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Comment 13 for Short-Lived Climate Pollutant Strategy (slcpstrategy-ws) - 1st Workshop.
First Name: John
Last Name: Haeckel
Email Address: jhaeckel@cleanfuelpartners.com
Affiliation: Clean Fuel Partners, LLC
Subject: Follow up comments to Workshop
Comment:
My comments are from the perspective of the CEO of a start-up which sees great potential to deliver business solutions to environmental issues through biorefineries (we want to capture methane as well as strip out nitrogen and phosphorous from digestate): 1. As you think through what I expect will be incentive structures to encourage adoption, I think that fostering highest and best end uses for the outputs as an economic matter will help projects to attract private capital on an un-subsidized or limited subsidy basis, creating enormous leverage for the incentive dollars you may recommend. I would be happy to share my basis for suggesting this. 2. If you have not created one, it may be useful to develop an inventory of organic waste streams either created by state entities/agencies/etc. or where the disposition of waste streams is directed by the state in one way or another. Subject, of course to contractual and/or other commitments, this creates for you an economic tool to encourage private capital participation by helping solidify one key component of the equation – input sourcing. 3. While it is not my current focus, I have spent a fair amount of time, dating to a year ago, exploring the use of liquefied natural gas (“LNG”) as a marine fuel. My question/comment for you is please not to leave the shipping industry out of the equation. If diesel is bad for the environment, residual fuel oil is much worse. Although Emission Control Area restrictions should cause a shift to somewhat more environmentally friendly fuel grades for SOx and NOx compliance, that is ultimately a function of compliance. I have not kept up on it, so do not know the recent history of experience with compliance.
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Date and Time Comment Was Submitted: 2015-06-02 07:16:02
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