See also:

• Release of Public Comments on Draft Strategic Plan.  Announcement (dtd 21 Dec 2005) from the U.S. Climate Change Technology Program.  Also available in PDF format.
• List of Commenters.  Also available in PDF format.
• List of Supplemental documents.  Also available in PDF format.
• Strategic Plan, Draft for Public Comment.  Review draft (dated September 2005).

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Landfills are brushed over in this chapter and mostly discussed in the context of methane emission containment. The use and management should be afforded a much deeper and comprehensive investigation. Research must be invested into reversing the practice of deposing biodegradable materials in landfills, so that they can be turned into energy either in the form of a gas that can produce electricity or biofuels.

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A reference is needed for the scenarios discussed in this sentence. Also, the potential reduction in non-CO2 gas emissions should be put in the context of the projected CO2 emissions, which range from 983-2189 GtC for 1990-2100 in the SRES illustrative scenarios (IPCC (2000), Table SPM-2b).

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Collection and destruction of methane from landfills at a scale of 2.5 million metric tons of waste in place is required under USEPA regulations in order to achieve incidental control of non-methane organic compounds typically found in landfill gas. Landfills of this size and larger typically produce over 500 cubic feet per minute (CFM) of methane, which is capable of producing more than 1 MW of power with commercially available equipment. Economically attractive technology is available and commonly in use for conversion of methane to energy at landfills in this size range, both in the US and globally. Marketplace drivers to improve technology at this scale are already operating.

However, most landfill sites in the US and globally are smaller than this, yet contribute significantly to methane emissions. These smaller sites have neither regulatory nor economic drivers in place to motivate the landfill owners to capture and destroy the methane. Existing energy conversion technologies do not allow breakeven economics for conversion of methane to useful energy products at this scale, with very few exceptions.

An effective technology strategy for government intervention to increase capture and conversion of landfill methane therefore should include a component that focuses on small scale landfills that are currently below the regulatory and economic breakeven thresholds for methane capture and energy conversion. This would generally be for landfills designed to hold less than 2.5 million metric tons of waste, that would produce less than 500 CFM of methane. Furthermore, focus on the methane energy conversion technologies in this range (less than one MW) would also provide incentives for alternative waste processing technologies that produce methane, including bioreactor landfills and anaerobic digestion.

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Section 7.1.1.3

There are two categories in the current portfolio: bioreactor landfills and emerging technologies for the conversion of landfill methane.

In the bioreactor landfill category, a significant number of the current full-scale demonstration projects are at landfills that were not designed as bioreactor landfills, i.e. where bioreactor technologies are retrofit in existing landfill sites. While these projects are valuable, the data has only tentative applicability to future bioreactor landfills that are designed "from scratch" as bioreactor landfills. The latter will have monitoring systems, drainage systems, and gas collection systems designed from the beginning, rather than retrofitted, to be used in bioreactor landfill operations, and will not have partly decomposed wastes in place from a time before bioreactor operations were implemented. Funding should be focused on new landfills (or new, separate, landfill cells at existing sites) that will produce data that can be used in design of future facilities.

In the energy conversion category, there is a focus on LNG production. There are many other technologies that may be developed to convert methane to energy, including small scale engines and turbines such as Rankine cycle, Stirling engines, and microturbines and associated generators that could benefit from technology development. This category of the portfolio should be broadened to not focus narrowly on LNG.

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With regard to landfill methane, why not concentrate some RD3 on separating the components of waste and gasifying the hydrocarbon fraction to produce hydrogen and/or electricity and sequestering the resulting CO2. The other components of the waste could be recycled or reused. Only a small fraction would need to be landfilled. This is an old idea, but it could do with some dusting off and reinvigoration.

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Specific Comments on Chapter 8.4 Enhancing capabilities to measure and monitor greenhouse gases

The Aluminum industry is currently participating with EPA in advancing the measurement of PFC emissions from aluminum primary production faculties. These efforts have lead to improved monitoring and measurement methods, as well as advancements in the accuracy of emission factors. These efforts should be continued and added to the Strategic Plan.

