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<tr><td><b>Comment Number: </b></td><td>533254-00014</td></tr>

<tr><td><b>Received: </b></td><td>1/16/2008 10:59:21 AM</td></tr>

<tr><td><b>Organization: </b></td><td>Beta Analytic Inc.</td></tr>

<tr><td><b>Commenter: </b></td><td>Thierry Sam Tamers</td></tr>

<tr><td><b>State: </b></td><td>FL</td></tr>

<tr><td><b>Agency: </b></td><td>Federal Trade Commission</td></tr>

<tr><td><b>Rule: </b></td><td>Guides for the Use of Environmental Marketing Claims; Carbon Offsets and Renewable Energy Certificates</td></tr>

<tr><td><b>Attachments:</b></td><td><a href='533254-00014.pdf'>533254-00014.pdf</a>&nbsp<a href='http://www.adobe.com/products/acrobat/readstep2.html' target = _blank >Download Adobe Reader</a><br></td></tr></Table>

<hr><P><b>Comments:</b></p>Dear Sir / Madam:


We believe voluntary carbon offset programs and REC's (renewable energy certificates) should include the use of ASTM D6866 for measurement and verification of biogenic/biomass CO2. ASTM D6866 is currently under consideration for California's AB 32 program. A variant of ASTM D6866 (CEN 15591:2007) is also used to monitor Refused Derived Fuels for the European Union's Emission Trading Scheme. The Renewable Obligation Certificate program in the United Kingdom is also considering this method for monitoring biomass energy production.


ASTM D6866 is particularly useful for determining the biogenic carbon fraction of heterogeneous fuels such as municipal solid waste or tires. Furthermore, the analytical method works exceptionally well with a CEMS (Continuous Emissions Monitoring System) since the method is ideally suited to measure the biogenic fraction of the CO2 gas emitted from the combustion. Analyzing the CO2 gas itself eliminates the inherent problems of having the proper sampling protocol in place (particularly with regard to waste characterization studies). 


The CEMS can be retrofitted with a gas bag apparatus to capture the CO2 at whatever interval the operator desires (i.e. daily, weekly, monthly). Nonetheless, if a CEMS is not available, a gas sample can be taken directly from the stack. If this is not possible, the solid fuel sample can be analyzed.


The ASTM D6866 method is a standardize version for industrial use of radiocarbon dating, an analytical technique that was developed in the 1950's. Radiocarbon dating has been used for decades for dating archaeological artifacts. The same principles of dating (i.e. analysis of the carbon 14 atom) can also be used to measure the biomass component of materials. In effect, biomass contains a well characterized amount of carbon 14 that is easily distinguished 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, 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 satisfy legislation requiring Federal agencies to give preferred procurement to manufacturers using the greatest amount of biomass in their products (per the Farm Security and Rural Investment act of 2002). It was quickly established that radiocarbon dating was the only viable technique to make the determination of the biomass percentage. A working standard of radiocarbon dating for industrial use was completed in 2004 and is now cited in Federal Law (7 CFR part 2902).


The long history of radiocarbon dating with decades of exhaustive research on the variables effecting the analytical technique make radiocarbon dating a robust analytical tool for monitoring biomass carbon/CO2. A standardized version now available with ASTM D6866 only strengthens its applicability for monitoring and verifying biomass emission sources.


To support our argument to include ASTM D6866 as a verification and measurement tool in voluntary carbon offset programs and REC's, we are attaching the following two documents:


1. The draft version of the California Mandatory Greenhouse Gas (GHG) Emissions Reporting Protocol (Please see sections A-78 and A-80).


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


Sincerely,


Thierry Sam Tamers

Director


Beta Analytic Inc.

4985 SW 74 Court

Miami, Florida 33155 USA

ttamers@betalabservices.com

www.betalabservices.com

Direct: (1) 305-662-7760

Tel: (1) 305-667-5167

Fax: (1) 305-663-0964

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