Comment Log Display

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
California Registrations: Mechanical Engineer ME15046    Fire
Protection Engineer FP248    Agricultural Engineer AG309


December 6, 2008


Clerk of the Board
Air Resources Board
1001 I Street, 23rd Floor
Sacramento, CA 95814


Subject:   AB 32 Scoping Plan    
                Comments to reduce greenhouse gas emissions in
California


Comments for review and For The Record and Ideas Submitted: 
Please forward copies to the above to appropriate departments. If
requested, I can forward copies to any other party of interest.


In order to make a major impact on reducing greenhouse gas
emissions in California due to fossil fuel use, it is also
necessary to look at Global solutions in addition to all the local
solutions.

The following is a compilation of specific areas where significant
pollution reductions can result in less carbon dioxide, methane and
other GHG’s including PM10 and PM 2.5 from entering our
environment. 

These pollution reductions items include the following:

1.	Wood Burning – Including Open Burning of Orchard Prunings.

2.	TABLE “A” - COMPARISON of CONTAMINATES & PROBLEMS caused by:   
        OPEN  BURNING OF DRY WOOD  Versus  DECOMPOSITION. 

3.	Diesel Irrigation Pumps – Avoid electric motors. 

4.	PM10 & PM2.5 – Encourage non-till agricultural practices.

5.	Forest Land – Capture biomass for useful purposes. 


6.	Energy – Encourage renewable energy in lieu of fossil fuel
use.

7.	BioCoal Fuel – A brief write up on one potential new useful
carbon neutral fuel solution to reduce greenhouse gas emissions.


1.  Wood Burning of Orchard Prunings & Biomass Use 

It is recommended that rules on open wood burning be relaxed. The
burning of orchard pruning’s results in considerably less polluting
that any other option available today. 

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 harmful GHG’s. The burning of
wet wood should be discouraged. 

If wood is allowed to decay by natural means, including
decomposition by ants, termites, microbes, fungus, etc. Then,
carbon dioxide and methane gas is generated and released along with
other GHG’s. Methane is one of the major primary airborne
contaminant generated on earth. 

By burning the 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 as a fuel in
electrical power production.  

If this renewable 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,
and many others. 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. BIOCOAL Fuel
is our latest patent pending invention and it holds promise of
converting wood into a clean burning fuel. See www.biocoal.net 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 is best to burn the wood
prunings.

Farmers cannot allow prunings to build up year after year,
allowing them to become a fire hazard and habitat for rats, ground
squirrels and other 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. 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 levels down. It becomes clear that there
are no simple solutions to our many environmental problems but
frequently, unnecessary regulations can result in more harm than
good.   

When dry wood is burned, as in the open burning of prunings,
instant smoke and water vapor is visible along with carbon dioxide,
carbon monoxide, methane and other GHG’s plus ash being emitted.
(Note: Dry pruning’s may contain over 22% moisture.). When wood is
left to decompose it may take years to break down but over 10 times
as much methane may be generated.  If one looks at the big picture
it becomes 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 prunings, is insignificant in comparison. 

These no burn laws can result in considerable economic loss to the
state, hurt farmers and taxpayers, and the resulting air pollution
problem will become worse not better. It is in the best interest of
the state that these anti wood burning laws and regulations be
delayed, modified or rescinded until practical methods of
transferring ag waste prunings to biomass facilities for efficient
burning is worked out. In the meantime continued ag burning is far
less polluting than not.

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.. 

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		     
Carbon Dioxide                 	     More                     
Less
Carbon Monoxide     	     Less                      More*
Methane                   	     Less                      More*
Other gasses/ VOC’s 	     Less                      Much More*
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
Energy Policy                     Good                     Not
Good*                  Problem
Based on the above chart it would be much wiser to select open
burning of dry orchard prunings where mostly water and CO2 are
produced, plus ash & some other gasses.  When prunings 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
discing 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 particles enter the air when
farm practices are changed from non-till operations to discing in
wood chips. The fine dust increase may easily be 10 fold or more.
Many farmers have changed to non-till 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.


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.   

Regulations should be modified to allow for best management
practices to prevail.


4.   Forest Measures:

The environment would be better served if dead forest timber and
debris were harvested for commercial use. If left to stand and
ultimately decompose or catch on fire, it produces significant
quantities of carbon monoxide, methane and other GHG’s. 

By harvesting dead timber and clearing built up debris, new growth
will be encouraged. It is new growth that extracts more carbon
dioxide from the air. That does a tremendous amount of short term
good in reducing air pollution. And a new healthy forest is
generated. 