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In support of Implementation Next Steps, Core Approach #3: Enhance Opportunities for Partnerships, we recommend two additional activities:

- Establish an information sharing program that will provide basic guidance to the private sector on modeling, analyzing, measuring/monitoring, and reporting of emissions data. This would enhance the Integrated Measurement and Monitoring System Architecture (Figure 8-2), enable faster and more accurate benchmarking and assessment of GHG reduction actions, and reduce overall implementation costs to the U.S. economy through various commonalities of R&D software and hardware technology and processes.

- Utilize Participant Indicative Data Obfuscation (data masking) software technology to allow private sector companies to provide data anonymously into the Program if they wish to do so. Privacy of data and information must be considered as a crucial factor in convincing early adopters of climate change technologies to provide corporate data.

In support of Implementation Next Steps, Core Approach #7: Provide Supporting Technology Policy, we recommend three additional activities:

- Establish criteria for use of robust and scalable analytical data management and decision support systems that can transition across different climate change technology development platforms as they are developed over the near term timeline (to 10 years from present). This would help Federal agencies 1) leverage their R&D investment in analytical data management and decision support systems across different climate change technology development platforms and timelines 2) allocate more federal budget dollars for emissions reduction and emissions monitoring technology work and 3) maximize their R&D information technology return on investment (ROI).

- From the outset of the Program, establish criteria for software and systems development that effectively integrates measurement and management of emissions data with the modeling and mining of emissions data. This would include systems development for national and local emissions inventories, carbon budget estimates, emissions reduction modeling and estimates, emissions measurements, and so on.

- Identify those data modeling, data management and decision support systems that are immediately required. These R&D software and hardware systems would include:

* Large scale aggregated data warehouses and a supporting data framework that would provide a common access platform to researchers and hold baseline data on CO2 sequestration, energy efficiency technological developments, etc.

* Databases to hold an inventory of the monitoring equipment utilized in R&D and data models to analyze this equipment information. We believe that data mining and modeling on this monitoring equipment data could reveal critical device related trends that can negatively or positively impact GHG measurements. All readings must be traceable to their originating measurement device or proxy.

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The Measurements and Monitoring Framework for the Climate Change Technology Program Strategy as mapped appears to be one-directional, from supply to demand only, with no looping back of information from demand side actors. This would not support a more granular breakdown of field data required for voluntary benchmarking assessment of private sector results.

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We recommend that Figure 8-1 show the demand side actors providing data to contribute to the integrated information required for benchmarking of results against expectations.

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Data exchange protocols must be defined and agreed to well before deployment to ensure required information is captured or calculated at each source. We recommend the use of service oriented architectures that will 1) decouple requestors from databases and permit users in any area of R&D to utilize common calls to access data from any source and 2) seamlessly merge content from multiple R&D sources irrespective of the specific source’s content.

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Of the three methods of CO2 sequestration presented, geologic, terrestrial, and oceanic, we’ve assessed that oceanic sequestration presents the highest levels of risk and risk management requirements to both public and private sector participants. This is due to the lack of supporting demonstrable scientific experiments and environmental impact studies as mentioned. We would like to add a third level of risk, which is the lack of clear ownership of location. The lack of clear ownership of location, for example in the case of international waters, presents an additional risk management challenge that does not exist in geologic and terrestrial sequestration since these occur within national borders. This lack of clear ownership of location and subsequent lack of oversight could present future data traceability and data monitoring challenges, unless clear restrictions are put on location of oceanic sequestration activities and special procedures are developed to prevent leakages beyond these locations. We therefore recommend that the Program make note of the higher level of risk associated with oceanic sequestration along with possible risk mitigation strategies, which could include scientific, technology, legal, and insurance-based risk mitigation actions and hedges.

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We believe that the statement :software development that allows further integration of measurement data with emission modeling processes can lead to improved estimates" should be seen as an overall goal of the U.S. Climate Change Technology Program in all areas of climate change technology development. This goal should also be applied to Section 8.2 Energy Production and Efficiency Technologies, Section 8.3 CO2 Capture and Sequestration, and Section 8.5 Integrated Measurement and Monitoring System Architecture. All of these areas would benefit significantly from a tighter integration of data measurement and modeling processes and software systems.

