| Comment | John Paoluccio Consulting Engineers, Inc.
P.O. Box 1316, 5038 Salida Blvd., Salida, CA 95368
Ph: 209-545-1661 Fax: 209-545-3533 Email:
johnpaoluccio@sbcglobal.net
May 7, 2010
Air Resources Board
"awhiting@arb.ca.gov"
Re: Notice of Public Meeting to Hear a Report on the San Joaquin
Valley Smoke Management Program and Consideration of Modifications
to Agricultural Burning Requirements
Subject: Comments / Open Burning Actually Reduces Air Pollution
Summary:
The following comments relate mainly to almond and related
prunings. Several specific revisions to the above rule are
requested.
The ARB has mainly attributed the reduction of PM2.5 since 2002 to
the reduction of open burning. I suggest that the changeover to
non-till operations by many almond growers and others played a more
significant role in reducing PM2.5 and PM10 in the entire area than
reducing open burning. The small particle dust generated by disking
orchards is considerable greater than that of non-till.
The ARB current position will result in a reduction of open
burning of agricultural biomass such as almond prunings. The Air
Resources Board says that wood burning causes considerable air
pollution and numerous restrictions are being made. They want
farmers to chip prunings and disc them into the soil instead of
burning them.
Chipping and allowing the wood pruning’s to decay causes more air
pollution than open burning of dry pruning’s.
Consideration might be given to restricting open burning on “No
Burn” days like they do with fireplaces. That would not be an
unreasonable rule.
Each year when forest fires occur, very wet wood is burned and
millions of tons of harmful GHG’s are formed. In contrast, the
burning of dry almond prunings is negligible in comparison. The
forest departments are on the right track to divert that biomass to
offset fossil fuel use. They still have to slash and burn most of
the forest thinning and residue because not enough biomass power
plants are available. Many of the recently published reports by the
Energy Commission and the ARB are recognizing that tapping into
biomass can help California reach its mandated 1/3 reduction in
carbon dioxide by 2020.
It is hoped that the following information will be considered and
the District will concur that Open Burning of dry almond prunings
be continued.
Comments submitted: for review and For The Record.
Thank you for the opportunity to submit written comments on the
proposed amendments to the rules and regulations on Rule 4103 (Open
Burning).
Before making a decision to ban open burning in favor of certain
options, all pro and con issues should be addressed. By analyzing
the overall air pollution caused by open burning versus the
recommended options to burning such as chipping and disking the
pruning chips into the soil should be considered. See comparison as
shown in attached Table “A”.
These pollution reductions items include the following:
1. Wood Burning – Including Open Burning of Orchard Pruning’s.
2. TABLE “A” - COMPARISON of CONTAMINATES & PROBLEMS caused by:
OPEN BURNING OF DRY WOOD Versus DECOMPOSITION.
3. PM10 & PM2.5 – Encourage non-till agricultural practices.
4. Energy – Encourage renewable energy in lieu of fossil fuel
use.
1. Wood Burning of Orchard Pruning’s & Biomass Use
The burning of orchard pruning’s results in considerably less air
pollution than chipping and disking or other options available
today. It is recommended that rules, on almond pruning’s for
example, allow for continued open burning.
Biomass holds the promise of reducing fossil fuel use and can
substantially help our energy production and dependency on foreign
oil. If all open wood burning were stopped, our air quality would
get worse not better.
Burning dry wood is natural and good for our environment and is an
important part of the cycle of life on earth. Biomass takes in
carbon dioxide during growth and gives it up during decomposition.
However, when wet wood is burned, incomplete combustion occurs with
the release of substantial amounts of polluting GHG’s. The burning
of wet wood should be discouraged.
If wood is allowed to decay by natural means, including
decomposition by ants, termites, fungus, microbes, etc. Then,
considerable amounts of methane gas are generated and released
along with other GHG’s. Methane is one of the major primary
airborne contaminant generated on earth.
