An Inconvenient Truth – regulatory response ash to waste

An inconvenient distraction: A vexatious type can make it difficult for success and a friend points out ‘a difficulty’ and you find yourself in a position of lampoon. The issue is should what you report be directed or controlled. To illustrate we published, 13 December 2014, “Maybe the question is better put this way: Plants don’t need carbon, soils do. Biochar is but a hazardous waste from pyrolysis”. This was not a position statement; it was outlining a problem of perception promoted by deniers that you should think of it as an ash.

On 13 December 2014 we also wrote – “The quandary for most of us when we express our thoughts is we can be regarded as excessive or obsessive for seeking out an agenda”. In this story CO2Land org had an agenda – to make one aware. To be aware that moves were afoot overseas to have ash declared ‘waste’. The below the radar application if you want to make more of it.

What is difficult to accept is that the catalyst for this change was the coal fired power stations in the USA. The story unfolds as:

On 22 December 2014, http://www.wastedrive.com published that – Feds: Coal ash classified as solid waste – by Nicole Wrona. This followed a story published by Dina Cappiello The Associated Press on 20 December 2014 through the Casper Star Tribune. Outlining: “The Obama administration on Friday set the first national standards for waste generated from coal burned for electricity, treating it more like household garbage rather than a hazardous material.”

To directly quote wastedrive.com – on the affects of the new regulations:

Dive Brief:

  • New federal standards will categorize coal ash as a solid waste instead of considering it a hazardous material.
  • The classification was determined despite pushback from environmentalists. The regulations do not extend to shuttered power plants, but would apply to closed ash ponds where utilities are active.
  • States will continue to ensure standards surrounding the waste are followed. The federal government would have taken over enforcement had the decision turned out differently or if the waste had been dubbed “hazardous.”

Dive Insight:

  • The Environmental Protection Agency (EPA) said it would protect citizens from the risks associated with coal ash waste sites while pledging to hold corporations who operated ash waste sites accountable. The rules are expected to increase leak monitoring, control blowing dust, and to require companies to publicly release test results.
  • Waste Management had predicted a substantial amount of growth for the company if the rule were to be approved. The ash waste stream is larger than the waste stream currently handled by the company.

Recommended Reading:

Now back in Australia the Carbon Farming Initiative is sympathetic to bio char from pyrolysis. The difficulty is the regulations that are responded to by the EPA of each state. The question now is will this USA EPA ruling be followed in Australia? Will bio char too be cleared of any stigma of a perception either implied or express that it is an ash – should be leave this to experts?

It is not that simple. As we said previously what is needed to be truly progressive is the commitment to investigate the potential. Do we need a senate inquiry to get that moving? We see some wonderful benefits where multiple products could be extracted from just a simple classification change being the catalyst.

The facts they say: About the poles and wires selloff.

The facts they say: About the poles and wires selloff. Revenue is a weird thing and it is all about your plan. That is short term gain verses long term revenue. What can get missed on that point is what is changing around you can be a bigger factor than the emotion around the change. That factor is technology and the transition strategy to survive – to survive you need to transform how you do your business or get pushed aside. The other issue is not only the technology challenging you it is the skill required to understanding how to take the opportunity to exploit the rise of the technology. These comments are as important for Energy Network companies as they are for banks, the financial services industry, sales, commodities traders, agribusiness and manufacturing. Dare we also say, political response, too.

One group we know of, http://www.solarcitizens.org.au has been active in seeking “to change the game”. They are referring to the practices and the behaviour of companies that run electricity networks. They are targeting those that control how we get our electricity and are encouraging concerned parties to participate, by way of a submission into the Australian Senate Inquiry, and submissions closed 18 December 2014.

The Senate is looking to spotlight whether it is fair that power prices have surged across the board in Australia. Whether it is because of the unnecessary upgrades to the electricity network, known as ‘gold-plating’ of the grid. What is being investigated, and you can see the full terms of reference for the Senate Inquiry here:

  • Whether energy companies have misrepresented information to the energy regulator for their benefit
  • Allegations of price rorting by companies
  • Whether current network arrangements discriminate against homes and businesses who generate their own power, and
  • The possibility of establishing an independent body to investigate and prosecute poor behaviour.