New potential breakthrough:  One major problem with all forms of
carbon sequestering is that when wood decomposes the captured
carbon is released back into the air environment and the stored
suns energy is lost. What is needed is a method to interrupt the
Carbon Cycle to prevent the wood from decomposing for the long
term. We have developed a patent pending new processing method to
accomplish this with a carbon offset product called BioCoal Fuel.
Tests have shown the new bio-fuel is hydrophobic, is resistant to
decomposition by insects, ants, termites and microbes. This
breakthrough and other new processes that utilize renewable energy
biomass offer the best opportunity to solve our air pollution
problems as we turn away from fossil fuels. More information is
available at www.biocoal.net. It will no doubt take many new energy
solutions and it would be very helpful if the ARB would devise a
Product and Process Evaluation Form that lists the pros and cons
for any and all new methods to reduce greenhouse gas emissions. 
This may include energy input to produce one pound of bio-fuel,
heat output available per pound of bio-fuel, gasses generated, ash
generated, soil, liquid or gas form, etc.



5.   STATIONARY DIESEL ENGINE CONTROL MEASURES
(The conversion of irrigation diesel pumps to electric motors.)

The ARB regulations are intended to reduce diesel exhaust
emissions from the estimated 8,600 stationary engines operating Ag
irrigation pumps. The regulations require that old diesel engines
to be replaced with more efficient diesel engines or electric
motors. Farmers would most likely install electric motors in lieu
of the more complex and expensive new type diesel engines.  The
changeover should be voluntary.

When a large percentage of the 8,600 engines are converted to
electric motors, the electric power grid will have to accommodate
the additional peak load of all the engines converted. Power plant
inefficiencies and transmission losses are several times the end
load and that would result in more pollution generated at the power
plant. 

Throughout the world, most nations use coal as the primary fuel
for producing electricity. Coal is the cheapest and the dirtiest of
the fossil fuels. California has in recent years shifted more to
natural gas for electric power production.  Natural gas is
expensive and the cleanest burning of the fossil fuels but is
limited in supply and the general population depends on it for home
heating. 

Imported electric power from other states must meet new strict
pollution standards that many coal plants have difficulty meeting.
California has been known to be a leader in environmental matters
and technical advances.  However, other states and nations that
depend on coal use do not have the option for natural gas use. In
order to make a major impact against Global Warming we must reduce
mainly coal and other fossil fuel use. As natural gas becomes
scarcer California will need to rely on more coal use. California
should encourage coal fired plants to utilize co-firing with
biomass to reduce the net carbon dioxide emissions to less than
natural gas fired power plants.
 
It is also recommended that a cost analysis and comparison of the
pollution generated from leaving the diesel engines “as is” versus,
changing them over to electric motors be conducted, prior to making
any changes. The change option should be left to the farmer or pump
user.

Most of the diesel pumps are used for occasional pumping and
operate a small number of hours per year. Unlike electric power,
the diesel powered engine does not have the tremendous transport
losses of energy. It is its own power plant. From an energy and
pollution standpoint, the diesel engine should generate less
pollution than converting the pump to electric power. The use of
independent diesel engines is a smart design and puts no strain on
our electric grid system. 

Results that may occur if diesel engines are converted to electric
motors:

•	Converting to electric use may end up with more fossil fuel
being used. 
•	Fossil fuel energy is consumed to manufacture the new electric
motors.
•	Conversion adds significant peak loads to the electric power
grid. 
•	New electric power plants will need to be constructed.
•	Additional power will need to be purchased from out of state.
•	Peak summer loads would be detrimental to the electric power
grid.
•	Consider the high cost of replacing pump engines with motors.
•	More fossil fuel use results in more carbon dioxide and other
pollution.
•	The cost for implementing this regulation may run in the
billions of dollars.
•	Add all the additional paperwork, frustration and manpower.
•	Farm product costs will increase and taxpayers will pay more. 
•	Californian farmers will be less competitive, imports increase
and jobs lost.

We should be trying to discourage peak electric power use and
encourage conservation and more renewable energy use.  The periodic
operation of diesel driven pumps keeps the power needs “off” of the
electric grid. 

We should also encourage farmers to consider using renewable
bio-diesel fuel to reduce net air pollution and improve existing
engine efficiency.  


6.   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 approximately 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. 

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 Global Warming. 


7.   BIOCOAL Fuel - A Potential Global Solution to Global Warming
& Climate Change.

Developing useful energy from renewable biomass is gaining global
attention. Many scientists believe that biomass holds the key to
solving our global energy and pollution problems. We agree and have
been involved in this effort. 

As one of many firms involved with developing new and improved
energy systems we wish to share our information as an example of a
promising new biomass processing method in helping solve our global
energy and pollution problems. 

The new fuel is an enhanced form of biomass in the form of
torrefied wood pellets. A high temperature “immersion conduction”
processing system removes the water and VOC’s from the wood and
treats the wood in an oxygen free environment. The wood pellets
undergo an endothermic reaction where the molecular structure and
chemistry is altered to a plastic like state so it burns clean. 
This new fuel is considered a near term solution and could be
brought on line in months to immediately provide renewable energy
and reduce pollution. It may be a global solution to the world’s
energy and pollution problems.

