Comment Details
| Comment Author: | Charles White |
| Organization: | Waste Management |
| Comment Date: | Tuesday, 23 February 2010 |
| Comments: |
Other/General Comments: Please post the following comments to replace those submitted Feb. 19, 2010 for Waste Management. Please note that the revisions herein are minor in nature, but more properly identify the Harvest Power initiative described in the comments. Thank you. February 19, 2010 Mr. William Drumheller Western Climate Initiative Submitted Via Internet RE: Comments by Waste Management submitted to Western Climate Initiative on release of Voluntary Renewable Energy Market: Issues and Draft Recommendations issued January 14, 2010 Dear Mr. Drumheller: On behalf of Waste Management (WM), thank you for this opportunity to submit comments on the document entitled “Voluntary Renewable Energy Market: Issues and Draft Recommendations” issued January 14, 2010. WM has played an active part in efforts by the Western Climate Initiative to establish a cap and trade system spanning its partner jurisdictions. We applaud your work to date in this regard. While there is much to support in prior work products, we caution the Western Climate Initiative in its efforts to link the renewable energy credit system to its cap and trade system because of the potential to confuse and duplicate renewable energy programs that are working well. WM has made significant investment in renewable energy generation. The Company is leading all others worldwide in development of renewable energy from solid waste. • Since the early 1970’s, our Wheelabrator Technologies division has delivered clean, renewable energy from municipal solid waste while saving space in landfills. Wheelabrator has converted more than 157 million tons of waste into more than 85 billion kilowatts-hours of clean, reliable power. Each day, Wheelabrator’s fifteen waste-to-energy facilities generate sufficient electric power to meet the needs of more than 650,000 homes. Twenty-four states and the District of Columbia define waste-to-energy as renewable energy in regulation, law and statute. Waste-to-energy is a renewable source of electricity as defined by the 2005 Energy Policy Act and by the U.S. Department of Energy. Both the U.S. House of Representatives’ energy bill and the Senate Energy and Natural Resources Committee’s approved American Clean Energy and Leadership Act establish a federal Renewable Portfolio Standard that recognizes waste-to-energy as a renewable energy source. Wheelabrator also owns and operates the Shasta biomass facility in Anderson, California that generates 55 megawatts of renewable power from wood waste. • WM is a leader in landfill-gas-to-energy technology with projects now generating renewable power throughout its nationwide disposal system. Federal and state law confirm landfill-gas-to-energy as renewable power. The Company’s landfill gas-to-energy projects generate enough renewable energy to power 400,000 homes every day and offset nearly 2 million tons of coal per year. WM currently has 110 landfill gas-to-energy facilities and is working toward a widespread implementation for the future. • Last month, WM announced an agreement to partner with Harvest Power and expand next generation organics materials processing facilities across the United States and Canada. Together with WM, Harvest has significant expertise in organic waste management, from building and operating large-scale organics materials processing facilities to marketing compost products. Harvest owns and operates the largest food and yard waste composting facility in North America. Harvest is also developing innovative high solids aerobic and anaerobic digestion and composting technologies, which accelerate the decomposition of organic materials to produce renewable energy that offsets the use of fossil fuels. The process creates clean biogas that can be converted into electricity, liquefied natural gas, or compressed natural gas, and also generate high quality, nutrient-rich compost products. • Waste Management has developed technology that promises to reduce the cost of anaerobic digestion and still produce high quality compost and renewable power. The WM Reclaimable Anaerobic Composter (RAC®) takes advantage of existing gas to energy infrastructure and an anaerobic composting POD system for batch treatment of organics including yardwaste, wood chips, oil & grease and food waste. Each POD processes up to 5,000 cubic yards of yardwaste and food waste in a completely sealed vessel. Instead of converting the compost aerobically to carbon dioxide (CO2) only, the RAC technique converts the organics to about a 45%/55% mixture of carbon dioxide and biofuel (CH4). The resultant biofuel is processed and utilized through the existing gas to energy infrastructure. In larger facilities, the gas might be used for liquefied natural gas or compressed natural gas. • WM is investigating and investing in alternative fuel from waste technologies that could provide energy to the electricity grid. Most recently, WM joined Valero Energy Corporation, the largest refiner in North America, in the investment and development of a unique waste-to-fuel conversion technology developed by Terrabon. WM will assist in securing organic waste streams, which Terrabon will use to produce high-octane gasoline using its MixAlco™ technology. MixAlco is an acid fermentation process that converts biomass into organic salts. The resulting non-hazardous organic salts, or bio-crude, would be then shipped by truck, rail or pipeline to a Valero refinery or other centralized processing facility where it would be converted to a high-octane gasoline that can be blended directly into a refiner’s fuel pool, avoiding many of the blending and logistics challenges presented by ethanol. • Technology that provides for landfill gas to be delivered directly to existing natural gas pipeline distribution systems and wheeled to transportation fueling stations shows promise as well and is fully supported by WM. The Gas Technology Institute is investigating the efficacy of this approach and WM anticipates that based on a forthcoming report, direct landfill gas use may be another avenue to generate renewable energy from municipal solid waste. Our commitment to renewable energy dates back nearly 40 years to Wheelabrator Technologies’ leadership in building one of the first waste-to-energy facilities in America. Since then, we have been committed to development of clean, renewable power from waste using a variety of technologies and approaches. We have invested billions of dollars in renewable energy development over the years based on our keen understanding that to sustain our planet, we must use resources wisely. Generation of power from what otherwise would be wasted is a wise use of resources. Others share our belief. The existing renewable energy programs – both voluntary and mandatory – and the creation of Renewable Energy Credits reflect the importance of renewable energy to policymakers and the public. We understand WCI’s intention to help aid in renewable energy development by linking its cap and trade program with a voluntary renewable program. But we ask that WCI proceed cautiously in this regard. The renewable energy market is a complicated marketplace with established rules hammered out over time. Renewable definitions, the bundling or unbundling of assets, the ownership of underlying benefits and assets, and the inability of a purchaser of one benefit attendant to the renewable asset not to reach back into a generator’s ownership of another benefit are all issues that have been settled through negotiation, legislation, regulation and in some cases, courts of law. The stability resulting from settling these complicated issues is essential to a thriving renewable marketplace. Indeed, ever increasing stability spurs increasing development of renewable energy as evidenced by the description, above, of WMI technologies and programs. We agree with the WCI that generation of renewable energy lessens our carbon footprint by avoiding generation of fossil fuels for energy. Greenhouse gas reduction is an important benefit of renewable energy. It is one of many reasons renewable energy makes sense. Linkage of renewable energy programs with WCI’s cap and trade program must be respectful of established precedent of the renewable market. Issues raised by WCI, such as tracking systems and verification, renewable definitions and eligibility, and overall coordination must be settled so as not to disrupt the renewable markets. WM looks forward to working with WCI on these important issues. Thank you for this opportunity. Sincerely, Charles White Waste Management |