Those that say the plan to sell off the poles and wires claim privatization leads to higher prices, reliability of supply declines, maintenance is avoided with disastrous consequences, and what could the most persuasive of all: Once it is sold that revenue source is gone!

Then we read ABC News 21 December 2014 the story headed New Tas energy plan will drive down power prices: Government.

“A new energy plan for Tasmania will result in lower power prices, the state’s Energy Minister says.

The Government is inviting Tasmanians to have their say on its new draft energy strategy.” Public submissions are open until mid-February.

This is said to be an opportunity to attract new business to Tasmania and for better ways to utilise the state’s existing energy assets.

They also moot the possibility of a second Bass Strait to the mainland interconnector and expanding their hydro generation output by 10 per cent.

They also quote the Energy Minister Matthew Groom:

“This is about a mindset shift, this is about recognising that the energy businesses are primarily there to deliver energy advantage to Tasmanians, and central to that will be the lowest possible power prices that are genuinely sustainable……………..We saw power prices increase by more than 65 per cent over seven years……..That’s unacceptable and under this new strategic direction, it cannot happen again.”

The strategy includes more work on encouraging competition, with the Government still open to selling Aurora Energy’s customer book.

We should say the truly progressive part is the commitment to investigate the potential of using forest residue for biofuel.

CO2Land org has empathy with the cause. That said we should realize the poles and wires (Electricity Networks), historically are a 130 plus years old system. Some did not have the network system for some times after that, and some still do not have access. It also follows that regulators and those consulting to the companies were constantly expecting continuous load growth on the network. The evidence is that is not now happening and predictions are it is now a very different market. In our opinion anything that can be gamed is a market and will be treated as a commodity by the players. The selloff of the networks is evidence also that the predominately state owned utility companies want to divest themselves of ‘services’ and the new owners will have the reign to treat all as a commodity. If you do not believe us – think of the new rules coming into play referring to ‘Cost reflective’ for network charges.

Are the rules setters correct? One argument that has gone for some time – at least since 1996 that we are aware of, is the fairness of cross subsidies within the networks charges being to transfer cost burdens from the sparse population region to the concentrated population region (country and city users). If you think of what the Australian Energy Regulator (AER) is saying and the Australian Energy Market Commission (AEMC) is saying it now it is enough it must change. Where it gets ugly is when you ask is the issue a question of to whom is the favour for – Business as usual and the rent seekers, or those that are bold and go forth with the transition to change.

Again, that all leads to the need to develop new business models and that need will be regardless for the reasons we started in para 1 of this discussion – the factor of technology.

A very likely model is that energy networks will adapt and change, and part of our believe of this is there will still be a need for some form of infrastructure to deliver the power. It will not matter is it is micro grid or long runs of poles and wires. The infrastructure will have new build, maintenance and upgrade needs. And, who pays? You do no matter what is the model.

A Quandary – Nit-pick or constructive critique of CFI ERF

The quandary for most of us when we express our thoughts is we can be regarded as excessive or obsessive for seeking out an agenda – the agenda to change that might be procedurally correct, but fails to address the main issue. For instance the Emissions Reduction Fund – Irrigated Cotton draft determination and associated documents (the consultation process closed 12 December 2014). The main issue, as with other Carbon Farming Initiative methods, is that it is harder for leading growers to be rewarded, as there is no recognition of past improvements.

In the main we found the draft cotton determination, draft cotton explanatory statement and the draft cotton equations, as is, to be sound. It has its process thought through well enough and while we could say some of the flow could be improved any further submission could appear to be nit-picking as opposed to constructive criticism.

Was there room for constructive critique? Yes, but these are areas we might like to adjust the eligibility criteria. Also a little tweaking of what appears too broad in the descriptions. They are areas that could be argued as wrong, but they really are areas for the regulations or legislation to be adjusted. When you access the process of a determination your role amounts to comment on the process that is laid out in the draft determination. It is not the appropriate place to express frustration with the rules. Expressing your frustration is really the domain of the politics.

