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, 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 – 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.


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: .

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!

Regulatory Response – Strengthened in NSW and Qld

Resource recovery is a hot issue – pun intended – the problem is most that say they do have methods rarely have solutions at a commercial scale. Often the excuse is the rules are at fault. There may be some truth in that claim even if in the main it is the systems that are at fault for offering concept grants as opposed to solution incentives in Australia that dominates the innovation space. If you think we are saying that at least one iconic institution might have a reason to delay innovation. That is not what is being said: It is being said regulatory response mechanisms are in need of a rethink. In particular we find evidence that regulatory response with policy on reuse, recycling, reprocessing and energy recovery, is not necessarily consistent with the most efficient use of the recovered resources opportunity.

As we seem to doing so regularly lately we can report NSW and Queensland are doing something about the rules around resource recovery that do not weaken the intention of the rules, and at the same time they encourage a more flexible approach to offset harm. It is done with new policy positions being taken that alter the regulatory response to issues. This change means the EPA of both states are responding to solutions that says show me it works and we will listen as opposed to it does not fit the guidelines sort of approach.

It is true some in our society just want to exploit with disregard to good environmental practice and some media might even exploit our emotions in the interest of their own agenda, and strong regulatory responses remain in need to counter same. For example we found a story of a notice that the NSW Environmental Protection Agency (EPA) has issued a clean-up notice to a fuel transport company in relation to environmental issues at its depot. The NSW EPA found “that fuel or a similar material had leaked or been pumped onto the ground” at the site. According to NSW EPA the clean-up notice requires Xpress “to immediately stop receiving or removing any waste and contain any contamination within bunds on site”. Source NSW EPA’s media release on 3rd September 2014. Clearly the regulatory response was appropriate for this matter.

Staying on NSW rules, on 10th September 2014, the Office of Environment and Heritage announced it was rethinking its approach to its major projects policy in NSW. The benefit said is it is a more flexible approach aimed to put an end to case-by-case negotiations by providing a standard method for assessing impacts and determining offset requirements. The new policy is likely to be followed by additional changes to biodiversity protection arrangements in NSW, which are currently undergoing a comprehensive review.

Also related to this policy approach is a Legally-backed accreditation scheme that is the offsets policy for major projects will be accompanied by a new accreditation scheme for consultants who administer the policy’s supporting framework for biodiversity assessment. The accreditation scheme will be developed over the next 18 months, while the new policy is being implemented. The policy will be given formal effect through legislation after the 18-month interim phase, and the accreditation scheme will also have legislative backing. During the interim phase, consultants using the assessment framework must be accredited under the NSW BioBanking Scheme, in accordance with s142B of the Threatened Species Act.

Importantly to above is that it has planning protections that do not allow empowered consent authorities to allow economically significant projects to proceed with watered-down offset obligations if normal requirements would have affected their viability. In other words discounting is not allowed. However, the policy will allow credits to be earned from ecological rehabilitation. The NSW Government’s response to public comments on the draft version says it is also open to allowing “other forms of post-development rehabilitation” to earn biodiversity credits.

NSW biodiversity offsets policy for major projects (NSW Government, September 2014)

Framework for biodiversity assessment

Report of submissions on the draft policy (NSW Government, September 2014)

Individual submissions on the draft policy


Now to Queensland where the media reports would have you believe there are no rules. We read that on 2nd September 2014 the Queensland companies are now subject to pay five times more for some infringement notice offences, and the Department of Environment and Heritage Protection can now issue notices for a wider range of infractions. The Queensland Government introduced the changes, which took effect from September 1, through a new State Penalties Enforcement Regulation. Several offences under the Environmental Protection Act will now incur an infringement notice penalty of $11,385, up from $2,277:

  • contravening an environmental protection order;
  • carrying out an activity without an environmental licence (known as an ‘environmental authority’ in Queensland);
  • failing to comply with an environmental authority condition; and
  • failing as the holder of an environmental authority to ensure compliance with its conditions.

That later is most interesting as it makes it much more difficult to outsource your responsibilities.

The report goes on to say: Infringement notice penalties for most other offences have more than doubled, with many rising from $2,277 to $5,692. New Environmental Protection Act infringement notice offences include:

  • failing to provide a financial assurance before undertaking an activity that requires an environmental authority or before engaging in small-scale mining (penalty of $11,385);
  • not complying with conditions of a licence ($11,385);
  • ailing to comply with a notice ($8,538); and
  • unlawfully causing material environmental harm ($8,358).

Failing to comply with a condition of approval in breach of the Waste Reduction and Recycling Act will now incur a penalty of $11,385 (up from $2,277). Penalties have also risen for infringement notices issued under the Water Act and several other acts. In 2012-13, the most recent year for which statistics are available, the Department of Environment and Heritage Protection issued 280 penalty infringement notices for environmental and nature conservation breaches, a big rise on the 76 notices issued in the previous year.

You see, it will not just disappear – the regulatory response continues.

from Gonna Do and Talk About to – the Paradigm Shift needed

A discussion group, Sustainability Professionals, is having a long running discussion on the need for a paradigm shift in how we think and act. After CO2Land org posted, 22 April 2014, an Ecoprofit Management Newsletter item on World Meters – Population (pop increase 655,000 net in 3 days). It started a thought process that indicated we complain too much, and do not address the more important aspects – the real dangers of accepting the status quo. How do we go from gonna do and talk about to formulating the tools for shifting our mindsets?