By burning dry wood we simply release the stored solar energy and
produce mainly water vapor and carbon dioxide. Better yet, waste
wood can be collected, milled into pellets and used in electrical
power production. Even better solutions include processing the
wood pellets into clean burning torrefied wood for use in co-firing
with coal or gasification processes. This allows biomass to be
utilized and helps keep harmful fossil fuels in the ground.
If this wood resource were burned in a biomass plant under ideal
conditions, only a very small amount of pollutants would be
emitted. We would derive substantial energy and reduce our
dependence of fossil fuels. A win-win situation that should be
encouraged.
New technologies, inventions and processes that utilize renewable
biomass offer many opportunities that can lead to a substantial
reduction in fossil fuel use. These include bio-diesel, ethanol,
wood pellets, torrefied wood pellets and many others. Torrefaction
is one of the most promising technologies. This process involves
the heat treating of wood in the absence of oxygen where almost all
the water and VOC’s (volatile organic compounds) are driven out.
Torrefied wood can be used as a solid fuel or used in gasification
or conversion to oil. Torrefaction was developed by the French
decades ago but the processing methods were inefficient and very
little product was used in the energy sector. Many countries are
now working on improved systems for use in electric power
generation.
Note: We are also involved in this effort. As an environmental
engineer and inventor of environmental products we have been
involved with energy systems, air pollution and converting biomass
to practical use for over 40 years. CNFbiofuel™ and CNF torrefied
wood™ (formally BioCoal) is our latest patent pending invention and
it holds promise of converting wood into a clean burning fuel. See
www.CNFbiofuel.com for more information.
Technology and economics do not currently allow for many other
practical options for the farmer other than to burn the prunings.
Wood chipping and transporting the chips to a pellet mill or
biomass plant would be ideal and may soon be practical as soon as
efficient biomass conversion to fuel becomes more acceptable. In
the meantime, while it is not practical or economic to justify this
method of energy conversion, it still best to burn the wood
pruning’s.
Farmers cannot allow pruning’s to build up year after year,
allowing them to become a fire hazard and habitat for rats and
vermin in addition to the decomposition gases produced. The
practice of wood chipping has had mixed reviews. Some chips add to
foreign matter in harvested almonds and reduce their value. To
speed breaking down the chips they can be disked into the soil but
that is contrary to the non-till practices that helps reduce fuel
use and keeps PM10 and PM2.5 dust down. It becomes clear that there
are no simple solutions to our many environmental problems but
frequently, unnecessary regulations that only look at one side of
the problem can result in more harm than good.
When dry wood is burned, as in the open burning of pruning’s,
instant smoke and water vapor is visible along with carbon dioxide,
carbon monoxide, methane and other GHG’s plus ash being emitted.
Dryer wood results in more complete combustion with more energy and
water generated. When wood is left to decompose as in disking it
into the soil, most of the biomass will be converted into
considerably more methane , carbon dioxide, and other GHG’s than
with burning. If the fossil fuel energy of chipping and disking is
included along with all the PM10 and PM2.5 generated it becomes
very clear that burning dry wood is a much more earth friendly
choice.
The breakdown of wood products in forests, swamps, wetlands,
farms, soil and landfills are some of the main producers of methane
gas in our atmosphere. The pollution from farm burning, of hard to
handle orchard pruning’s, is insignificant in comparison.
Restricting open burning results in considerable economic loss to
the state, hurts farmers and taxpayers, and the resulting air
pollution problems will become worse not better. It is in the best
interest of the state that restricting open burning be curtailed
until practical methods of transferring ag waste and pruning’s to
biomass facilities for efficient burning. In the meantime continued
ag burning is far less polluting than disking and other options.
Throughout the United States attempts are being made to collect
methane gas from landfills, sludge, animal waste, and other biomass
sources and convert it into useful energy instead of allowing it to
enter the atmosphere.
Biomass is considered Renewable Energy with a zero net addition of
carbon to our environment. California has hundreds of millions of
tons of biomass available for future energy use. At present only
about 1% is utilized for electric energy production. The practical
use of this resource should be encouraged. Biomass offers the only
practical near term solution to meeting our carbon dioxide
reduction goals.