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Geographic distribution of SO2 and carbon black is important, yet the measurement and monitoring of these is not mentioned.

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The Integrated Measurement and Monitoring System Architecture would benefit from an identification of actors, for example, who makes the predictions and observations, who implements and manages the decision support systems and management systems, and who takes GHG reduction actions. Currently the only actor inferred is the public sector utilizing the federal observations systems and models. However given the expectation of adoption of climate change technologies by the private sector and the requirement for benchmarking of planned improvements against current capabilities, then field data will be required from companies for calibration. We recommend that participation from public sector and private sector actors be more clearly noted in the System Architecture Figure 8-2.

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Basic research is an important component of the technology development process, and CCTP is to be commended for including it as one of the program’s strategic goals. However, basic research needs to be subjected to the same management criteria as technology development. Appropriate criteria for success need to be established for basic research projects. These should be articulated in the strategic plan as should the manage-ment process for ensuring that basic research will be a productive component of the CCTP.

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Chapter 9 discusses the science of estimating future climates. Great strides have been made in computational skills. However, the promise of estimating future earth temperatures is questionable, since today we can not take yesterday’s climate data and hind cast yesterday’s weather conditions. Thus, projecting the future is not possible.

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Good overview of how to broadly and effectively select and focus R&D.

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While modeling is acknowledged to play a key role in the necessary technology development to reduce greenhouse gas emissions in the United States, the draft could be much more specific in the necessary modeling capabilities that are required.

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Chapter 9 discusses lighter automobiles, and fission energy, but is silent on the use of nuclear power plants. Nuclear power is available now. It is clean, low cost and affordable. However, with all the years of nuclear power, government has not been able to solve the waste problem. Government has studied the burial of the waste, but the problem is still sitting in pools of water: waiting. If we cannot solve the nuclear waste problem, how will we develop new energy generating system without creating more problems to solve?

Chapter 9 falls back on wind and solar power, but no one has made a life cycle economic analysis of either of these forms of power. The low voltage generated means batteries and transformers must be involved. Base on the life of my car battery, I can envision high maintenance and replacement cost. Also, the energy required to fabricate structures, batteries, blades, transmission lines appear staggering. We are having difficulty maintaining our current grids, without adding to the burden by spreading the generating sources to windy or sunny places.

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The following key areas of modeling are mentioned:

* Improved models of the aerodynamics of wind turbines and other fluid dynamics processes

* Computer-assisted simulations of proposed advanced components and energy systems

* Predictive modeling of physical systems.

I believe these are too vague and the following specific areas need to be included:

-Three dimensional Computational Fluid Dynamics modeling for Generation III and Generation IV nuclear reactors.

This should include coupling of neutronics physics to heat transfer and fluid dynamics, as well as three dimensional models for critical heat flux or dry-out prediction (the latter being relevant for Generation III reactors). Significant validation is also required for these powerful models to be used in a regulatory environment.

-Development of Computational Fluid Dynamic modeling capabilities related to the Advanced Fuel Cycle Initiative (AFCI)

The UREX+, PYROX, and SANEX/DIAMEX processes all involve fluid mixing coupled to chemical reaction, precipitation and/or electrochemical processes in the liquid or gaseous phase. Spallation of liquid metals is an additional complex fluid dynamic process that is key to accelerator driven transmutation. Coupling these physical models to the fluid dynamics will be important for scaling up these processes.

-Further development of tools to model gasification accurately and reliably

This should include multiphase model development. Existing models need to be further developed to improve computational efficiency for the unsteady flows found in gasification combustion systems.

Ash, slagging, and fouling are some of the most important technical challenges facing gasification systems, and the relevant CFD models need to be developed and validated.

Mercury absorption models for CFD have been developed for sorbent injection within traditional coal-fired power plants, but the mechanism will be different for gasification plants, and these models need to be further developed.