We all know about the importance of educating our children, and use well worn terms like: they are our future and history shows us the way. But, what faces us now is unprecedented in human history, and if adults don’t act there may not be a future for humans. It is therefore foreseeable the paradigm shift needs to have an education component and have:

“INTERNAL TRAINING IN THE ADULT SECTORS on all issues explaining what sustainability is all about. This is sorely needed. We need to work education and training in these issues into the corporate and government structures. They are so risk management oriented. So let’s take a different approach. We need to address and train in the ROI across the board on what sustainability and bringing in why ecosystems working together is key. In the corporate and governments culture employees and all of management must take courses on line such as sexual harassment in the workplace, ADOBE training, how to deal with difficult co-workers, etc. WHAT IF we added:

Sustainability Planning
Sustainability Has a History
Planning Policies for Government and Business
Introduction to Action Initiatives
Waste Streams for Consideration
The Plan: Design and Implementation
Social Responsibility
Definition and Benefits
Guidelines for Transparency for Your Stakeholders
Basic Training of Renewable Energy
Leadership and Administration
Green Building / Systems/Materials
Green Building and Renovations Defined
Energy Efficient Systems
Driving Forces for Change
Risks and Benefits of Green Construction
Green Construction Risk Assessments
Green Certification and Standards
Green Certifications and Standards
Energy Ratings and Audits Defined
Certifications and Energy Standard Case Studies
Green Building Adding to the Bottom Line
Green Supply Chain Management
Leadership, Assessment, and Life Cycle Analysis
Environmental Costs and Benefits
Guiding Your Company’s Plan
Success Story
Waste Management
Waste Concepts are a Part of History
Tracking and Transporting Waste
Solid Waste Principles
What Can Be Recycled?
A Plan to Begin Managing Your Waste
Contractual Guidelines are a Must
Transportation / Green Fleet Management
Introduction to Green Fleet Concepts
Alternative Fuel Overview
Green Fleet Case Studies
Green Transportation Saves on the Bottom Line
Sustainable Purchasing Practices
Concepts in Green Purchasing
Involve Your Purchasing Department in Sustainability
Green Cleaning Practices
Becoming Familiar with Green Cleaning Concepts
Changing Your Cleaning Practices
Water Conservation
Efficient Use of Your Water Resources
Learn about Water Conservation From The Health Care Industry
Water Filtering Options and Storage
Preventing Stormwater Pollution
Environmental Accounting
General Environmental Management System Guidance
International Standards
Environmental Management System Implementation
Planning for Environmental Accountability
Tracking Carbon Emissions
Food Service
Waste and Recycling in Food Service
Greener Food Service Practices
Renewable Energy
Introduction Renewable Energy to Government and Business
Identifying Local Renewable Resources
Waste to Energy Saves Money!

So, wouldn’t this type of internal training help to effect change, catapult the forming of internal committees and cause departments to change business practices? I think it would. This is available now and courses include core competency testing, narration and are of high quality. Place these on corporate and government websites globally, and make them part of compliance internal training programs then the wider public can make better and more ‘informed’ business decisions. “. Quoted is Kerry Mitchell from Green Education On Line/ Berkshire Hathaway Home Services.

Maybe she has nailed it, a big like from this end. Now how do you get our pollies interested?

The business of BIOCHAR

The problem can be called “Marketing Myopia”, and the claim was made in relation to the uptake of BioChar. Quickly scanning to understand what was meant by that term the Business Dictionary was most helpful. Marketing Myopia – A short-sighted and inward looking approach to marketing that focuses on the needs of the company instead of defining the company and its products in terms of the customersneeds and wants. It results in the failure to see and adjust to the rapid changes in their markets.

The concept of marketing myopia was discussed in an article (titled “Marketing Myopia,” in July-August 1960 issue of the Harvard Business Review) by Harvard Business School emeritus professor of marketing, Theodore C. Levitt (1925-2006), who suggests that companies get trapped in this situation because they omit to ask the vital question, “What business are we in?” Read more:

So: What is the business of BioChar? It can elicit a number of different answers that can supply at least 11 different industries. What might change is the name that suits the industry. For instance it may be called Bio-Carbon for industrial applications, and can be called carbon black, or graphite.

Applications in industry can be:  Insulation, Air decontamination, Decontamination of earth foundations, Humidity regulation, Protection against electromagnetic radiation (“electrosmog”), Exhaust filters, Controlling emissions, Room air filters.

  • It can be part of Industrial materials: carbon fibres, plastics.
  • Its use in Electronics: Semiconductors, batteries.
  • Use in Metallurgy: Metal reduction.
  • In Cosmetics: Soaps, skin-cream, therapeutic bath additives.
  • In Paints and colouring: Food colorants, industrial paints.

In Energy production:

  • Pellets, substitute for lignite.

In Medicines:

  • Detoxification, carrier for active pharmaceutical ingredients.

In apparel and footware:

  • Fabric additive for functional underwear, Thermal insulation for functional clothing, Deodorant for shoe soles.

In sleepware:

  • Filling for mattresses, filling for pillows

For protection:

  • Shield against electromagnetic radiation.

Then for applications of decontamination and waste handling:

  • Soil additive for soil remediation (for use in particular on former mine-works, military bases, radio transmitters sites and landfill sites)
  • Soil substrates (highly adsorbing, plantable soil substrates for use in cleaning waste water; in particular urban waste water contaminated by heavy metals)
  • A barrier preventing pesticides getting into surface water (Sides of field and ponds can be equipped with 30-50 cm deep barriers made of biochar for filtering out pesticides)

Treating pond and lake water (Biochar is good for adsorbing pesticides and fertilisers, as well as for improving water aeration)

  • Use as or in a Biomass additive, Biogas slurry treatment, Active carbon filter, Pre-rinsing additive, Soil substrate for organic plant beds, Composting toilets.

Then for applications of the treatment of drinking water:

  • Use in: Micro-filters, Macro-filters in developing countries.

Then for numerous Agricultural purposes it can be used or invaluable for:

  • Silage agent, Feed additive/supplement, Litter additive, Slurry treatment, Manure composting, Water treatment in fish farming, Carbon fertiliser, Compost, Substitute for peat in potting soil, Plant protection, Compensatory fertiliser for trace elements.

But you will say some of these are activated carbon. What is the difference? According to Achim Gerlach and published in ithaka (ithaka is also the reference to the 55 uses of biochar above): “Activated carbon = biochar – Generally speaking, all activated carbons are originally biochars. Active carbons are however “activated” using acids or hydroxides or 900°C water steam. In doing so, their specific surface area increases from app. 300 m2/g to over 1000 m2/g. Activated carbon is 5 – 10 times more expensive than simple biochar, so it is possible to use 2-3 times the amount of biochar to achieve the same result – whether with regard to digestion in cattle or in a sewage treatment plant. As activated carbon is for the most part produced without adequate controls in South-East Asia or South America, the eco-balance often leaves a lot to be desired. Biochar by contrast is produced from controlled, locally grown raw materials using controlled production methods. There is no real difficulty involved in producing activated carbon from biochar.”

