On April 14, 2011 members of the environmental community including the Sierra Club and the Union of Concerned Scientists sent a letter to Resources Secretary John Laird opposing CalRecyle’s certification (for RPS credits) of Plasco Energy’s conversion technology project in Salinas Valley, California. The letter, sitting PRC Section 40117’s scientifically incorrect definition of “gasification” argues that the certification should not have been given because the gasification technology (with its proposed conversion of solid waste to electricity) would involve combustion (which it did not), not be able to meet the criterion of “zero emissions” (which no other energy generating technology in California is held to), and would ultimately hurt recycling (which CTs do not do). What the letter fails to mention is that the Plasco project would: created domestic green renewable energy, reduce both GHG and air emissions, and reduce dependence on landfills.
The arguments refuting these assertions are set out in our previous blogs and can be reviewed on our website (environmentalproblemsolving.com/). What is essential to consider, however, is that both the Sierra Club and UCS have, on the record, come out in favor of CTs (the Club in favor of both CT generated biofuels and electricity, UCS in favor of CT generated biofuels) while opposing the Plasco project based on arguments condemning conversion technologies.
In 2009 the Sierra Club along with the WorldWatch Institute published a White Paper (Smart Choices for Biofuels) wherein they support the development of CT produced biofuels and electricity. In pointing out that farmed feedstock for biofuels create GHGs, air emissions, threaten land conservation, and create water pollution the organizations state:
“Second generation biofuels bring advances in processing…For biodiesel, newer technologies abandon the reliance on natural oil feedstocks, allowing for larger-scale production, greater use of industrial and urban wastes, and the creation of synthetic fuels from a wider range of biomass…In the thermochemical platform, heat, pressure, chemical catalysts, and water are used to break down biomass in much the same way that petroleum is refined. Thermochemical technologies include gasification, fast pyrolysis, and hydrothermic processing. These technologies can be used to convert almost any kind of biomass into fuel…giving them a potential advantage over biochemical technologies that rely on developing specific enzymes to break down specific plant matter (emphasis added).”
“Converting biomass into heat or electricity instead of transportation fuel is a far more efficient use of this renewable resource” (emphasis added).
Converting biomass into electricity is precisely the position the Sierra Club opposed in both its letter to Resources Secretary John Laird (and its opposition to AB 222).
In its report The Billion Gallon Challenge published in 2009, UCS sitting a gasification project to biofuels as a positive role model for biofuel development stated:
“Waste products have been identified as sources of renewable fuels that dramatically reduce global warming emissions without displacing forests or food production…Fulcrum Bioenergy a Pleasanton, CA company is planning to build one of the first facilities to convert municipal solid waste into fuel at an industrial scale (more than 10 million gallons a year) at a site outside Reno, NV. Fulcurm uses gasification, which breaks down cellulosic biomass into carbon monoxide and hydrogen which are subsequently converted into ethanol …It is expected that these approaches will be optimized to handle the variable nature of waste as a feedstock, and tat the projects will have the capacity to produce clean fuel while reducing landfill requirements. And because the garbage tends to be where the people are, the fuel can be produced close to consumers, thereby saving on transportation costs and associated emissions…Industry estimates put the total potential liquid-fuel production derivable from this resource at 10 billion to 21 billion gallons per year.”
This is the exact argument made by CT proponents, including Plasco, in California. This is also the position UCS (and the Sierra Club) argued against in opposing CalRecycle’s certification of Plasco’s gasification project in SalinasValley. Indeed, one might ask: if Plasco using the same gasification technology had proposed waste to biofuels would UCS have opposed the project?
