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Kelly, Shaheerah

From: Afro-Asian Energy Development Consortium Inc [aedinc@gmail.com]

Sent: Monday, December 30, 2013 8:24 AM

To: Kelly, Shaheerah

Subject: AED Response to EPA(epa-eTransmittal-1) Public Notice of Extension of Public Comment 

Period for the Proposed Clean Air Act Prevention of Significant Deterioration Permit for Sierra 

Pacific Industries - Anderson Division (SAC 12-01)

Attachments: Harvest Biomass Collaboartive Global flyer-F.pdf; California Cow flyer EnerC-12 F (6).pdf; 

BWF Schematic for Demo power net generated from Plant-A & B Draft-1 EPA SP 22Oct '10 

(1).pdf; BioSequestration Intiative Worldwide-F.pdf

Ms Shaheerah Kelly

U.S. Environmental Protection Agency, Region 9 (AIR-3)

75 Hawthorne Street

San Francisco, CA 94105-3901,USA Phone: (415) 947-4156

 Subject:PERMIT APPLICATION NO. SAC 12-01 (Ref: SIERRA PACIFIC INDUSTRIES - ANDERSON 

DIVISION) 

Dear Ms Kelly (EPA-SFO): 

 

This refers to our phone conversation and email of 9th Dec 2013 regarding the subject 

public notice inviting comments for the :

1. The Best Available Control Technology (BACT) determinations

2. The effects, if any, on Class I areas;

3. The effect of the proposed facility on ambient air quality; and

4. The attainment and maintenance of the NAAQS.(National Ambient Air Quality 

Standards)

AED Comments and Response:

AED (Afro-Asian Energy Development Consortium) is administering Harvest Biomass 

Initiative(HBI) which is the PPP* program of Harvest Biomass Collaborative Worldwide 

(HBCW) as per attached flyer.(*Public Private Partnership)

HBCW mission is similar to that of California Biomass Collaborative(CBC) as administered 

by UC at Davis for state of California while HBCW program is Worldwide serving all 

inclusive; the developed nations(G20) as well as developing nations(G77).

AED Harvest Biomass Initiative involves unique proprietary technologies for biomass 

utilization by converting raw forest-residue/forest waste-wood/agrowastes into BWF® (Biomass Water Fuel).

 
2

North America has over 1 billion tons/year biomass available(DOE) and similar abundance 

in major continents and island nations of the world.

BWF is also BioSequestered Premium Clean BioCoalTM which is Ash & Sulfur Free Carbon 

Neutral (ASFCN) Renewable Fuel that is pumpable and Low Cost Petroleum Fossil Fuels 

Substitute.

BWF technologies addresses the challenges involved in (1) economical biomass transport 

and (2) has superior combustion attributes that are (3) more air quality standards 

compliant compared to raw biomass transport and combustion characteristics.

GHG emissions reduction* are estimated to be 30% and or more considering the biomass 

life cycle (i.e.cradle to grave), compared to existing raw biomass utilization methods. By 

the same yard stick, switching to BWF and or BioCoal-blended fuels from raw biomass as 

fuel will result in minimum 15% reduction* in gross fuel utilization costs. (*order of 

magnitude-site specific) 

 Another major impact will be immense savings($) in halting and reversing 

forest destruction due to uncontrolled 

 forest fires occurring with alarming frequencies every year in 

California and other vulnerable regions besides

 mitigating climate changes triggering such devastation, resulting 

in billions of dollars in loss and damage.

Given the required funding, AED will consider a global 

demonstration centre with ongoing support involving a modular 

commercial biomass BWF conversion plant(120 tpd) that can be at 

any appropriate location including supporting Sierra Pacific's 

Andersen operation.

 

Presentation of techno-commercial details of AED proposal for the 

parties involved will be next appropriate step for which we will 

appreciate your early response.

Thank you.

Bhasker Patel

Chairman

AED
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HBCW (Harvest Biomass Collaborative Worldwide)

 

On Mon, Dec 9, 2013 at 4:05 PM, Kelly, Shaheerah <Kelly.Shaheerah@epa.gov> wrote: 

* * * PUBLIC NOTICE * * *

 PERMIT APPLICATION NO. SAC 12-01
Harvest Biomass Collaborative Worldwide

Administered by Afro-Asian Energy Development Consortium Inc

the Harvest Biomass Collaborative Worldwide “HBCW

alliance of industry, educational institutions, environmental and

government agencies, and NGO’s

nations. 

Sponsored by a group of concerned scientists, technocrats, 

entrepreneurs and investors, the Collaborative 

agencies and industry partners to address the issues of global climate 

change and world poverty mitigation.

the production and transportation of renewable energy, bio

blended products from renewable and fossil energy sources, and other 

remedial technologies leading to a sustainable

environment. Appropriate application of these technologies can halt 

and/or reverse deforestation

and development of biomass energy sources worldwide.