Over 8 billion tons of coal equivalent fossil fuel is used each
year. The market for this new fuel includes co-firing with coal and
replacing coal in the long term for clean electric power
generation. It has immediate application as a long life storable
product for “Carbon Offsets”. This fuel allows existing coal fired
plants to co-fire and lower greenhouse gas emissions. It also
becomes an ideal feedstock for gasification systems.  
No changes to existing coal fired plants are required. The new
fuel is friable and can be co-fired at 15% in the near term and
100% in the long term. In a preferred form of the invention the
product is in the form of Enhanced Torrefied Wood Pellets. 
All fossil fuels, like biomass, contain carbon and hydrogen atoms
in long chains. The fossil fuels have high carbon content with
little moisture. Wood materials contain high levels of moisture and
volatile organic compounds that result in incomplete combustion
when burned. That is one of the reasons wood in not generally
accepted as a practical fuel for energy production. Through a new
“Conduction” processing method this technology can quickly turn
biomass into clean burning BIOCOAL Fuel. This renewable energy fuel
is essentially moisture free with very little VOC’s. The heat
content is over 10,000 Btu per pound. The products of combustion
are mainly water and (neutral) carbon dioxide. The new process
produces finished product quickly, efficiently, economically, and
with little energy use. No outside power is needed for large self
contained facilities.
The energy from the sun holds the best promise of solving our
global energy and pollution problems. Biomass is the most plentiful
source of renewable concentrated carbon but until now, all attempts
to utilize this free source of the suns energy has met with
technical difficulty and costly extraction solutions. Bio-diesel
and ethanol are examples of the liquid forms of bio-fuels that
require complex processing and high energy use to turn the biomass
into usable forms of energy. Virtually all other biomass forms of
energy have run into similar technical difficulties and that is why
they are not used extensively. What has been needed is a
breakthrough in converting wood into a practical and clean fuel.
BIOCOAL Fuel is one such breakthrough. It uses biomass feedstock
such as pruning’s, ag waste, landfill wood waste, forest debris,
lumber waste, grasses, energy crops such as Switch grass, and many
other biomass sources that would otherwise be left to decay, break
down, decompose or be burned. When this occurs we lose all the
benefits of the suns energy plus we allow the re-entry of all the
methane, carbon dioxide and other GHG’s per the CARBON CYCLE of
Nature. This new fuel product will not break down like wood and
other plant material. It makes an ideal Carbon Offset because it
resists all forms of natural decomposition. Plus it is a clean
burning renewable energy fuel. 
Global Warming and Climate Change caused by the burning of
“non-renewable” fossil fuels and increases in the atmospheric
concentration of Carbon Dioxide are considered 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 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 Warming and Climate Change
problems.
With all the conservation efforts, new liquid bio-fuels being
used, and improvements in transportation, the air pollution problem
will still get worse until we find a new fuel for producing clean
electric energy. The area of greatest need is the development of a
new fuel to replace “COAL”. BIOCOAL Fuel is a renewable energy
solid fuel that is designed to replace coal. It can also reduce oil
and natural gas use. BIOCOAL Fuel is the most practical utilization
of the stored suns energy in biomass. Not only does it burn clean
but it utilizes all the waste biomass that if left to decompose,
would re-introduce all the methane, carbon dioxide and other carbon
compounds back into the environment plus wasting the stored sun’s
energy. 
In addition to putting to use all the available waste biomass,
changes will be required in land use issues related to the growing
of energy crops such as Switch grass. New farming practices will
put low quality land to use in growing energy crops, harvesting,
milling and processing plants will also be needed. New industries
would be formed and millions of new jobs would be created. 
We believe that biomass related solutions, and in particular, this
new technology has the long term potential of removing billions of
tons of carbon dioxide every year from our global environment.
Virtually all coal could stay in the ground and we would use oil
for new products of the future. 
The BIOCOAL Fuel website can be viewed at www.biocoal.net.

Sincerely


John A. Paoluccio PE
Engineer, Inventor and Farmer

Work: John Paoluccio Consulting Engineers, Inc.  – Mechanical /
Environmental 

Work: Inventive Resources, Inc.  -  Environmental Products /
BIOCOAL Fuel

P.O. Box 1316, 5038 Salida Blvd., Salida, CA 95368
Ph: 209-545-1661   Fax: 209-545-3533   
Email: johnpaoluccio@sbcglobal.net    info@biocoal.net
www.JPCE.com & www.biocoal.net

Home:  Modesto, CA 95356.  Farm – Operates a small almond
orchard.