Subject: Comments to Draft Specifications for Application of UNFC-2009 to Renewable Energy Resources: from Michael McCurdy, Leios Engineering
16 October 2014
In reviewing the Part IV, Generic Specifications, part D. Commodity or product type, the draft specification includes the statement “For Renewable Projects producing multiple sales products, the non-energy commodity shall be excluded from the Renewable Energy Resource quantity”.
Many biomass technologies upgrade the Renewable Energy Source producing a co-product suitable for sale as food for people or livestock feed. My concern is that by establishing an economic value of the Resource based solely on the energy content as liquid fuel or electricity, the specification could create an economic incentive to destroy food or feed to produce energy. It may be worth considering food or feed to be an energy commodity on the basis of the energy that could be recovered by an end user. For example, sugar produced during ethanol production could be valued on a kJ/g basis depending on how much of the sugar is consumed by the human body."
F. Michael McCurdy, P.E.
Senior Project Manager, Renewable Energy Generation
Leidos Engineering, LLC (formerly RW Beck)
Comments from Michael McCurdy, Leios Engineering to Draft Specifications for Application of UNFC-2009 to Renewable Energy Resources.
16 October 2014
In reviewing the Part IV, Generic Specifications, part D. Commodity or product type, the draft specification includes the statement “For Renewable Projects producing multiple sales products, the non-energy commodity shall be excluded from the Renewable Energy Resource quantity”.
Many biomass technologies upgrade the Renewable Energy Source producing a co-product suitable for sale as food for people or livestock feed. My concern is that by establishing an economic value of the Resource based solely on the energy content as liquid fuel or electricity, the specification could create an economic incentive to destroy food or feed to produce energy. It may be worth considering food or feed to be an energy commodity on the basis of the energy that could be recovered by an end user. For example, sugar produced during ethanol production could be valued on a kJ/g basis depending on how much of the sugar is consumed by the human body."
F. Michael McCurdy, P.E.
Senior Project Manager, Renewable Energy Generation
Leidos Engineering, LLC (formerly RW Beck)
Comments from Michael McCurdy, Leios Engineering to Draft Specifications for Application of UNFC-2009 to Renewable Energy Resources.