Being we mentioned the ERF – Irrigated Cotton draft determination, we should let you know what is it about. The first thing is it is the opportunity for growers to obtain certificates called the Australian Carbon Credit Unit (ACCU) under the Act 2011 called the Carbon Farming Initiative (CFI). The reference to the Emissions Reduction Fund (ERF) is part of the CFI Amendment Bill 2014. The fund is designed to help reduce Australia’s emissions by providing and incentive for business, landowners, state and local governments, community organization and individuals to adopt new practices and technologies which reduce emissions. The ERF does include incentives for business activities and farming practices. To find more go to: http://www.cleanenergyregulator.gov.au .

A bit more about our thoughts on the determination and consultation on the Draft Energy Reduction Fund: Irrigated cotton.

  • The ‘system’ is for irrigated cotton growing mainly in Queensland, NSW and Western Australia.
  • The incentive is to encourage Nitrogen fertiliser use efficiency and efficiency is a measure of the ratio of lint yield to nitrogen applied via synthetic fertiliser (kg lint yield per kg N).
  • An increase in nitrogen fertiliser use efficiency is equivalent to a decrease in emissions intensity from synthetic fertiliser use in irrigated cotton (t CO2-e per kg lint yield).
  • Because nitrogen fertiliser use efficiency is calculated using both nitrogen fertiliser use and yield, credits for emissions reductions can be generated by reducing fertiliser use while maintaining or increasing yield, or by increasing yield without a corresponding increase in fertiliser use. This approach also ensures that credits for emissions reductions cannot be generated through a contraction of yield without a reduction in fertiliser use.
  • The draft Determination therefore enables irrigated cotton growers to adjust nitrogen fertiliser rate according to paddock yield potential in the project area, provided that nitrogen fertiliser use efficiency increases.
  • There is support for a broad range of activities to improve the efficiency (reduce the emissions intensity) of fertiliser use in irrigated cotton, including activities to improve lint yield without a corresponding increase in nitrogen fertiliser application rate, and activities to modify the rate, timing, method and efficiency of nitrogen fertiliser application.
  • Proponents have the flexibility to select management actions that suit their individual circumstances.
  • In this draft, cotton is the only crop in the production system eligible for generating credits for a reduction in emissions from synthetic fertiliser use.
  • Emissions from other crops grown in rotation with cotton, with the exception of green manure, are excluded from this draft Determination.

What is Synthetic fertiliser?

Inorganic are sometimes called synthetic fertilizers since various chemical treatments are required for their manufacture.

Synthetic fertilisers do not include solid or liquid organic products created using waste products of other industries that do not meet these labelling and minimum nitrogen content standards. For example, synthetic fertilisers do not include manures, such as poultry litter or beef feedlot manure, or mulches and composts, such as composted ginning trash.

What is a Green Manure?

A green manure is a legume that is planted in a paddock to improve the soil for a subsequent cotton crop. A green manure crop is not harvested and the above ground growth is returned to the soil. Examples of green manure are vetch, faba beans, chickpeas and annual clovers. Non-legume crops which require nitrogen fertiliser are not included in the definition of green manure

What is Organic fertiliser?

Organic fertilizers are usually (recycled) plant- or animal-derived matter. The main “organic fertilizers” are, in ranked order, peat, animal wastes, plant wastes from agriculture, and sewage sludge.

If you picked up on peat as a organic fertilizer and the reference that it has no nutritional value to the plants, but improves the soil by aeration and absorbing water. You might ask why is biochar not a fertilizer?

Bio char

It gets down to two issues:

  1. Bio char is described as a sequester of carbon and as such binds carbon to its properties.
  2. So broad is the definition that it is seen to be the product of ‘burning’.

The later point is where it gets interesting and frustrating. This is because the technology for fine chars is thermochemical decomposition of organic material at elevated temperatures in the absence of oxygen. In another speak, Bio char is created by pyrolysis of biomass.