This still does not answer the ‘what business are we in’ question. It follows that you define your product by way of what it does. But in business it is a definition of purpose for whom the business does serve is how you tend to answer ‘what business are we in’. Now consider the question of whether your product is to be considered as sourced from a co-product, or a by-product. Looking at this logically, it could be seen that the former broadens the scope of available uses that go beyond considering it a variable price component. A by-product might not be a business, and is more likely to be treated in a similar way to waste and less likely to be refined.

If you understand business you will know that the value model assumes you will seek what the market will bear in terms of price and volumes. A by-product only seeks to dispose of the ‘waste’ at a level that mitigates the cost of production. The issue then becomes how do I guarantee a quality product if it is not priced correctly.

Therefore a successful business proposition will have the price set in terms of purpose, price of bioenergy plants and the need for the plants to be tweaked so as to be priced accordingly and as a minimum must have a value sufficiently above its inherent energy value for the use of, and, or the market intended. Why, your business customer base needs to be accommodated to broaden the available uses, and that will be more than agricultural soil amendment.

So what is the business your in? Conventional wisdom suggests you need to be “Cool”, have a willingness to collaborate with end users, understand the proposals of purchasing chars from many sources, spend as much time & effort in researching/ formulating/inoculating to get the biology balance right, and set yourself up as best practice biochar ‘finisher’.

What is a finisher? John Christy asked the same question on LinkedIn, and as best as CO2Land org can find is: A biochar ‘finisher’ is someone who augments it, packages, and distributes. All they want is a price and a place to sell to, and focus on energy production. Is there anyone doing this or willing to consider at this point. Christy continues saying “Offtake agreements are needed now in order to get the financing for these projects. Ideally we want a 20 year agreement to take a minimum amount of biochar, meeting certain criteria….or a memo of understanding would help”. Maybe, that is the tact your business can take too, to satisfy the customers need!

This post does not attempt to address the production or the farm scale platforms for biochar use other than mention some of the factors of the business that will affect how you will function as a business. Country to country the price and composition of biochar will differ. Like all product, the material inputs is important. Here in Australia we have a forestry industry that can provide feedstock from floor waste and we can calculate the manufacturing cost of biochar from that source, other countries might not have such a luxury and have other sources of feedstock materials. The point is well made by John “There is much to be done to define biochar quality, learn how to ship large quantities without significant losses”.

As a footnote references:


Energy Utilities changing Models – A Battery of Choice

As one would normally do, chat about renewables and impacts on the utilities business model while relaxing with friends. It was a case of too much uncertainty over how the consumer would be treated because of change. Central to the discussion was that a provider to the electrical distribution system could threaten the current regulatory and centralized generation models of ‘essential services’.

What does this mean?  The business as usual model is failing where supply centric economics demanded you build additional load capacity and transport the capacity to the place of need. This model also meant the assets, including the customer, was owned by the utility. If you think of it this way, Governments tend to discourage demand side solutions. Demand Management was tended to be more of a series of incentive programs for utilities to duplicate infrastructure to transport to the demand source.

So, what happened to change the balance? The obvious: Technologies improved, carbon became issues for society and clean energy and renewables were being shown as a better way to address the logistics of meeting demand where it was needed. As a result some of the conventional infrastructure was at risk of being a stranded asset and the need to build conventional infrastructure required incentives from Government to reduce the financial risk. For example, the Demand Side Incentive scheme (DIS) formulated at about 2004 is dramatically underspent but is comforting for utilities in being a facility to reduce the financial risk.

If we note the changes in the needs of society as a driver for change: Governments and their policies encouraged that traditional public ownership be phased out to pass the needs to private investment. Government was happy for this ‘fix’ as they see it as the asset is sold for a value and ongoing regulated charges and fees and taxes are being paid to treasury, and that is a public benefit. The perfect storm in Australia is this action is also one of the drivers for electricity tariff increases in Australia. Recently the state of Queensland announced a 21% increase to its general tariff.  A source, CO2Land identifies as SF said: “Therefore those consumers with solar PV are subsidising those consumers that don’t have solar PV”.

From that last statement we can assume government policy (Federal and State) is very much the catalyst that resulted in the model change. Whether the change was necessary was more of a political move in this instance. It followed that technology and innovation evolved and the model change was inevitable. If you follow the beliefs of the 5th Column existing, this was done by infiltration of the policy areas by a particular group. It follows, in contemporary Australia, Government policy is more reactive than before, and since the 1970’s the rule of law was modeled as to be reactive to the needs of the dominate influence. Below is an explanation of this view as posted by on 3 April 2013. Where:

Co2Land org now asks: If we consider the four primary schools of thought in general jurisprudence :

  •   Natural law is the idea that there are rational objective limits to the power of legislative rulers.
  •  Legal positivism, by contrast to natural law, holds that there is no necessary connection between law and morality and that the force of law comes from some basic social facts although positivists differ on what those facts are.
  •  Legal realism is a third theory of jurisprudence which argues that the real world practice of law is what determines what law is; the law has the force that it does because of what legislators, judges, and executives do with it. Similar approaches have been developed in many different ways in sociology of law.
  • Critical legal studies is a younger theory of jurisprudence that has developed since the 1970s which is primarily a negative thesis that the law is largely contradictory and can be best analyzed as an expression of the policy goals of the dominant social group.

If you think of the debate of tariff increases. Then you should consider it may have been ‘an expression of the policy goals of the dominant social group’, as critical to that issue. We should then think about the set of claims that the “Renewable Energy Targets” (RET’s) had undesirable consequences, and how governments (Federal and State) now realise that the larger than expected number of early adopters who signed up for the long term contracts are now having a negative impact on state & federal budgets, and this is one of the dominate drivers for electricity tariff increases in Australia. For those needing an introduction to the scheme, the RET’s are a federal government initiative commencing during year 2001, and from those bills and legislation various states and territories introduced those targets as various incentive schemes for customers to invest in solar PV with generous feed in tariffs. This incentive had the effect of distorting the demand supply balance, and the popularity embarrassed and alarmed treasury. If we use SF as the source again; “Queensland Govt initially offered 44cents per kWh this has now been reduced to 8cents. That said the response from the customer was rapid with Australia now having 2500MW of solar PV with and average capacity of 3.5kW.”

