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Uwagi do projektu Strategii Transformacji Ciepłownictwa do 2040 r.
The Clean Air Task Force (CATF) proposes several amendments to Poland's draft Heating Transformation Strategy to 2040. Key recommendations include a more nuanced approach to nuclear heating—distinguishing between large plants, SMRs for cogeneration, and heat-only SMRs—and the removal of renewable hydrogen as a general heating solution due to inefficiency. CATF also advocates for enhanced risk-sharing mechanisms for geothermal energy, specifically 'Super Hot Rock Energy', and the legal and financial inclusion of energy communities and social ownership models to increase local acceptance and efficiency.
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Document type: Statement
GREENPEACE AFRICA SUBMISSION ON THE DRAFT INTEGRATED RESOURCE PLAN (IRP) 2018 UPDATE
Greenpeace Africa argues that the draft IRP 2018 Update is inadequate for achieving a just transition to renewable energy and fails to meet South Africa's international climate commitments. The submission calls for the total removal of new coal and nuclear capacity, the elimination of artificial caps on wind and solar energy, and an accelerated decommissioning of coal-fired power stations. It highlights severe air pollution in Mpumalanga and the critical need to prioritize water security in energy planning. The document emphasizes that the plan must be based on the latest IPCC science to limit global warming to 1.5°C and should incorporate transparent data on costs and demand-side management.
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Document type: Statement
Kemper in Perspective
The author asserts that the $7 billion cost of the Kemper plant in Mississippi is attributable to the first-of-a-kind TRIG gasifier and construction issues, not the Selexol carbon capture technology, which is a well-established process used in over 110 projects. The document contrasts Kemper with the Petra Nova project in Texas, which was completed on budget as a retrofit. Kemper is presented as globally significant because it demonstrates the storage side of coal gasification, offering a potential model for coal-to-chemicals plants in China to stop venting CO2. Domestically, the project demonstrates the expandability of the U.S. CO2 pipeline network. The author concludes by calling for Congressional incentives, such as production tax credits, to accelerate the deployment of carbon capture in the power and industrial sectors.
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Document type: Statement
Comments to ARB on Quantitative Methodology, Accounting
The document outlines technical recommendations for the California Air Resources Board (ARB) on monitoring, reporting, and verification (MRV) and accounting for CO2 sequestration. It emphasizes the priority of subsurface plume tracking over surface monitoring, argues that only anthropogenic CO2 should be credited, and suggests pragmatic 'haircut' approaches to credit reductions in the event of atmospheric leakage. For EOR applications, it clarifies that recycled CO2 should not require mass balance accounting and stresses the critical importance of wellbore integrity in brownfields.
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Document type: Statement
Comment on The American Physical Society Hydrogen Report
Amory B. Lovins of the Rocky Mountain Institute argues that the APS Hydrogen Report incorrectly claims a need for new storage materials and underestimates the competitiveness of reformed hydrogen because it assumes the use of heavy, inefficient vehicles. Lovins asserts that ultralight, high-efficiency vehicle designs make current compressed-gas storage and natural-gas-reformed hydrogen economically viable. He further contends that electrolytic hydrogen is too expensive to justify nuclear power subsidies and criticizes the APS panel for relying on a narrow range of outdated governmental sources rather than current technical evidence.
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Document type: Statement
2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf
This October 2012 submission from the Natref refinery to the South African Department of Environmental Affairs (DEA) argues that the proposed Minimum Emission Standards (MES) are technically and socio-economically unsustainable for existing inland refineries. Natref advocates for a "bubble" approach to emissions management rather than a point-source approach and requests separate, less stringent limits for existing facilities compared to new plants.
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Document type: Report
2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf
The South African Petroleum Industry Association (SAPIA) submitted a set of comments and proposals to the Department of Environmental Affairs (DEA) on December 23, 2012, regarding the regulation of atmospheric emissions. The submission focuses on refining definitions, reporting requirements, compliance timeframes, and specific emission standards for combustion installations and petroleum product storage.
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Document type: Statement