We do not argue that is a fertilizer. What we argue is it is an agent to improve the efficiency of fertilizer use.

Another potential for confusion is linking soil carbon to bio char. Soil carbon is a condition and bio char is a conditioner. If you think one is the constant and the other the agent for change it makes sense does it not?

That leaves the issue of if it is helpful why is it excluded from the incentives?

Maybe the question is better put this way: Plants don’t need carbon, soils do. Biochar is but a hazardous waste from pyrolysis, looking for a below-the-radar application. Do we have that application? But that is for another discussion and a case study!

The leap of faith to a low-carbon future – Engineers Australia

The platitudes no longer cut it, the cries that the scientists are wrong is being proved wrong. Since the carbon pricing signals were removed from our (Australia’s) trade all the numbers are going backwards. Our energy intensive industries are increasing emissions (Hugh Saddler wrote, 2 December 2014) “the recent emissions trend ‐ since the last CEDEX® report with data to June 2014 – is an increase in total emissions of 2.2 million tonnes CO2‐e, with a large increase in electricity generation emissions and a smaller increase in petroleum emissions. Then on 3 December 2014 the national newspapers reported from the accounts data released that day – we are officially in an income recession. It follows our manufacturers are in decline, our commodities crisis is real and our trading partners have been stockpiling to ride out the storm – the financial storm that affects jobs, the economy and the deniers ability to hype hysterical nonsense about contributing to environmental fraud.

Outside of science, is anyone of note is taking this whole business of a low carbon future seriously? Yes, the banks are, and so are our engineers. The engineers’ story is:

Engineers Australia commits to designing the quantum leap to a low-carbon future. Willow Allento on 27 November 2014 published,

The interview write up and policy highlights are here: http://www.thefifthestate.com.au/innovation/engineering/engineers-australia-commits-to-a-low-carbon-future/70016

“Around 100,000 of Australia’s brightest innovators and designers and operational experts committing to a climate change policy and sustainability policy that is binding within the professional code of ethics, that’s a game-changer. Interviewing Dr Cruikshanks-Boyd this morning and reading the policies again and again [pithy, pointed and absolutely game-changing] I keep thinking – “This is the quantum leap we needed to escape the turmoil of the policy lens and have concrete action that really changes everything substantially.”

Can engineers save the planet? I reckon it’s tremendous they’ve set themselves loose on the opportunity to do so!

Engineers Australia has put sustainability and climate change mitigation at the core of the profession, with the formal adoption of two new policies and a series of events on opportunities.”

We read the policies were also peer-reviewed by 25 external bodies. So it is not insular it is outward looking to establish the practice and engage. They are actually committed to put sustainability up front engage with clients to promote the business case. We further quote:

“As engineers we have a role to play not just in innovating, but in selling the business case.

Regarding the property sector, he said engineers must make clear to clients there is a market for sustainable buildings, and use lifecycle cost analysis to demonstrate the cost-effectiveness of taking a more sustainable approach and gaining “market edge”.

While the policies were passed unanimously, there was robust debate, he said, particularly around the climate change policy, with a significant minority of members opposing the climate change policy on principle initially. He said given the organisation has about 100,000 members, all of whom were consulted on numerous drafts, a percentage of sceptics was to be expected.

On an organisational level, the policies mean Engineers Australia is throwing its combined weight and expertise behind efforts to transition to a low-carbon energy future, reduce fossil fuel dependence, design within a lifecycle costing framework, look for industrial ecology opportunities in managing waste, and prioritise renewable resources wherever possible.

There are a lot of engineers associated with the fossil fuel industries, and I thought we would strike problems with them during the debate [on the climate change policy]. But the more balanced members in that industry recognise it must be dealt with, so we resolved that through the simple addition of a statement that there would need to be a transition from fossil fuels,” Dr Cruikshanks-Boyd said.