CO2Land org chose to give an example of Queensland for convenience, as this states geography and population patterns influence the custom that those consumers with a service, are asked to provide subsidies to those that do not.  In the case of electricity you could argue the subsidy required is determined by the length of the extension cords needed. You might understand why that state found it Initially appealing that solar PV was a localized delivery point. However, managing the asset is a different matter.

We are seeing similar issues being evident from around the world – business as usual is failing as the utility model. The danger is stranded assets and less control being possible. A story titled The Clean, Simple Solar and Storage Solution to US Utility Business Model Woes .

Tells of an interview with former United States Secretary of Energy Stephen Chu on utility business models.  While the gist of what he said wasn’t new to me, the clean and elegant way he laid out what he sees as the future of utilities and solar power is worth sharing.

Similar to how in the past telephone companies – he specifically named AT&T – used to own the entire telephone system from the overhead telephone lines up to and including the phone in your house, Chu feels that utilities ought to own solar panels and energy storage systems that they put on their customers’ roofs and in their garages. He said if utilities could outfit homeowners with solar panels and a 5-kW battery system, they could continue selling that customer power just as they do now. The utility would own the system, maintain the system and the customer would have no out-of-pocket expenses for it other than continuing to buy power at the same rate or at perhaps an even lower rate.

 In the three-minute interview, Chu didn’t explain another huge reason that utilities should consider this option: distributed generation used in this way counteracts the need to build additional generation as the load capacity needs increase.  And lastly and most important, the utility gets to keep its customer.

Utilities should probably get clear on their approach soon. When it’s just a quarter or a half of one percent of a utility’s customers that have their own PV and are selling their solar power to the grid at the retail rate, the utility doesn’t care. But energy storage and PV panel costs are dropping, and once that percentage of utility customers’  that are zeroing out their bill goes to 5, 10 or 15 percent then “it’s a big deal” said Chu.

Chu said he told utilities that PV and energy storage is going to come and they should “form a new business model” NOW so that what today is a potential revenue loss, could become an area of growth for them in the future.  Plus, he said this model would eventually lead to a more stable grid for us all. “

CO2Land org is finding it difficult to solely blame the RET Scheme as the problem. The evidence is the splitting of the RET’s scheme into a ‘small scale’ offering for predominately solar PV is the problem. It is appropriate to say any change to the utility models would and did have a cause and effect disruption on the industry, and cause and effect type of disruption suggests any intervention will introduce more shocks in the industry, and we can expect that ideologies will continue to influence the Governments policy advisors who are without a full understanding the implications. It also follows that a large dependence on small scale or residential solar PV services implies a need for significant workforce skills shifts to cater for the growth and scope of the model change for utilities to take control of the assets at a domestic level to be to be effective. That is a significant cost driver, and it is reasonable to ask why should the utility be the provider of choice for these services where it would serve to drive up prices?

In defence of RET’s large scale systems, it follows that large systems do not directly affect the utilities mechanism to preserve the current regulatory model, but they shift the balance so that the model needs to be reviewed of the purpose and objectives in the delivery of the product. It follows that centralised generation models are what utilities do very well, and large scale transportation and distribution are well established capabilities of the industry. Expanding that capability to large commercial rooftops and installations might be a good idea. However, it too is not without the need for change. Albeit less dramatic than small scale.

CO2Land org is not proposing we should concentrate on picking winners for the model change.  However, ‘the battery concept’ leads to deeper thinking. The demand initiative needs to be expanded and a battery concept is not just a means of storage of an electron! It can mean tools and equipment that is readily available to balance the total load needs, and not just peak demand requirements. We know solar’s great weakness is peak availability profile and traditional batteries concepts take up rare earth minerals to manufacture. Are they already defunct? A far more sensible battery concept is something that can utilise what we have already consumed and discarded to be returned to there natural elements while producing energy and balancing the supply needs.  If you prefer think of it as a provider it can be an insurance tool for a supply imbalance, So can what they do be a source of energy rationing and balancing that fits neatly into the traditional delivery mechanism.

One such battery concept is the waste to energy gasifiers and their products including pyrolysis retorts. These can easily be written into the current infrastructure and be part of any new regulatory mix – even provide a result for policy without implications – it is not creating anything new – just making something old new again!

For the future, CO2Land org can see a lot more independent renewable sources becoming the norm, and utilities will be using energy exchanges to sell power to customers. This differs from ownership of customers in that bidding could be managed power purchasing agreement with give and take provisions in the price. What regulators will have to deal with is that nationwide and globally installing microgrids for Businesses and Communities will need to fit into economic as well as technical delivery models. A real power of choice if you prefer to think that way.

Fit for Purpose – assumptions in MSW and WtE

End to end solution for treating Metropolitan Sewage and Waste (MSW) is a hot topic, and very much in the fore of forums for 2013. So enthusiastic are the players it is very difficult to differentiate the fact from the ideals. Look and you will see a lot of justification and more than adequate presentation of the material. What is more difficult is to get a clear indication of the capability and improvements over current practices.

The culprit may be assumptions, and they are widely used under management scenarios. If we define assumptions as a statement that is assumed to be true and from which a conclusion can be drawn. It might even be that as we rely more on big data an omission from the assumption can lead us to ignore the obvious. Take this example statement – Our machine can undercut all other in terms of power costs. Then if we find published a number of a competitors, but necessarily the same technology, we can quote that number and assume ours as similar or superior. Yet, as was said it is not the same technology.