-Further development of CFD combustion models for NOx, SOx formation

While the focus of the program is greenhouse gas reduction, any fossil fuel combustion process will need to address NOx and SOx formation. Current CFD models for the formation of these species are empirical, and detailed chemical mechanisms are too inefficient to use for practical problems. New efficient models need to be developed. This will assist in improving emissions from processes in all industries using fossil fuels or bio-fuels.

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Strategic Research is at the heart of Pasteur Quadrant basic research needed by applied technologies. However, not many explicit examples are given. Instead paragraphs contain italics phrases that are not elaborated. For example, under transportation on p 9-7 the first paragraph italicizes "materials science" and "joining and welding science." What are the particulars that go with these phrases?

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Not all under "carbon capture and geologic repositories" seem to fit that heading. For example the basic biological research paragraph and the genomics research paragraph don't seem to fit.

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transforming it to another form of carbon that may be more useful, or more safely or permanently stored.

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Research on methods of enhancing the abiotic uptake of CO2 by the ocean, and/or storing carbon in the ocean in forms other than acid-producing, easily degassible CO2 will also be considered.

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Exploratory Research is an important key to innovation. I applaud you for identifying and highlighting it. No idea is presented about how Exploratory Research will be organized, managed or even initiated, however. I suggest consideration of the paper called Climate Change Technology Exploratory Research (CCTER) as a seed money approach to organizing Exploratory Research. This seed money activity could be carried out within or outside DOE. I prefer the option of a not for profit corporation funded by DOE, other agencies and the private sector to administer the seed money endeavor. It would be part of CCTP, but not part of DOE. This paper is on the web at www.cpc-inc.org.

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genomics, chemistry, biotechnology and bioengineering. Also, relevant to CO2 capture and sequestration, the natural chemical reactivity of CO2 could be exploited to remove CO2 from the air or from waste streams, while forming stable, storable carbon compounds or useful products.

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Integrative concepts. Integrative concepts cut across R&D program lines and attempt to combine technologies and/or disciplines. An example might be a scheme that combines sequestration of carbon in soils with the development of a novel form of bio-energy.

My suggestion is: "Another example might be the development of fundamental understanding of the Vehicle-to-Grid (V2G) impact on global energy sector and climate change".

Integrative concepts might be difficult to coordinate across agencies or across traditional R&D program or mission areas; hence more concerted effort might be required to explore such concepts and manage research in these multi-mission areas.

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Scientific breakthroughs need to be pushed toward energy technology applications. This is being done more and more effectively by BES and BER, but something like the old ECUT program might be worth reconstructing to pursue science push more systematically.

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Chapter 10 seems to take the place of an Executive Summary. That is OK, but perhaps it should be acknowledged up front. Chapter 10 is not really an executive summary, however. I think one is needed.

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Chapter 10, Conclusions and Next Steps, seems to underplay the role of renewables. For example, the central role of biomass for carbon neutral fuels and to offset the carbon emissions from transportation should be more explicitly highlighted.

Chapter 10, The importance of terrestrial storage is underplayed.

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Under Presidential leadership, and in partnership with others, the United States is now embarked on an ambitious undertaking to develop new and advanced climate change technologies. These technologies have the potential to facilitate a global shift toward significantly lower greenhouse gas (GHG) emissions, and do so at substantially lower cost, while continuing to provide the energy-related and other services needed to spur and sustain economic growth.

- I don’t see much leadership from the President in pushing for legislation that could substantially reduce GHG emissions within the next few decades. Far from being an ambitions undertaking, I see the plan as an effort to appear to be doing something significant while delaying any real action until the costs to human societies and natural ecosystems are obvious to everyone. By then it may be too late.

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Figure 10-1

Inconsistencies.