At this point CO2Land org notes a fundamental point for getting anything done, as it is possible to get polices of government changed through professional lobbying and advocacy, the real impact happens at the individual level. We also learnt, and we admit we too are learning, sustainability has been one of the four pillars of the Engineers Australia organisation binding code of ethics since 2010; to continue the quotes:

“While Dr Cruikshanks-Boyd is disappointed in the current “entrenched situation” regarding government policies on climate change and sustainability, he said Engineers Australia would ensure the new policies and the views they represent were well known to government.

He also said that the profession was in a position to leverage enormous positive change regardless of government policy through placing its focus on achieving sustainable outcomes in all they do. Just as there are negative tipping points that lead to collapse, there are positive tipping points that lead to exponential progress”.

A fundamental point of our mortality is also made in that professions live longer than politicians. We assume what was meant is that politicians are most concerned for themselves and professionals for their legacy. Without too much more waffle below now is more direct quoting from the article:

Some of the key statements in the Climate Change policy include:

Building upon a long history of Engineers Australia policy development, and as the largest technically informed professional body in Australia, Engineers Australia advocates that Engineers must act proactively to address climate change as an ecological, social and economic risk.

Engineers Australia is committed to natural resources policy reform to adopt full life-cycle analysis, including the pricing of resource use externalities, to ensure responsible resource allocation decisions.

Engineers Australia will work to facilitate statutory, regulatory and policy reform such as progressive Renewable Energy Targets, incentives to promote renewable and sustainable energy technologies, energy efficiency standards, transport emission limits, and incentives/disincentives to reduce dependence on fossil fuel sources. It is recognised this is part of a transitional process.

Engineers have an ethical responsibility for, and play a key role in, limiting atmospheric greenhouse gas concentrations, through transformative change and innovation in engineering education, and practice.

Reduction of the emission of greenhouse gases to the atmosphere associated with engineering activities should be accorded urgent priority in engineering endeavours.”

Some of the core statements in the sustainability policy include:

Our Code of Ethics requires us to develop engineering solutions that repair and regenerate both natural and social capital, while maintaining economic health.

Engineers Australia acknowledges that to achieve sustainability outcomes requires transformative change in business practices, lifestyles, and in the way resource allocation decisions are made.

Fundamental to this change is the recognition that a healthy economy is underpinned by a healthy environment and respect for all life on earth.

Engineers Australia and its members commit to ensuring all relevant stakeholders are consulted, and that open and regular reporting of progress towards delivering sustainability outcomes forms a fundamental component of engineering practice.

This Sustainability Policy is supported by an Implementation Plan, which articulates specific changes to engineering practice that arise from adoption of this Policy.

Specific sustainability considerations to be applied to engineering practice (policy and projects) include (not in priority order):

  1. The use of resources should not exceed the limits of regeneration.
  2. The use of non-renewable resources should create enduring asset value (everlasting and/or fully recyclable), and be limited to applications where substitution with renewable resources is not practical.
  3. Engineering design, including product design, should be whole system based, with consideration of all impacts from product inception to reuse/repurposing.
  4. Product and project design should consider longevity, component re-use, repair and recyclability.

Eliminating waste should be a primary design consideration. Unavoidable waste from any one process should be examined for recycling potential as input to another productive process.

The rate of release of any substances to the environment should do no net harm, and be limited to the capacity of the environment to absorb or assimilate the substances, and maintain continuity of ecosystem services. In all instances, such releases should be lifecycle-costed and attributed.

Proactive and integrated solutions are preferable to reactive, linear, “end of pipe” solutions, such that there is a net sustainability benefit.

In circumstances where scientific information is inconclusive, or incomplete, the precautionary principle and risk management practices should be applied to ensure irreversible negative consequences are avoided and not passed as a liability to future generations.”

Co2land , as you would expect is pleased to see Engineers Australia is throwing its combined weight and expertise behind efforts to transition to a low-carbon energy future. Our only point that could improve that position were they say ‘reduce fossil fuel dependence, design within a lifecycle costing framework, look for industrial ecology opportunities in managing waste, and prioritise renewable resources wherever possible’, we would prefer the words ‘eliminate fossil fuel dependence’. Sometimes the simple wording is more meaningful!