Recently a post was read and it said in the US, under US Average Levelized Cost for Plants in the Annual Energy Outlook 2009 and 2010 and 2011, a typical generator running on Biomass has net requirement for a price of 11 c kWh to break even. Then came an assumption from the author that as these tables have no values for Advanced Plasma Conversion it is assumed a value of  $0.044/kwh is the value that you add for comparison. The difficulty is the published number for biomass is taken from experience and certain modeling under a list of data sources. The advanced plasma conversion unit was then part of a hypothetical assessment according to mathematical values that commence with an assumption, and will be correct until proven wrong. The fatal flaw in this is that facts are with the biomass and its testing included load scenarios and importantly it has a generator (that thing that produces electromotive force – electricity) attached. What is obscure is whether the Advanced Plasma Conversion unit is connected to a generator, or whether it needs one. For an investor this is a matter of concern, and for a professional in the industry it says embarrassing!

Another major issue is the maturity of the solutions put forward for you to make a project decision.  At program level you can take liberties and shuffle as you need to, at a project level on time and on budget can be you nemesis if you make the wrong assumptions – as said earlier – assumptions are a management scenario. CO2Land org assumes four scenarios are possible for waste handling solutions. It can be put forward to consider: Business as Usual, Gasification, and Pyrolysis, Plasma conversion.

  1. Business as usual (BAU) is an option fast running out, and in areas of rapid urbanization and rapid growing economies the time has already arrived that it cannot continue, not just because of the carbon issues but because it is an economic cost. This does not discount the importance of carbon, but indicated that developing countries needs the resource recovery as much as it is in need to develop.
  2. Gasification is an effective incineration tool, and innovations are proving to be effective in optimizing syngas recovery and returning additional products from the process for agriculture and raw material recovery.
  3. Pyrolysis is also an incineration tool, albeit at higher temperatures with the added benefit of being able to produce syncrude and chars to order. The process needs to be well managed to avoid the possibility of producing dioxins.
  4. Plasma conversion has been around for some years and has chequed history as an incineration method. Two particular issues have dogged the traditional designs. High and constant power requirement, and not being able to control temperature and ionizing across the plasma bed. Considerable claims are being made of advances in the technology. Confidence is continuing to grow on the refinement of the equipment and a number of sites across the world are being implemented.

The Cost benefit of each scenario indicates:

  • Point one is clear – the high cost of resource recovery weighs heavily when the budget is restricted for an authority and they would promote BAU until an incentive was put forward.
  • Point two and three are relevant and in more recent times the marrying of the two according to need is seeing this technology develop into a useful cost effective solution and should be the method of choice in most instances for the next 7 to 8 years.  By this it is meant it is the best technology to implement for most scenarios now and into the future in that time frame and it useful life for many more.  It also has an advantage of being complimentary to most commercial activities, and the ability to be scalable as required.  The strong point potential is to return a number of waste materials, especially plastics to virgin materials.
  • Point four will be the technology of the future; it has the potential (ideal) and the hopeful expect an almost unending product potential from this technology. The next generation is expected to be approved and producible in around 5 years. The scale of the projects required to cover the capital costs is the biggest limiting factor for future projects.

In more detail is this information the current Waste to Energy scenario suggests the difficulty is with the techno-commercial format. That comparing apples with apples may not be possible. An example is given by 
William G. Acker ( where he looked for Advanced Plasma Conversion tables in the U.S. Annual Energy Outlook 2009 and 2010 and 2011. In these tables there are no values for Advanced Plasma Conversion. So he then said he must assume that what was claimed by another company representative was a value added to the values. He himself then assessed the closest estimate to which the technology is closest to be the figure for Biomass. This is not his definitive position, all he asks is someone to provide a value to share that is more accurate. However, in the mean time we make the assumption it must be correct until refuted

Then CO2Land org decides to ask a question in a forum on Waste to Energy (WtE): “Excuse the confusion, a lot of justification and adequate presentation of the material is provided. What is not clear is the capability from the production of an energy source to the actual electromagnetic force. In other words: what are the source, type and cost of the generator machine? Or, is your Plasma machine also a generator of electrical power in its own right without the need for other equipment?  The response: Good question!  The discussion then centres on whether matters were assumed or simply relayed on what was actually said on the capacity and nothing more.  Being that capability was not addressed is not the domain of the engineers for not giving you correct info, or how confidential agreement might stop you providing information. It may well be a simple case of the enquirers having no idea on what to ask. They do not ask because it was not obvious or lost in techno-commercial format of the communications.

In the quest for comparing apples to apples, and ignoring that baseline quotes may be flawed. To compare the possible in WtE from our view (to which we will assume you will be at odd. Information supplied illustrated:

A hearth gasifier with a reciprocating low Btu engine and conventional generator can be leased in Australia with an operating cost of 8.2cents per kilowatt-hours, with a 25,000 hours maintenance requirement. These costs are worked assuming a 1MW net unit and economies of scale suggest lower costs for larger units. If I combine the capability of the unit with a pyrolysis retort and produce syncrude and biochar, the offset pricing suggest a decrease in generation capacity will result, but the operating costs will settle at around 5 cents a kWh. The number will vary according to the feedstock quality.

Very recently an indicative quote that asked for capacity to handle MSW with1750 kcal as feedstock and input 300 tonnes per day for using advanced plasma conversion. What would be the project cost? The answer came back in the order of  $6.5m plus the cost of shredder activity and generator sets required – that is the cost to add capability is not in the cost mix.  The difficulty now is the assumption that must be made in the numbers.

In another example of a project where the project is not only proposed, is financed (and currently on hold to commence), is again supplied by William G Acker, of the MSW Plasma Gasification Facility for St. Lucie, Florida. This facility would use 686 ton per day of MSW and would produce 22 MW Gross and 18 MW Net of electricity. The installed cost came to $190,000,000. Amortized the project over 30 years with the Levelized Capital Cost alone (no maintenance cost, no labor cost etc.) comes to $0.0922 per kWh. If we add labor and maintenance costs the total may be ‘assumed’ to be around $0.14 per kWh. Then we must consider the money made for taking the waste off the hands of communities, or business that are paying to, landfill it we then could subtract around $0.03 per kWh from the operating cost resulting in $0.11 per kWh.

