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RePower South: 

Advanced Biomass Energy’s Role 

in GHG Emission Reductions 

February 25, 2015
1. Background on RePower South and Advanced 

Biofuel (“ABFuel”) 

2. ABFuel is a low-cost compliance option

3. RePower South is deploying ABFuel now

4. FIP must include waste-derived fuels

5. EPA should allow the use of existing methodologies 

2

Agenda
• RePower South was created to 

deploy ABFuel (licensed 

ReEngineered FeedstockTM) to 

power generation facilities

3

Who is RePower South? 

• RePower South establishes mutually beneficial 

relationships with the municipalities and power plants 

that are its key customers and shares revenues with 

the communities

• As previously discussed with EPA, 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, derived from MSW, 

that lowers GHG emissions and controls criteria and 

hazardous air pollutants

• ABFuel lowers the cost of compliance with GHG rules

• Reduces direct and lifecycle fossil and non-fossil (e.g. landfill 

methane) GHG emissions 

• Significantly expands total waste stream recycling 

penetration and landfill diversion

• Broadly deployable in areas with sufficient waste and 

coal-generated electricity

ABFuel Overview

4
• Low-cost to utilities: 

• On a delivered MMBTU basis, the energy content of ABFuel is 

offered at a 10% discount to coal

• Cost and allocation of renewable attributes and GHG

reductions negotiated with each facility – varies by state under 

current law

• On balance, ABFuel offers greater than 10% GHG reductions 

at a cost below LCOE of existing coal fired facilities

• Waste processing costs at or below landfilling: 

• RePower South’s facility costs covered by waste tipping fees 

and recycling revenues

• Underlying waste processing done below the cost of landfilling 

ABFuel Is A Low-Cost Compliance Option

5
• ABFuel does not require public subsidies, tax breaks 

or other incentives to be deployed broadly and quickly

• RePower South will receive revenues from incoming 

MSW stream (e.g. tipping fees and recycling revenues) 

and revenues from sale of ABFuel

• Dual long-term revenue streams with credit-worthy 

counterparties make RePower South facilities attractive 

investments

• State and federal environmental benefits provide 

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

ABFuel Does Not Require Subsidies Or Incentives

6
• ABFuel can reduce GHG emissions by:

• Increasing and expanding recycling, reducing the energy 

usage and CO2 generation from the harvesting of virgin 

materials

• Significantly reducing landfilling quantities, including organic 

material and the resulting CO2 and methane emissions 

footprint

• Directly displacing fossil CO2 from coal combustion for power 

generation 

• Reducing parasitic loads from control technologies at coalfired power plants 

• Displacing coal and the associated GHG emissions from coal 

mining and transportation

7

Greenhouse Gas Reductions
• ABFuel will be particularly effective 

in the Southeastern U.S. 

• If 50% of the initial RePower South 

target facilities are operating, we 

estimate annual GHG reductions of 

3.6 MTCO2E

• Southeast is relatively more 

dependent on coal and has less 

renewable energy generation 

capacity than the rest of the U.S. 

Regional Impact of ABFuel

8
• RePower South is bidding for a contract with the 

County of Charleston to process the city’s municipal 

solid waste

• Meeting with the Finance Committee in March 2015

• Pending licensing and regulatory approvals, RePower

South will construct the facilities to manufacture 

ABFuel

• SCANA, a South Carolina utility, has made 

investments in Repower South and is negotiating the 

terms of a fuel supply agreement

• SCANA has publically indicated support for the project

Deployment Of ABFuel Is Underway 

9
• ABFuel can be broadly deployed anywhere that there 

sufficient waste and coal-generated electricity

• 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)

ABFuel Is Broadly Deployable 

10
• Waste-derived fuels must be included in the FIP, to 

ensure that States will include these fuels in their SIPs

• ABFuel provides benefits of renewable biomass 

without the negatives of food-based or woody biomass

• Majority of ABFuel’s biogenic emissions are “anyway” 

emissions

• Biogenic content will otherwise degrade and emit both CO2

and methane 

Waste Derived Fuels Need Clear Rules

11
• EPA’s prior statements indicates that waste-derived 

biomass will be credited under the Clean Power Plan:

• “We anticipate that states likely will consider biomass-derived fuels in energy 

production as a way to mitigate the CO2 emissions attributed to the energy 

sector and include them as part of their plans to meet the emission reduction 

requirements of this rule, and we think it is important to define a clear path for 

states to do so.” (Clean Power Plan)

• “For waste-derived feedstocks, the EPA intends to propose exempting 

biogenic CO2 emissions from GHG BACT analyses.” (McCabe memo Nov. 

19, 2014)

• EPA’s revised proposal for the Biogenic Assessment 

Framework would appropriately treat waste-derived 

biomass differently from food-based or woody biomass

EPA Support For Waste-Derived Biomass Crediting

12
RePower South’s comments recommended that the 

Clean Power Plan should allow:

• Credit for early action

• Credit for inside and outside the fence reductions for 

waste-derived fuels

• Credit for methane emissions reductions

• Clear and consistent treatment for waste-derived fuels 

using existing accounting methodologies

Comments on the Clean Power Plan

13
• EPA should allow the use of existing protocols and 

methodologies for quantifying GHG reductions 

• There are many well-established methodologies and protocols

• Development of new methodologies could slow the 

deployment of ABFuel and similar innovative technologies

• EPA should require that eligible protocols and 

methodologies: 

• Be scientifically sound and methodologically accurate 

• Avoid over-estimation of emission reductions

Quantifying ABFuel’s Emission Reductions 

14
• EPA’s WARM is well-suited to conservatively measure 

GHG emission reductions associated with ABFuel

• Designed to measure emission reductions associated with 

different waste management practices 

• Calculates (1) a baseline GHG emission scenario and 

(2) an alternative waste management practice GHG

emission scenario

• WARM analyzes changes in tons recycled, tons landfilled, 

tons combusted and tons composted

• WARM assumes RDF, which has a dramatically lower 

conversion efficiency than ABFuel

EPA’s Waste Reduction Model (“WARM”)

15
• WARM analyzes additional factors to determine the 

life-cycle GHG reductions: 

• Regional “marginal” electricity grid mix emission factor based 

on the location where the co-firing occurs

• Whether landfill in which the MSW would be disposed has a 

landfill gas (“LFG”) control system, the landfill’s LFG collection 

efficiency, and whether the LFG control system recovers 

methane for energy or flares it

• Moisture conditions and associated bulk MSW decay rate 

• Emissions that occur during transport of MSW based on 

distance traveled

EPA’s Waste Reduction Model

16
• A number of protocols have been developed under the 

U.N.’s Clean Development Mechanism 

• For example, a protocol to quantify methane emissions 

reductions associated with diverting agriculture waste to be 

used as a feedstock for certain products

• Voluntary carbon registries have developed GHG

reduction protocols for many different types of projects

• Climate Action Reserve’s Coal Mine Methane Protocol

quantifies GHG reductions associated with methanedestroying devices on active underground coal mines

Existing Models & Protocols 

17