Cost and durability are the major barriers to Fuel Cell commercialization. The vehicle technologies research programs have a number of specific goals (see: Chapter 4: Reducing Emissions from Energy End Use and Infrastructure - Page 5, Line 5 to 16). For transportation applications, which have the most stringent cost and durability requirements, fuel cell costs need to be decreased by a factor of 5,1 and durability needs to be increased by a factor of 3 to be competitive with current vehicle technologies (see: Technology Options for the Near and Long Term Report: Section 2.2.5 Page 14).

Actually the vehicle technologies research programs fixed these goals for the year 2015 (see: Chapter 5: Reducing Emissions from Energy Supply, Page 9, Line 10 to 14) and also the 2005 U.S. Energy Bill decrees that: “the Secretary shall submit to Congress a report describing ...(4) progress, including progress in infrastructure, made toward achieving the goal of producing and deploying not less than — (A) 100,000 hydrogen-fueled vehicles in the United States by 2010; and (B) 2,500,000 hydrogen-fueled vehicles in the United States by 2020”.

From my point of view if all actual RD&D, technical and cost barriers are overcame by 2015 and the U.S. Energy Bill goals are achieve by 2020, the H2 Fuel Cell Vehicles will be a “Near Term ” technology and not a “Mid or Long Term ” technology (as indicated in Chapter 10: Conclusions and Next Steps in Figure 10-1: Roadmap for Climate Change Technology Development and Deployment for the 21st Century, Page 3; and Chapter 4: Reducing Emissions from Energy End Use and Infrastructure Page 3, Line 7 and Page 4, Line 21).

U.S. Energy Bill, 2005, http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_bills&docid=f:h6enr.txt.pdf Sec. 811, Page 259.

Near Term: “near-term” envisions significant technology adoption by 10 to 20 years from present, “midterm” in a following period of 20-40 years, and “long-term” in a following period of 40-60 years. See: Chapter 10: Conclusions and Next Steps - 10.1 Portfolio Priorities and Current Emphasis Figure 10-1: Roadmap for Climate Change Technology Development and Deployment for the 21st Century, Page 3.

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The timelines established give no opportunity for hydrogen internal combustion engine (ICE) vehicles. Those vehicles could easily be on the road today if there was a refueling infrastructure. ICE vehicles require only minimum modification in order to run on hydrogen and would greatly reduce not only greenhouse gas emissions, but the 100% known danger of air borne pollutants. If a hydrogen fueling infrastructure existed...even a minimal one... it would pave the wave for even more efficient fuel cell vehicles. BMW and Ford among others have plans to produce hydrogen ICE vehicles. Energy Conversion Devices has modified a Toyota Prius to run on hydrogen. Hydrogen ICE vehicles can deliver almost zero emissions and they can do it today. Offering hydrogen as fuel choice is imperative for America’s energy independence, for the reduction of air borne pollutants, and for reducing green house gas emissions. America was founded on the concept of free markets and competition. Our reliance on foreign oil has stifled that competition and freedom and is sending the money of Americans to foreign lands...and often lands that are hostile to us. Establishing hydrogen as a fuel choice would spark a new flow of competition amongst native coal, ethanol, nuclear, wind, solar, and hydro companies to produce hydrogen at a low cost using new methods. The industry needs government support to establish rules and regulations that allow hydrogen to be a transport fuel. According to Air Products, the hydrogen already produced to day would be sufficient to fuel 250 million fuel cell vehicles (http://www.airproducts.com/Products/LiquidBulkGases/
HydrogenEnergyFuelCells/FrequentlyAskedQuestions.htm). The United States knows how to produce hydrogen and we know how to ship it and transport it to industries. We need to take that the extra mile now and make it available at the pump to US consumers.

Additionally, representatives of both Ballard Power and General Motors testified before the US Senate on July, 27 2005 that they expect to have fuel cells for vehicles that would be competitive on price and performance with traditional gasoline internal combustion engines by 2010 if produced in volumes of 500,000 or more. Without a fueling infrastructure, it will obviously be impossible for them to achieve that goal. The timeline established in figure 10-1 has fuel cell vehicles coming into play in 2025 at the earliest, while in the July 27, 2005 testimony of Larry Burns and Dennis Campbell you have the key players in America’s big 3 automotive companies stating fuel cells could be ready in 2010. I believe that time line needs to be adjusted.