This results in CO2Land org asking: Will the actual plasma price to generate electricity please stand!  So we know without assumption forming the core costing criteria a project cost is capable of producing electricity for approximately 11 Cents per kWh, and the example hearth gasifier somewhere from 4.4 to 11 cents per kWh. Albeit other examples might swing wildly towards higher costs depending on the operating and technology vintage.  That said there is no doubt that given time and R&D plasma conversion in whatever form will be the way forward. In other examples plasma systems are doing OK for the job required, but academia and those in the industry say it is some way off being perfected and as efficient as it should be.

If we go back to the influence of assumptions the problem for the industry is that laboratory results and mathematical equations don’t often become reality, as not everything is scalable. In the mean time it is “danger danger, Will Robertson” as borrowed from ‘lost in space’ which was entertaining series a little while back. We also need to be fully aware of the smoke and mirrors approach that do a wonderful job with customers who are not normally that knowledgeable.

Another factor of our times is that despite each supplier wanting to win each job, they are fighting for funds within an economy where funds requiring $50M or more are highly competitive. In these instances those projects where the technology is still to be proven it will take second place to those known to do the job.

Evidence of uncertainty in the accuracy of a useful lifecycle may lead you to consider that you might want to lease the plant, it could be a lower risk in these times. The more popular in these circumstances are suggested as those that offer an operational lease rather than a financial risk.

We trust that has covered off on the choices – if you feel too much assumption is made or if you know better – please show yourself!

encouraged to submit an EOI – but!

We have spoken with our contact, and we are encouraged to submit an EOI for the CRE Grants program. Given that everybody else is submitting EOI’s for Wind and Solar systems, we may be in with a good chance.  This is a response sent in after it was posted Closing 21 Feb – excluded, on February 13, 2013 by co2land

In fact three relevant responses came in and each had a story that you might be interested in:

Renewed Carbon – Have a BioHub design. They have a set of engineering firms in Newcastle ready to: Design the plant, Build the plant, Run the plant for 12 months, Take all the start-up risks, Sell the operating plant to the eventual owner.

All they need is about $12m !!!

They are working towards a pre-feasibility study to establish whether they are just dreaming (They believe such a study will a green-light the project). But the study will cost several hundred grand!

It is matter of hurdles (one at a time) and a simple process of: let’s get the money for the Pre-Feasibility Study and work from there.

Part of the reason for their enthusiasm is they are aware of working Pyrolysis plants in several places in Europe, as such they are confident the ‘Commercially Available’ constraint in the EOI closing 21 Feb 2013 should not be a problem.

With that said, I wonder if many are aware of the more sophisticated Veolia WASP project at Woodlawn, via Tarago in NSW. This project has been held up in NSW Planning approvals for some time now and as we have spoken to the engineers at the plant – it is a source of great frustration.

Then a more detailed retort from Peter and Kerry Davies of Real Power Systems (who have built their gasifier and Pyrolysis retort machine in Australia and demonstrated its commercial application in Australia) lament the issues they have had since showcasing the capabilities on the grounds of Parliament House in 2009). In this response they are responding not only the Closing 21 Feb story they are also referring to happenings in the prickly exchange between  and City of Sydney Tri-generation project, and the general stonewalling they have encountered with their offering in the quest for a commercial outcome.  In direct quote:

“Thanks for the link, we just read through the three associated articles:

The attacks are coming from the green’s associates and heavily rely on BZE, a Melbourne University academics club who want Oz to go solar thermal immediately and trust that in doing so costs will fall and engineering problems overcome. This involves putting several thousand square km’s of solar arrays down in adjoining rural areas…

The core arguments against the renewable component of the plan centre on biogas, which is produced using anaerobic digestion and therefor predominately methane (85% CH4). We would consider these arguments to be largely valid although they don’t go far enough, the cost of efficient closed cycle anaerobic digesters is millions of $ per MWe of capacity and are prone to significant operational problems. In the EU it has been found engines running on biogas have difficulty meeting emission guidelines as some fuel is not burnt (escaped methane) and running excess oxygen to correct this then results in NoX emissions rather than CH4, there is a lot of work being done to overcome this limitation.

These arguments though are not valid at all for gasification whose output is “producer gas”  which has <1% methane and the fuel gas component is CO & H2, much cleaner in combustion and not subject to “methane leaks”. Gasification also is far more flexible in its feed stocks which can readily include waste paper with plastics contamination, and is easily topped up with solid fuels produced from plantations, crop residues or RDF pellets.

NoX  is easily managed in a properly engineered system running on producer gas since its formation is temperature and free oxygen dependent. Modern “lean burn” engine technologies combined with rapid exhaust cooling (via cogen) readily address the emission concerns. Direct combustion systems are more difficult, the critics seem to be confusing the two.

Trigen should be eminently suitable for Sydney so long as it genuinely includes absorption chiller technology for the building climate control required in warmer months. We don’t believe waste heat and inversion layers should necessarily be an issue so long as the trigen plant is not using fossil fuels or high methane biogas. Indeed with some lateral thinking and applied engineering the waste heat from higher rise buildings could be used through thermal siphoning to alleviate air pollution at street level.

We are aware of some very clever “Urban food production” systems that can produce very high outputs from small areas using aquaponics (fish and hydroponics). The rooftops of many high rise buildings would be eminently suited with proper planning to include these which then turns the total system into a “Quad generation”, utilising CO2 from the engine exhausts in the greenhouse above and providing local restaurants with fresh fish and vegetables grown in their own inner city building or precinct! Such innovations are we believe relevant now and can only become increasingly important for the future of sustainable cities.

Heightened ambient noise is an engineering/$ issue. A couple of years ago we responded to a request for tender for a cogen plant at a public swimming pool. The EPA imposed a noise limit of 32 decibels (it turned out there were dwellings within 20m of the installation site…). To put this in perspective such a noise limit can be exceeded by the act of sitting down in a country library and opening a hardcover book… We found a solution with pre-cast acoustic chambers from a Sydney supplier which added about $80,000 to project cost (yes you can also cast in situ). You could rev a Harley at full throttle inside one and not exceed the 32DB limit outside. To give you some idea of what this means in practice the fan running on the RPS system demonstrated at Bungendore for REDay generates 55DB.