In comparison, the burning of fossil fuel gas, oil and coal is
considered Non-Renewable Energy and contributes 100 percent carbon
compounds to our air environment. Therefore, whenever it is
possible to use renewable biomass fuel instead of fossil fuels our
environment will remain cleaner.
Let’s relax open wood burning rules and allow farmers to continue
with common sense management practices. This benefits us all with
less regulation and less pollution.
2. TABLE “A” COMPARISON of CONTAMINATES & PROBLEMS caused
by: OPEN BURNING OF DRY WOOD Versus DECOMPOSITION
ITEM OPEN BURNING DECOMPOSITION
COMMENTS
Visible Smoke More*
Less Minor Problem
Water More
Less Good
Carbon Dioxide More
Less Good
Carbon Monoxide Less More*
Good
Methane Less More*
Good
Other gasses/ VOC’s Less Much More*
Good
Ash More
Less
Soil Nutrients Less Much
More
PM-10 Less Much
More* Major Problem
PM-2.5 Less Much
More* Major Problem
Rodent Habitat /Fleas Less Much
More* Major Problem
Fossil Fuel Use Less Much More*
Worst Problem
Added Carbon Dioxide Less Much More *
Problem
Expenses Less Much More*
Problem
Time/Manpower Less More*
Problem
Consumer Cost Less More*
Problem
Adverse Health Effects Less More*
Problem
Based on the above chart it would be much wiser to select open
burning of dry orchard pruning’s where mostly water and CO2 are
produced, plus ash & some other gasses. When pruning’s are stored,
chipped, and then disked into the soil much more air pollution and
other problems occur. Long range storage increases rat, mice,
rodent and flea infestations that migrate to populated areas.
Considerable PM 10 & PM 2.5 are generated due to chipping and
disking chips into and disturbing the soil. Decomposition leads to
the release of many greenhouse gasses. Plus 100% of the pollution
from the fossil fuels used is added to our environment. All the
collected suns energy is lost that could have been put to good use
and a waste of a valuable biomass resource.
3. DUST - PM2.5 and PM10:
Significant increases in fine dust PM 10 & PM 2.5 particles enter
the air when farm practices are changed from non-till operations to
disking in wood chips. The fine dust increase may easily be 10 fold
or more. Many farmers have changed to non-till or reduced tilling
operations and the results have proven to be very beneficial to
reducing dust generation. Dust mites and other pest problems are
reduced with non-till operations.
According to the University of Nebraska Institute of Agriculture
and Natural Resources no-till, national cropland soil erosion has
plummeted and the process can reduce soil loss by 90 to 95%. If
open burning is prohibited and chipping and disking occurs, we will
see a dramatic increase in PM10 and PM2.5. That is contrary to the
California Health and Safety Code.
CROPS: In general, it is beneficial to keep orchards and other ag
properties clean of waste biomass and minimize unnecessary
equipment use. Excess fuel consumption and putting dust into the
air is not helpful to plant tissue.
Farmers are constantly resorting to Best Management Practices,
trying and evaluating new tested Methods, and learning how to be
good stewards of the land while being more productive.
Farmers appreciate new ideas, research, safer chemicals, safer
equipment and improved operations. Farmers should be allowed to
decide how best to manage surface pruning’s by open burning instead
of chipping and disking the soil.
4 Energy – Encourage renewable energy in lieu of fossil fuel
use.
Energy exists in many forms. Most of the energy we use is derived
from the sun. This includes fossil fuels, biomass, wind energy and
hydroelectric power. Carbon is the building block of life and is
in all fossil fuels, wood, and all plant and animal life. Fossil
fuels may contain 70 to 95% carbon and wood, trees and plants may
have 50% carbon.
