Comment Log Display

Dear Sir / Madam:

We would like to bring to your attention the following sentence in
Section 95125(h)(2) that might lead to some confusion in its
interpretation:

"The operator that combusts fuels or fuel mixtures that are at
least 5 percent biomass by weight and not pure biomass, except
waste-derived fuels that are less than 30 percent biomass by
weight of total fuels combusted for the report year, shall
determine the biomass-derived portion of CO2 emissions using ASTM
D6866-06a as specified in this article."

It is presumed that plants that elect to label their fuels as less
than 5 percent biomass by weight or waste-fuels as less 30 percent
biomass by weight will do so with the knowledge that the entire
fuel mix will be classified as a fossil fuel. In our opinion, the
first sentence in section 95125(h)(2) is not clear with regard to
this point.

There are two possibilities to remedy the ambiguity of the first
sentence in section 95125(h)(2). The first possibility is to
recommend that the ASTM D6866-06a method be used for all
heterogeneous fuel mixtures. As such the sentence could read as
follows:

"The operator that combusts fuels or fuel mixtures that contain a
mixture of biomass and fossilized materials shall determine the
biomass-derived portion of CO2 emissions using ASTM D6866-06a as
specified in this article, unless the operator wishes to report
all their CO2 emissions as fossil-fuel."

Alternatively, you could elaborate on the first sentence of
section 95125(h)(2) with this sentence added to the first
sentence: 

"........ Operators that combust fuels or fuel mixtures that are
less than 5 percent biomass by weight and not pure biomass, or
waste-derived fuels that are less than 30 percent biomass by
weight of total fuels combusted for the report year, can elect to
report all their fuel mix as 100% fossil fuel if they do not
determine and report the biomass-derived portion of CO2 emissions
of their fuel using ASTM D6866-06a."

Please call or email us if you have any questions regarding this
comment.

Sincerely,

Thierry Sam Tamers
Director

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