTION PER YEAR: 303,308 M

10% reduction for a typical 600 MW coal power plant at ~ 
• WARM model does not capture full GHG redu

benefits of ABFuel: 

• Assumes co-firing with minimally processed refuse

fuel

• Assumes conversion efficiency of 16-17% in the R

mass burn facilities – likely target plant in Charlesto35% efficiency in 2012

• ABFuel can improve boiler efficiency by 1-2% and 

demand for coal and the resulting fossil CO2 emiss

• ABFuel reduces fossil CO2 and methane emission

both direct combustion of coal and the associated transportation

• Thus, ABFuel’s true emissions reductions are 

significantly greater than the WARM model re

ABFuel GHG Reductions
• When 50% of the 

prospective RePowSouth facilities are operating, we estimannual GHG reduc3.6 MTCO2E

Regional Impact of ABFuel
• RePower South will receive revenues from in

MSW stream

• Tipping fees per load and recycling revenues

• RePower South will receive revenues from sa

ABFuel

• Dual long-term revenue streams with credit-w

counterparties make RePower South facilities attractive investments

• State and federal environmental benefits prov

additional revenues that will be allocated on a by-facility basis

ABFuel Is Financeable Without Subs
• ABFuel can be broadly deployed in areas wh

sufficient waste and coal-generated electricity

• ABFuel technology can be deployed in every state• Multi-material processing and advanced manufactu

consistent emission reductions across waste sheds

• Potential for widespread international deploym

• 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 (IE

ABFuel Is Broadly Deployable 
• Reduces cost of compliance with MATS and C

• Improves plant efficiency and decreases coal cons• Reduces direct and lifecycle fossil and non-fossil (e

methane) GHG emissions, criteria pollutants, and H

• Significantly expands total waste stream recy

penetration and landfill diversion

• Broadly deployable in areas with sufficient wa

coal-generated electricity

• Reduces health and environmental impacts in 

environmental justice communities

• Generates revenue and creates long-term loc

ABFuel – Additional Benefits Beyond G
An Example of ABFuel’s Waste-Shed Im

More than

85%

Currently

Discarded

Currently

Recovered

Current Disposition of MSW

(Charleston, S.C.)

Currently Composted

Less 

30

Discard

Land

Recyclin

Energy

Recovery

as ABFTM

Composted

With ABFuelTM Techno
• ABFuel can be optimized 

for plant-specific emissions reductions

• SO2, SO3, HCl, and Hg 

• Additives can also be 

used to improve unit operating efficiency

• ABFuel treats the full 

emission stream

Firing at 8-13% energy substitut(Based on Oct. 2013 full scale test at SCanadys Power Plant)

Traditional & Hazardous Air Pollution Co

SO2

59% 

to 

70%

Hg

32% 

to 

54%

96% 

to 

99%

SO3
• Key regulatory features that can encourage th

deployment of beneficial alternative fuels like 

• Allow states the flexibility to credit the full l

benefits of co-fired alternative fuels

• Allow compliance credits for reductions bo

and outside the fence line

• Encourage early compliance and over-com• Allow credits to be traded among electric 

generators that supply the state

EPA GHG Rules For Existing Pla