Finally Origin/Cogent might consider the following: The RPS plant being commissioned at Sutton at the moment just took delivery of 80m3 of sawdust for further client trials. This plant when operational in the next week or so will consist of:

Gasifier – clean fuel gas and high temperature treated biochar output.

This char output can be used for water filtering and odor control amongst other external applications before going off to be added to compost for final recycling & CO2 sequestration.

Integrated pyrolysis retort – operates off a portion of the gasifier output so as to be more consistent, controllable and able to handle high/variable feed stock moisture contents, capable of sustained temperatures >650oC. Outputs biochar or torrefied biomass depending on temperature/residence time profile selected so effectively could replicate any typical biochar specification required or alternately pre-condition solid fuels for the gasifier.

Also can provide process heat for a range of purposes.

Electricity generator (20kWe) – Dual fuel diesel & producer gas from the gasifier . Typical diesel displacement when the gasifier is running would be 85% (reduction in normal diesel use). Later we will trial recycling a portion of this final exhaust back through the gasifier to re-crack some carbon dioxide (CO2+heat= 2CO) further reducing nett emissions.

We are also currently refurbishing a 50kWe straight gas industrial genset to add later in order to achieve 100% organic power.

Briquette press – for hot briquetting product directly out of the pyrolysis retort. (This is part of RPS’s R&D looking at subsequent material handling/transport/application strategies).

This briquette press is a proprietary design that we own the rights to and is able to be locally fabricated by any competent engineering shop so is not a high cost imported item.

So it is really a combination proof of concept/commercial plant that goes beyond just a functional bioenergy/char retort design and looks more at a whole of system farm scale factory with core components equally at home in the basement of a building in order to give flexible outputs that maximise benefits. This plant is readily brought up to the scale some companies have received offers of multi-million dollar public grants to build…but still haven’t been able to do so.

All of which has been done not only in the absence of government grants or sucking in market venture capital but also in spite of direct obstruction and commercial bastardry by vested interests. What might be described as “Success against Uncommon Odds”.

If the City of Sydney/Origin/Cogent trifecta are genuine they need to stop playing around the edges and get serious with some sort of supportive funding delivered through a credible pilot plant trial to publicly validate what we already know, instead of waiting for people like ourselves with real solutions to solve their problems for them entirely at our own expense.

Best Regards,
Peter & Kerry”

Then from George Paulos, where is writes of his IMPLETERRA new Plasma Gasification System:

“Thanks for connecting with me.

And as you have already pointed out: YES I love my work !

Hopefully we can be of fruitful service to one another.

I would like to move some things in Down Under with you.

For example: Our new Plasma can extract precious metals from ore.

This is currently being tested in our lab in the US.

Thus all these hazardous chemical for extraction get needless AND

of course the overall calculation for the mining company gets CHEAPER In this sense its a win-win for all parties involved: We and our environment and the company and the economy ! And also: These Plasma devices cannot be sold, only leased based on Power Purchase Agreements. Thus no investment necessary ! “

On reflection of what George has said, and repeated by Real Power Systems: The way grants programs are administrated may be what is wrong with the industry, in this it is meant: Why do you need $XXk grant to write a pre-feasibility study and then go to a prospectus costing $XXXXXXK in order to persuade $XXm from investors given that the askers apparently already know the outcome of a larger feasibility study, or learnt from past mistakes…. Would it not be more sensible to do as the UK Government do – have a department and a fund set –up that is open to all, rather than a select few. The caveat is if you can prove the need, that sufficient testing is done and you can show it could work, and the ability to be an entrepreneur – be a doer not just a talker. You will be asked how much do you need and so on. No nonsense approach that makes the bankable process much more streamlined.

CO2Land org thank each for their encouragement. Clearly these are also worthy of encouragement because they each solve real problems to what we have now, WHAT TO DO to turn waste to energy and take the pressure off virgin materials being required every time!



Closing 21 Feb – excluded

Closing 21 Feb 2013, Community Renewable Energy Projects: Message  – Innovations excluded and technology chosen must be commercial. This is despite many innovators being able to prove an environmental benefit at least cost.  It is not a new issue it is a matter that is a symptom of measures providing a pathway regardless of the evidence. Albeit, justification for this approach can be found by some oblique reference to some far away story.

As the Lawrence Berkeley National Laboratory explains “One of the most serious (and valid) criticisms of subsidies for “renewable” energy is that they heighten the perception (but not the reality) that wind and solar are less expensive and more energy efficient than conventional fuels”.

If we single out the NSW Renewable Energy Precincts Program and the expression of interest for funding the wording says “EOIs will only be accepted for projects proposing to use renewable energy technologies that are commercially available and have been demonstrated in operation at a similar scale generation capacity for 12 months or more. Solar photovoltaic technology and wind are the two most common, and commercially available, renewable energy technologies. Most CRE projects internationally use one of these two technologies”. This is interesting as world wide, and in Australia, there are technologies that offer a better power capacity ratio. It is also interesting that in Australia at least one public entity has taken legal action to restrict (Suppression) the opportunity for a commercial opportunity with alternative renewable energy. When the reference is made to power capacity ratio it simply means – coal fired can be replaced by this technology as base load. It should also be said at a lower cost than wind and solar. AKA – cost benefit is superior.

It is difficult to understand why a ‘community’ program is directing a bias in this way towards wind & solar. CO2Land org feels this is a shame because more than a few communities would be able to scratch together sufficient green waste and other biomass resources to run a genuine base load or peak lopping plant, from what is waste with the added advantage of also having very useful co-products and creating more permanent local employment.

It follows that local government have obligations for services and various industry is within the boundaries they manage. Industry does two things: 1) They tend to consume more of the fuel resources available in the geographical area, and 2) Produce waste that is often toxic or hazardous in the environment.

In a growing trend around the world (being a reference was made in the NSW REP EOI), and since 1980, as far as CO2Land org can see, major industry is increasingly looking at methods for recovering the fuel value from many wastes.

CO2Land org can identify some of the different methods to do so and each is superior in their own way, and certainly make use of existing problems of waste and remove much of the need for virgin material in the products they offer. The point is made – not one product such as electricity generation of wind and solar, but also other products that make up the needs of society.

