1 Kelly, Shaheerah

From: Afro-Asian Energy Development C onsortium Inc [aedinc@gmail.com]
Sent: Monday, December 30, 2013 8:24 AM
To: Kelly, Shaheerah Subject: AED Response to EPA(epa-eTransmitta l-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 co nversation and email of 9th Dec 2013 regarding the subject public notice inviting comments for the :

1. The Best Available Contro l Technology (BACT) determinations 2. The effects, if any, on Class I areas; 3. The effect of the proposed facility on ambien t air quality; and

4. The attainment an d maintenance of the NAAQS.( National Ambient Air Quality Standards)

AED Comments and Response :

AED (Afro-Asian Energy Development Consor tium) 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 un ique 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 bi omass 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 pump able and Low Cost Petroleum Fossil Fuels

Substitute.

BWF technologies addresses the challenges in volved in (1) economical biomass transport and (2) has superior combustion attributes that are (3) more air quality standards compliant compared to raw biomass tran sport and combustion characteristics.

GHG emissions reduction* are estimate d to be 30% and or more considerin g 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% reduct ion* in gross fuel utilization costs. 

## (*order of magnitude-site specific)

Another major impact will be immens e 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 appr opriate step for which we will appreciate your early response.

Thank you.

Bhasker Patel

Chairman

AED3 

### 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 Bioma ss Collaborative Worldwide “HBCW alliance of industry, educational institutions, environmental and government agencies, and NGO’s
nations.

Sponsored by a group of concerned scientists, techn ocrats,

e ntrepreneurs and investors, the Collaborative agencies and industry partners to address the issue s 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 h alt
and/or reverse deforestation and developme nt of biomass energy sources worldwide.

By addressing the urgent global demand for indigeno us 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, techn ocrats, ntrepreneurs and investors, the Collaborative works with other lending agencies and industry partners to address the issue s 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 h alt
and/or reverse deforestation

, and encourage sustainable management

nt of biomass energy sources worldwide.

By addressing the urgent global demand for indigeno us 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 gl obal 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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# '		 # 12345#BiomassAll types of Agro Waste &Agro-byproducts(High moisture carbonaceous materials)~2500 Kcal/kg(Controlled)-Deoxidization-Dehydration**Biomass conversion toliquid format (Pumpable}A Renewable Superior Fuel(Non-hazardous, non toxic & non in-flammable)~5000-7000 Kcal/kgSubstitute for Fossil Fuel (Fuel Oil)(BWF Co-firing option reduces significant SOx,NOx,ROx)**Patented ProcessRaw BiomassAgro WasteBiomassWater FuelFormulationVolumetric VolumetricFor Interim study onlyRestricted /ConfidentialBWF Conversion Unit's Area(Orange shaded) needing R10/23/2010 support For Demo Unit's Thrust areaModular Commercial Demo Plant Configuration AnalysisDraft-1 20th Oct 2010For Interim study onlyPlant-APlant-BModule(Model)= 5 MW Conventional PlantGrid system(specific)Biomass to BWF(300 tpd)3.5 MW ExportConversion Plant-B(120 tpd)1-1.5 MWupto~ 1 to 1.5 MWBWF-->to BWF Plant-B(Heat Exch/Ancillaries etc)(sufficient +/-)** Biomass FuelSteamBoiler STG** Volume / mass** QualityCo-Generation** SteamBlack BoxVolume&quality** Resource Specific** Biomass Feedstock Preperation Unit** Raw Biomass : Storage , Handling , crushing , micro-sizing,feed-Blending** Thermal Characteristics(? ?)** Volume / ** mass (??)Part BWF quantity to be soldaedinc@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 CO 2 , either during processing or by end processes, part of the CO 2 produced sequestered in geologic formations or deep in the o ceans. Some of the
as CO 2 , increasingly designated as a “pollutant.” With b iomass fuel produced is consumed by the next generation of fuel crops planted to replace the biomass

energy . This is now an environmentally acceptable practic e, resulting in a “net carbon footprint” of zero.
Biomass can be considered to be a younger

Solution :

Biorecycling of all CO 2 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;



## BioSequestration TM 

## 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 BioCoal TM

Ash & Sulfur Free Carbon Neutral (ASFCN) Renewable
Low Cost Petroleum Fossil Fuel s 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 recove red easily and used for enhanced oil recovery or sequestered in geologic formations or deep in the o ceans. Some of the carbon will end up in the atmosphere , increasingly designated as a “pollutant.” With b iomass 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 practic e, 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 plan ting
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 CO 2 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

)



### Program s 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 CO 2 produced is consumed by the next generation of fuel crops planted to replace the biomass converted to clean . This is now an environmentally acceptable practic e, 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 plan ting

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 tha n maximum tree density.

• Public highway rights-of-way. (Most access/ loops currently have room for 20~50 cottonwoods, silver maples, box elders or green ash es, without infringing on visibility or maintenance.)

• Wind breaks

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

• New, low-density residential areas, where homeowne rs would agree to let designated trees grow for at least 20 years, and th us 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 investme nt 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 expen se of the bio-coal consuming companies, to be passed on to the end users. The cost of the electri city, as an end product, would still be less than that of electricity by solar means or windmills. Th e 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 CO 2 sequestration schemes. Regulatory agencies (EPA, s tate depts. of natural resources (DNR), etc) and volunteer environmental groups coul d 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 qu antity, for any other funded purpose. The program may augment private or government investmen ts 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 b io-coal burned will have accumulated a net-zero carbon “footprint.” Where the trees are n ot harvested and continue growing beyond the required 10-year basis of approval, they will continue turning CO 2 into trunks and roots, and the bio-coal burned will be developi ng an increasingly net-negative carbon footprint! What could be “greener?”

Advantages To all nations- Worldwide:

• The obvious: Delayed elimination net CO 2 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 (count ry specific).

• Development of future biomass energy (fuel wood) r eserves, 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 w oodlands, for recreational value
and wildlife habitat.

• Beautification of highways and other public lands.

• For Developing nations (G77), Increased GDP and ex ports potential to Developed nations (G20).