The Carbon Cycle on earth, in a simplistic example as follows:
plants take in carbon dioxide during growth in sunlight. The carbon
from the carbon dioxide gas is changed into a concentrated solid
form that includes sugars and other plant tissue. The plant is in
essence a solar battery that harnesses the suns stored energy in
condensed solid form.
When plants die, decompose or when burned, the captured carbon
compounds are released back into the ambient air and the suns
energy is released. This cycle has been repeating itself for
millions of years. Using biomass for fuel offers the most
opportunity for the near term solution to reducing carbon dioxide
concentrations.
Our firm, along with many others, is working on developing new
processes to convert biomass into useful clean burning fuels. Our
information is presented only as an example of potential renewable
energy solutions. We are in the development stages and do not
produce any product for commercial use at this time. The laboratory
size product we produce is only used in determining calorific
value, ash, and other properties.
The following describes our solution to the global energy and air
pollution problems.
Coal is the most used and it is the dirtiest of fuels.
Considerable efforts are underway by many firms in many nations to
improve Torrefaction technology that will allow for using torrefied
wood as a renewable energy fuel to co-fire with and eventually
replace coal. All prior art Torrefication methods utilize hot gas
or steam in a “convection” heat treatment process. We developed a
unique process of “immersion conduction” of biomass in a high
temperature heat transfer fluid in the absence of oxygen. This puts
over 1,000 times more heat transfer molecules in direct contact
with the wood surface over convection processes. Multiple stages at
different temperatures quickly make the conversion practical.
California, with its tremendous investment in the use of natural
gas for generating electricity has hundreds of millions of tons of
biomass that is simply wasted and left to decompose each year. This
renewable energy biomass could be torrefied and converted into a
solid fuel or gasified to replace fossil fuel natural gas. Many
other nations are now growing energy crops for that purpose.
Torrefied wood has about 10,000 Btu per pound.
California has over 550,000 acres of almonds in production.
Approximately 2,000 pounds of green brush is generated in each acre
per year. That and many other agricultural waste products could be
converted to useful fuels to replace fossil fuels.
Coal contains about 12,000 to 15,000 Btu per pound and is the most
used but dirtiest fossil fuel in use today. No other practical
renewable energy fuel exists to replace the vast amounts of coal at
this time except biomass. About half the out of state electricity
we use is generated from coal burning plants.
Global Environmental Pollution concerns caused by the burning of
“non-renewable” fossil fuels and increases in the atmospheric
concentration of Carbon Dioxide are considered by many, the
greatest threat to our environment today. Coal is considered the
most polluting fuel as it contains many heavy metals, including
sulfur, lead, mercury, and radioactive substances. Many countries
use very poor grades of coal that contain considerably more toxic
substances than the cleaner coal that is becoming scarcer. It may
come as no surprise to learn that many of the health problems
suffered today may be caused by the pollution from coal fired power
plants. It is estimated that California receives over 25% of its
air pollution from outside countries such as China and India. It
may not be long when most of the most harmful pollution we receive
originates from outside the USA. It is to the benefit to all for
California to lead the way in showing the world that the use of
renewable energy should be a major priority. We must address the
reduction of global coal use if we ever hope to solve our Global
Environmental Pollution problems.
Sincerely
John A. Paoluccio PE,
Engineer, Inventor and Farmer
Associate companies involved in development of renewable energy
fuel:
John Paoluccio Consulting Engineers, Inc. – Mechanical /
Environmental
Inventive Resources, Inc. - Environmental Products
CNFbiofuel, Inc. – Developing processing systems for CNF™
torrefied wood pellets
P.O. Box 1316, 5038 Salida Blvd., Salida, CA 95368
Ph: 209-545-1661 Fax: 209-545-3533
Email: johnpaoluccio@sbcglobal.net info@CNFbiofuel.com
www.CNFbiofuel.com
California Registrations: Mechanical Engineer ME15046 Fire
Protection Engineer FP248 Agricultural Engineer AG309 and Class
“A” General Contractor
Home: Modesto, CA 95368. Farm – Operates a small almond
orchard.
|
|---|