To give examples: Gasification, Pyrolysis, Plasma conversion are increasingly being piloted or in production in other parts of the world. Not surprising is that many of the leading work was from Australia, then ‘discovered’ by America, India, China and other countries determined to solve their resource and waste problems. If you were to argue it is cost that is the problem. As a single product produced wind and solar can argue they the high ground. “But consider this case of cement kilns converting waste: The ash in waste fuels becomes part of the cement product in a cement kiln, this system is one of the very few that actually consumes all of the waste material – both organic and inorganic turning all of the waste into product – no ash, no change in emissions and no impact on product quality”. Patent Number 8268073 System and method for making cement and cement derived therefrom

Inventors: Burton J. Kunik, James C. Berns, David G. Gossman

More recently, engineered fuels (Synfuels) are carrying on to advance the latest step in the process that started over 30 years ago. Some might even recall or have read that in World War 2 years the need to ‘invent’ devices to get the family car around as fuel was rationed. The new advances present the real potential for using a wider variety of waste materials, including treated medical wastes, to consume waste materials instead of coal and other natural resource based fuels in the manufacturing process.

Then there is products from the treatment of medical waste including sharps: Embodiments of this invention provide methods for converting a used healthcare material including a complex mixture of components including pulp materials, polymer materials, metal materials, and/or other material such as ceramic materials, ash materials, etc. directly into a burnable fuel, Without the need for component separation. Patent Number 8163045 Method and system of making a burnable fuel Inventors: Burton J. Kunik, James C. Berns, David G. Gossman

Still struggling in Australia is Real Power Systems. Peter and Kerry Davies have built a considerable amount of bench testing conducted (circa 2009 to now) and are successfully testing, including onsite pilots of their gasifier and pyrolysis retort and this success continues to lead to product identification not previously considered. They started being most interested in bio-char production for agricultural purposes, and the range of fuels that can produce and the range of waste they can treat under various water saturation condition is striking. And, they can produce syngas, synfuel, syncrude and have solved problems such as “Cavitation Phenomenon at the Reactor Chamber” that plaqued or was the reason for more expensive offering in the field.

If you can consider the cost savings when compared with traditional fuels it can be enormous. The environmental saving through the use of engineered fuels (syfuels) is a significant reduction of GHG emissions. So much so that engineered fuels, are getting overseas regulatory approvals and are meeting EPA definitions for “sufficiently processed”.

We are saying we should compare complimentary and alternative solutions to our energy problems, and being we should be very conscious of the traps involved in the development of technology, It can be very hard to stay focused when development is proving there is so much flexibility and opportunity in direction.

Possibly this is why the 21 Feb 2013 closing EOI has chosen to stay focused on wind and solar, but then something more needs to be done in keeping with the developments and as such building on advances to ensure uniform characteristics can be judged to gain a higher level of understanding and open whole new avenues for applications of otherwise problematic materials. What could be better than the local government waste dump having onsite production capability of syncrude made from waste tetra packs and plastics? it does make things oddly enough, a tad more difficult…but not impossible.

Contaminated Land – Research data

Reported is that research is ramping up into the number of areas responsible, or have responsibility for management of contaminated land. Worldwide, it appears the impediment to date has been the concern of uncovering unintended consequences by the actions that might be taken. This is understandable if you add that in order to take notice you need to understand the problem. It also follows that any data collection effort will serve as a proving ground for a methodology to deal with the problems that are uncovered. That in itself introduces another problem in that developing a Methodology requires funding or promises for funding.

Knowing that even governments have funding issues internal to themselves we could ask: So where should we start in Australia?  The immediate noticeable group addressing the quality of data issues of ‘real’ remediation challenges is the federal Department of Finance and Deregulation (DoFD) which has a Special Claims and Policy Branch that is leading a strategic data collection project examining the manner in which contamination issues are addressed. However, its purpose is to address Commonwealth Land Decisions-making and gather data only from entities covered under the FMA Act (Government Agencies) and CMA Act (Authorities). The Department has set out the project is to be collecting information in the earlier part of 2013. Whilst a let down to some, it is a start to identifying the effort needed.

Concurrently, Canada is turning its attention to those that refuse to clean up where they have polluted, and Environment Canada is beginning feasibility studies of remediation technologies that could be used on federal properties contaminated by chemicals.  Source: . A watching brief on Canada’s and other overseas, state and private groups suggests it is very wise to manage contamination within property decision-making groups and that they undertake research into solutions under key terms that may be available to reference available literature and what might be uncovered.

What CO2Land org has noted is that DoFD is finding the need to validate their understanding of the Commonwealth’s legal obligations relating to contamination liability – to clarify what they must manage as opposed to should manage.  (Those that follow this thread might recall – Posted on January 6, 2013 by co2land, Contaminated Land – Obligations to manage – was written to help the reader to understand that managing the environment means many things and it is not necessarily so that moral decisions will be made). This implies there are many areas of uncertainty and any contamination related advice would be welcome to help them target key areas of uncertainty.

In relation to the DoFD data project, Posted on January 8, 2013 by co2land , Contaminated Land – Remediation challenges was written Presently for a majority of contaminates, there are no endorsed standards or guidelines within Australia that define, for each category of land use, safe levels of soil contamination. What we do have within the National Environment Protection Measures Act 1998 (NEPM Act) guidelines is an adopted remediation criteria recommending investigation levels. Our suggestion is this investigation criterion is far too conservative and not well adopted or able to properly adept to manage health and environmental risks. Also written was CO2Land org noted that the federal Department of Finance and Deregulation has a number of areas responsible or have responsibility pertinent to management of contaminated land and wonders if it might be data collection that is the greater weakness in terms of the abilities for adequate and timely responses. This new post suggests DoFD is now prepared to push the boundries into uncertainty for those areas not previously covered by the scope of the land policy functions. CO2Land org also notes the timeframes for the project indicates the willingness for the data to be available for the 2013/14 Strategic Review Program – we applaud you for that. Small steps by a leap forward in terms of past efforts.