By addressing the urgent global demand for indigenous biomass 

utilization, HBCW can advance the goals and aspirations of both 

and G-20 nations as envisioned

Harvest Biomass Collaborative Worldwide

Asian Energy Development Consortium Inc

ss Collaborative Worldwide “HBCW" is a 

educational institutions, environmental and

government agencies, and NGO’s, from both G-77 nations and G

Sponsored by a group of concerned scientists, technocrats, 

ntrepreneurs and investors, the Collaborative works with other lending 

agencies and industry partners to address the issues of global climate 

change and world poverty mitigation. HBCW’s primary activities

and transportation of renewable energy, bio-fuels, 

renewable and fossil energy sources, and other 

remedial technologies leading to a sustainable and cleaner 

Appropriate application of these technologies can halt 

and/or reverse deforestation, and encourage sustainable management 

nt of biomass energy sources worldwide. 

By addressing the urgent global demand for indigenous biomass 

can advance the goals and aspirations of both 

envisioned by the United Nations. 

Asian Energy Development Consortium Inc (AED), 

is a global 

educational institutions, environmental and

77 nations and G-20 

works with other lending 

agencies and industry partners to address the issues of global climate 

activities include 

fuels, 

renewable and fossil energy sources, and other 

Appropriate application of these technologies can halt 

and encourage sustainable management 

By addressing the urgent global demand for indigenous biomass 

can advance the goals and aspirations of both G-77 
		



	



		

	







 	

 	


 
 	

 	

 	

 		

 
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Biomass

All types of Agro Waste &

Agro-byproducts

(High moisture carbonaceous materials)

~2500 Kcal/kg 

(Controlled) -Deoxidization -Dehydration 

**Biomass conversion to 

liquid format (Pumpable}

A Renewable Superior Fuel 

(Non-hazardous, non toxic & non in-flammable)

~5000-7000 Kcal/kg 

Substitute for Fossil Fuel (Fuel Oil) 

(BWF Co-firing option reduces significant SOx,NOx, ROx)

**Patented Process

Raw Biomass 

Agro Waste 

Biomass 

Water Fuel 

Formulation 

Volumetric Volumetric 

For Interim study only

Restricted /Confidential

BWF Conversion Unit's Area(Orange shaded) needing R10/23/2010 support 

Modular Commercial Demo Plant Configuration Analysis Draft-1 20th Oct 

For Interim study on

Plant-A 

Module(Model)= 5 MW Conventional Plant Grid system(specific) 

(300 tpd) 3.5 MW Export C

1-1.5 MW upto~ 1 

BWF--> to BWF Plant-B(Heat Exch/Ancillaries etc) (sufficie

** Biomass Fuel Steam

Boiler STG

** Volume / mass ** Quality Co-Generation ** Steam 

Volume quality

** Resource Specific ** Biomass Feedstock Preperation Unit** Raw Biomass : Storage , Handling , crushing , micro-sizing,feed-Blending** Thermal Characteristics(? ?)** Volume / ** mass (??)

Part 
 

aedinc@gmail.com

 

BioSequestration

(Developed(G20) and Developing(G77)

Halting Deforestation 

‘Harvest Biomass Collaborative 

BWF

BioSequestered

 Ash & Sulfur Free Carbon Neutral 

 Low Cost Petroleum Fossil Fuel

Introduction: 

Currently there are coal gasification 

cleanly. However utilizing any fossil fuel is considered ”un

converted to CO2, either during processing or by end

processes, part of the CO2 produced

sequestered in geologic formations or deep in the oceans. Some of the

as CO2, increasingly designated as a “pollutant.” With biomass fuel 

produced is consumed by the next generation of fuel crops planted to replace the biomass 

energy. This is now an environmentally acceptable practice, resulting in a “net carbon footprint” of zero. 

Biomass can be considered to be a younger 

Solution: 

Biorecycling of all CO2 produced by designated coal

crops to replace the carbon content of the 

accomplished today with existing technologies.

simple regulatory provision with or without incentive

coal consumed by industry (utilities 

of assorted fast-growing, low-maintenance 

of biomass with a carbon content equal to that of the 

‘BioSequestration.’ 

