8/14/2019 Beta Analytic's Public Comment on Western Climate Initiative Mandatory Reporting Requirements

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Beta Analytic LimitedLondon Bioscience Innovation Centre2 Royal College StreetLondon NW10NHUnited KingdomTel: (44) 207 617 7490Fax: (44) 207 160 5350Email: info@betalabservices.com

Beta Analytic Inc. (Headquarters)4985 SW 74 CourtMiami, Florida 33155USATel: (1) 305-662-7760Fax: (1) 305-663-0964Email: info@betalabservices.comWeb Site: http://www.betalabservices.com/

Attention: Western Climate Initiative

October 14, 2008

Ref: Use of ASTM D6866 for measuring the biomass carbon fraction of heterogeneous fuelsand biogenic CO2.

Dear Sir / Madam:

We believe the Western Climate Initiative should allow the use of ASTM D6866 'StandardTest Methods for Determining the Biobased Content of Natural Range Materials UsingRadiocarbon and Isotope Ratio Mass Spectrometry Analysis' for the measurement andverification of biogenic / biomass CO2. This well proven method is particularly useful formeasuring heterogeneous fuels (i.e. mixture of biomass with fossil fuel materials). Themethod can determine the biomass carbon fraction of heterogeneous fuels such asmunicipal solid waste or tires. ASTM D6866 works well with any type of sample (gas, liquidor solid).

The method is particularly useful with a CEMS (Continuous Emissions Monitoring System) tomeasure the biogenic fraction of the CO2 gas emitted from the combustion. This can beadvantageous where fuel sampling is difficult. The CEMS can be retrofitted with a gas bagapparatus to capture the CO2 at whatever interval the operator desires (i.e. daily, weekly,monthly). If a CEMS is not available, a gas sample can be taken directly from the stack.

The ASTM D6866 method is a standardized version for industrial use of radiocarbon dating,an analytical technique that was developed in the 1950's. Radiocarbon dating has been usedfor decades for dating archaeological artifacts. The same principles of dating (i.e. analysis ofthe carbon 14 atom) can also be used to measure the biomass component of materials. Ineffect, biomass contains a well characterized amount of carbon 14 that is easilydistinguished from other materials such as fossil fuels that do not contain any carbon 14.Since the amount of carbon 14 in biomass is well known, a percentage of biogenic carbon(or in the case of a gas sample, biogenic CO2) can be calculated easily from the overall

carbon atoms (or CO2) in the sample.

Although ASTM D6866 is now used throughout the world to measure biomass carbon / CO2,the origins of the method are American. It was written at the request of the USDA to satisfylegislation requiring Federal agencies to give preferred procurement to manufacturers usingthe greatest amount of biomass in their products (per the Farm Security and RuralInvestment act of 2002). It was quickly established that radiocarbon dating was the onlyviable accurate technique to make the determination of the biomass percentage. A working

8/14/2019 Beta Analytic's Public Comment on Western Climate Initiative Mandatory Reporting Requirements

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Beta Analytic

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standard of radiocarbon dating for industrial use was completed in 2004 and is now cited inUS Federal Law (7 CFR part 2902).

ASTM D6866 is now incorporated into California's AB 32 and The Climate Registry'sgreenhouse gas protocols. A variant of ASTM D6866 (CEN/TS 15747:2008) is used to

monitor Refused Derived Fuels for the European Union's Emission Trading Scheme. TheEuropean Union also allows the use of ASTM D6866 for monitoring other types ofheterogeneous fuels. The Australian government has incorporated similar recommendationsfor the use of ASTM D6866 for blended fuels. Lastly, the Renewable Obligation Certificateprogram in the United Kingdom is considering this method for monitoring biomass energyproduction.

To support our argument to use ASTM D6866 as a verification and measurement tool for theWestern Climate Initiative's reporting requirements, we have included below five links thatoutline the use of ASTM D6866:

1. The final draft version of the California Mandatory Greenhouse Gas Emissions ReportingProtocol (please see page 93 and specifically references to section 95125(h)(2)).

http://arb.ca.gov/cc/reporting/ghg-rep/arbreg.pdf

2. The Climate Registry's Greenhouse Gas Reporting Protocol (please see page 65).

http://www.theclimateregistry.org/downloads/GRP.pdf

3 EU Emission Trading System (please see pages 16 and 17).

http://ec.europa.eu/environment/climat/emission/pdf/mrg2faq_sep_2007.pdf

4. Australian Greenhouse Gas Reporting Protocol (please see pages 115 to 117).

http://www.climatechange.gov.au/reporting/guidelines/pubs/nger-technical-guidelines.pdf

5 The independent study by Fichtner / Columbia University commissioned by the RenewableEnergy Association for the United Kingdom's Renewable Obligation Certificate Program.This study demonstrates the clear advantages of using ASTM D6866 for determining thebiogenic CO2 fraction.

http://betalabservices.com/PDF/C14ReportRev03.pdf

The long history of radiocarbon dating with decades of exhaustive research on the variableseffecting the analytical technique make radiocarbon dating a robust analytical tool formonitoring biomass carbon / CO2. The standardized version now available with ASTM

D6866 only strengthens its applicability for monitoring and verifying biomass emissionsources. We therefore recommend that the Western Climate Initiative use ASTM D6866 forits biomass reporting requirements.

Sincerely,

Thierry Sam Tamers

Director