The testimony that Larry Burns (VP of Research & Development at GM) gave before the US Senate can be found here:

http://energy.senate.gov/public/index.cfm?FuseAction=
Hearings.Testimony&Hearing_ID=1490&Witness_ID=4233

The testimony that Dennis Campbell (CEO at Ballard Power) gave before the US Senate can be found here:

http://energy.senate.gov/public/index.cfm?FuseAction
=Hearings.Testimony&Hearing_ID=1490&Witness_ID=4234

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Initial deployment of fusion energy is planned for the "mid-term" as defined here, and large-scale fusion deployment is planned for the "long term" as defined here. The figure should be so modified.

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The "Roadmap" in Figure 10-1 (p. 10-3) appears to be a reasonable delineation of the short-, mid-, and long-term objectives of technologies, but the three proposed 20-year time frames extend too far out in the future, recognizing that not each and every one of the technologies listed in the columns may be realized when expected. The more realistic time frames that we have proposed above correspond to reasonable time frames for the energy supply technologies grouped in subsection III.H.2 below. As to anything beyond 45 to 50 years, that is far too speculative for meaningful analysis.

8 Intergovernmental Panel on Climate Change Special Report on Carbon dioxide Capture and Storage, Summary for Policymakers at 8 & n. 12 ( Sept. 25, 2005).

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"With some overlap, ‘near-term’ envisions significant adoption of at least some of the technologies in the column by 0-10 years from present, ‘mid-term’ in a following period of 10-20 years, and ‘long-term’ in a following period of 20-45 years."

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We believe that energy supply technologies for electric utilities should be included as follows:

− Short-term: advanced clean coal technologies (e.g., IGCC, supercritical pulverized coal), Regional Carbon Sequestration Partnerships, Carbon Sequestration Leadership Forum, Nuclear Power 2010, Advanced Fuel Cycle Initiative, hydro and non-hydro renewables.

− Medium-term: carbon capture and storage, FutureGen, Gen IV nuclear, advanced renewables.

− Long-term: fuel cells and hydrogen-linked generation, international magnetic fusion experiment (ITER), widespread renewables enabled by advanced electricity storage and enhanced transmission infrastructure.

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Biological/terrestrial sequestration, pages 10-4 and 10-8:

We support "R&D programs in advanced forest. . .systems" (p. 10-4)

and the concept that the government should "evaluate various technology policy options for stimulating land-use and land management practices that promote carbon sequestration and GHG emissions reductions" (p. 10-8, lines 24-25).

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regarding the technical, economic, and environmental acceptability will need to be explored and critically evaluated.

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Important research activities currently include: (1) the international Carbon Sequestration Leadership Forum ...

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The beginning of this section correctly observes that not all of the activities listed in the section will (or can) be pursued at once. The four Portfolio Planning and Investment Criteria listed in Box 2-1 will be useful in prioritizing actions under some but not all of the seven approaches listed in the section. CCTP needs to develop and make public its criteria for the approaches that are not part of the technology development cycle, specifically for ensuring a viable technology workforce of the future and for providing supporting technology policy.

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The beginning of this section correctly observes that not all of the activities listed in the section will (or can) be pursued at once.

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Increase International Cooperation, pages 10-7 - 10-8: We are very supportive of the international cooperation areas listed here and elsewhere and, in particular, the Carbon Sequestration Leadership Forum and the developing Asia-Pacific Partnership for Clean Development and Climate. In this regard, Dr. Watson in his Senate testimony (noted previously) said that "[a]ny effective international response to climate change requires developing country participation, which includes" - as we have urged in these comments - "both near-term efforts to slow the growth in emissions and longer-term efforts to build capacity for future cooperation" (emphasis added).

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Appendix A

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A.1

This offers a lead to study geoengineering approaches to mitigation. Technologies that mitigate the effects of climate change, enhance adaptation or resilience to climate change impacts, or potentially counterbalance the likelihood of human-induced climate change;"