Details : 

As a natural form of “carbon trading,” the CO

use by trees (biomass materials)

The biomass trees paid for by such a program can be any fast

preferably native species as determined by region and climate, such as;

 

 

BioSequestrationTM Initiative Worldwide

Developed(G20) and Developing(G77) Nations)

(Min 10” annual rainfall) 

Halting Deforestation and World Poverty Reduction Program

Harvest Biomass Collaborative Worldwide’ (HBCW)

BWF® (Biomass Water Fuel) 

As 

BioSequestered Premium Clean BioCoalTM 

Ash & Sulfur Free Carbon Neutral (ASFCN) Renewable

Low Cost Petroleum Fossil Fuels Substitute

gasification technologies that can produce hydrogen, petro fuels

fossil fuel is considered ”un-green,” since all of its carbon content is eventually 

, either during processing or by end-product combustion. For most coal gasification 

produced can be recovered easily and used for enhanced oil recovery or 

sequestered in geologic formations or deep in the oceans. Some of the carbon will end up in the atmosphere 

, increasingly designated as a “pollutant.” With biomass fuel sources, on the other hand, all the CO

produced is consumed by the next generation of fuel crops planted to replace the biomass 

. This is now an environmentally acceptable practice, resulting in a “net carbon footprint” of zero. 

younger much cleaner form of coal hence it is technically ‘

produced by designated coal utilization processes, into growing biomass 

crops to replace the carbon content of the bio-coal consumed will be carbon neutral

accomplished today with existing technologies. It would be helpful and supportive if there is 

with or without incentive that part of the gross income from every ton of 

utilities plants) enrolled in a program, must be invested in the planting 

maintenance biomass materials that in 10 years will generate a mass 

with a carbon content equal to that of the bio-coal consumed. We call 

As a natural form of “carbon trading,” the CO2 from the bio-coal need not be ear

biomass materials) planted under the program. 

trees paid for by such a program can be any fast-growing, low

as determined by region and climate, such as;. 

 

 

1

Worldwide

)

Programs of 

HBCW)

TM 

Renewable Fuel 

Substitute

petro fuels, and or electricity 

of its carbon content is eventually 

most coal gasification 

red easily and used for enhanced oil recovery or 

end up in the atmosphere 

sources, on the other hand, all the CO2

produced is consumed by the next generation of fuel crops planted to replace the biomass converted to clean 

. This is now an environmentally acceptable practice, resulting in a “net carbon footprint” of zero. 

technically ‘BioCoal’ 

processes, into growing biomass 

will be carbon neutral. This can be 

be helpful and supportive if there is a 

that part of the gross income from every ton of 

enrolled in a program, must be invested in the planting 

that in 10 years will generate a mass 

. We call this process 

coal need not be ear-marked for 

growing, low-maintenance, 
 

 

aedinc@gmail.com 

2

• Second growth forest areas with presently less than maximum tree density. 

• Public highway rights-of-way. (Most access/ loops currently have room for 20~50 

cottonwoods, silver maples, box elders or green ashes, without infringing on visibility 

or maintenance.) 

• Wind breaks 

• Non-utilized agricultural lands, including CRP (Conservation Reserve Program) acreage. 

• New, low-density residential areas, where homeowners would agree to let 

designated trees grow for at least 20 years, and thus claim to be doing their part to 

combat global warming. 

• Reclaimed, burned-over forest areas. 

• Commercial timber, pulp or fuel wood plantations, beyond the acreage that would be 

planted under owners’ planned or available investment budgets. (After the 10 year 

period, harvesting rights could be sold back to the owners, thus recouping some of 

the initial government investment.) 

The cost of these trees would be an operating expense of the bio-coal consuming companies, to be 

passed on to the end users. The cost of the electricity, as an end product, would still be less than 

that of electricity by solar means or windmills. The add-on cost of gasoline from bio-coal would be 

well below the cost of imported, OPEC-sourced oil. It would also be cheaper than the available or 

proposed CO2 sequestration schemes. Regulatory agencies (EPA, state depts. of natural resources 

(DNR), etc) and volunteer environmental groups could be involved in the planning, site selection, 

planting, and maintenance, thus giving them a sense of empowerment and a possibility of some 

wholesome, useful activity. The only limitation on the kind, numbers and location of trees(biomass 

materials) planted would be that they grow fast and are planted where trees would probably not 

have been planted, or sprouted naturally in such quantity, for any other funded purpose. The 

program may augment private or government investments in forests, but should not serve as a 

substitute for them, or as a complete subsidy. 

By the end of each 10 year period, the designated bio-coal burned will have accumulated a 

net-zero carbon “footprint.” Where the trees are not harvested and continue growing 

beyond the required 10-year basis of approval, they will continue turning CO2 into trunks 

and roots, and the bio-coal burned will be developing an increasingly net-negative carbon 

footprint! What could be “greener?” 

Advantages To all nations- Worldwide: 

• The obvious: Delayed elimination net CO2 emissions from the designated coal 

consumers. 

• Revitalization (life expectancy) Support for coal-based industries and utilities via 

Renewable energy option 

• Incidental investment in a massive future national reserve of timber and pulpwood 

resources, on both federal and private lands (country specific). 

• Development of future biomass energy (fuel wood) reserves, contributing to national 

energy independence and energy security, as biomass conversion process becomes 

more necessary and commercially viable. 

• Massive restoration or expansion of semi-natural woodlands, for recreational value 

and wildlife habitat. 

• Beautification of highways and other public lands.

• For Developing nations (G77), Increased GDP and exports potential to Developed 

nations (G20).