This inconsistency suggests splits in positions within the respective organizations’ policy staffs with some favoring CTs as an evolutionary technology capable of not only reducing landfill usage, and preserving natural resources while in the process creating domestic renewable energy (free from dependence on fossil fuels domestic and foreign); with others deeply concerned that CTs will literally gobble up waste materials which could otherwise be recycled (which they will not). Perhaps, in our overly specialized world, this kind of inconsistency was inevitable. Or, perhaps it simply shows that understanding CTs is a very complicated business easily leading to contradictions. The good news however, is that the Brown Administration has now given us the opportunity to resolve the dichotomy and come together on a coherent CT policy, for California, based on the creation of a “technology-neutral, feedstock based standard” for RPS eligibility.
On June 1, 2012 the Governor’s Office sent a letter to the Plasco Energy Group which stated:
“[W]e fully support CalRecycle’s efforts to develop alterative policies regarding waste to energy in California, including developing a technology-neutral, feedstock-based performance standard that could eventually be used in place of the definition of gasification for determining RPS eligibility.”
This kind of invitation is clearly a call to all of the stakeholders involved in the CT debate in California to come together and finally resolve how to integrate these technologies, which have been working successfully in Asia and Europe for more than twenty years, into the state’s environmental economy. As pointed out by the Sierra club, the World Watch Institute and the Union of Concerned Scientists these technologies: reduce GHG emissions, reduce air pollution, reduce water pollution, promote land conservation, and reduce our dependence on landfills.
Environmental Problem Solving Enterprises
Bob Sulnick & Gary Petersen
 PRC Section 40117 defines pyrolysis not gasification.
 Conversion technologies are by definition “non-combustion” technologies. In converting the syngas produced through the conversion process to electricity the gas is run through a generator identical to the process used to convert natural gas to electricity.
 Conversion technologies have been well established in Europe and Asia for more than 20 years, and have been an integral part of meeting their recycling mandates, landfill phase-out mandates and greenhouse gas reductions. See, University of California Riverside, “Performance and Environmental Impact Evaluation of Alternative Waste Conversion Technologies in California” (2004); peer reviewed, RTI International, Life Cycle and Market Impact Assessment of Non-combustion Waste Conversion Technologies. Moreover, the nations that recover the greatest amount of energy from solid wastes ae also the nations with the highest recycling rates.
 Smart Choices for Biofuels, Sierra Club, WorldWatch Institute, January 2009 at p 7.
 Ibid. at p 9.
 AB 222 was introduced into the California Legislature in 2010. The bill would have corrected the definition of “gasification” presently in PRC Section 40117. The bill did not pass out of the Legislature.
 In addition to the Fulcrum project, Covanta Energy Corporation has built a gasification project in Tulsa, Oklahoma, processing 350 TPD of post recycled municipal solid waste, for energy, for the past 10 months as well as Ineos/ New Planet BioEnergy’s gasification conversion technology operating in Vero Beach, Florida processing 400 TPD of wood waste and green waste to ethanol.
 The Billion Gallon Challenge, Jeremy Martin, June 2010 at p 37.
 Conversion technology efficiencies require homogenous feedstocks, thereby increasing recycling; they should be viewed as complimentary to recycling. Not all solid waste currently disposed can be recycled or composted. Contaminated organic materials, higher number plastics, and other materials, which cannot be recycled or processed in an economically feasible way are ideal feedstock for conversion technologies. Inorganic materials including glass, metals, and aggregate can reduce the efficiency of conversion technology operations; they have no value for conversion technologies thereby creating an incentive to separate and recover those materials for recycling prior to the conversion process. According to the “New and Emerging Technologies” study prepared by the CIWMB (now CalRecycle) for the legislature, certain materials such as glass and metals can reduce the efficiency of conversion technology operations: “There is a projected net positive impact on glass, metal, and plastic recycling…using mixed solid waste as feedstock, preprocessing results in removal of 7 to 8 percent of feedstock for recycling at gasification facilities and 12 to 13 percent of feedstock for recycling at acid hydrolysis facilities. This increase in recycling is related to conversion technology preprocessing operations”. California Integrated Waste Management Board, New and Emerging Conversion Technologies Report to the Legislature (2007) at pp 74-75.