RETHINKING OUR RENEWABLE ENERGY FUTURE: ReENGINEERED FEEDSTOCK. Compliance made easy: ReEngineered Feedstock

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1 RETHINKING OUR RENEWABLE ENERGY FUTURE: ReENGINEERED FEEDSTOCK Compliance made easy: ReEngineered Feedstock

2 Table of Contents I. Executive Summary...1 II. Accordant Energy, LLC and the ReEngineered Feedstock Model...2 III. The ReEngineered Feedstock Technology...3 IV. The ReEngineered Feedstock System...4 A. Multi-Material Processing Platform (MMPP)...4 B. Advanced Product Manufacturing (APM)...6 V. Benefits Of ReEngineered Feedstock...8 A. ReEngineered Feedstock Heat Value Comparison to Combustion of MSW...8 B. Air Pollution Reductions...9 C. Compliance With U.S. EPA Clean Power Plan and GHG Rule for Existing Power Plants...11 D. Waste Reduction...12 Conclusion...12 VI. Appendix...13 A. ReEngineered Feedstock Classification as a Non-Waste Fuel...13 EPA Non-Hazardous Secondary Materials (NHSM) Regulations...13

3 1 I. Executive Summary Coal is and will continue to be critical to the global energy mix due to its abundance and reliability. However, coal combustion releases pollutants such as SOx, mercury, hydrogen chloride, NOx, and CO2. Tightening regulations in the U.S., China, and Europe call for greater reduction of pollutants and greenhouse gases, putting power producers at a crossroads: curb pollutants to sustain supply for their customers, or shut down their coal-fired power plants. The first choice is made ever more difficult because existing air-pollution control technologies are inflexible, capital-intensive, and require long lead times. The second choice is suboptimal for other reasons. And yet at the same time, as energy needs increase and the desirability of coal decreases, the U.S. discards 60 million tons of combustible fuel each year approximately 330,000,000,000 Btus in the form of landfilled municipal solid waste (MSW). 1 Enter Accordant Energy s ReEngineered Feedstock ( ReEF ) an adaptable, cost-effective, immediately deployable solution that would allow for the recapture of much of the energy value inherent in the MSW resource. In ReEF, Accordant Energy has created a highly customizable fuel that can be co-fired with coal, thereby reducing air emissions, improving boiler efficiencies, reducing emissions of criteria pollutants, reducing emissions of hazardous air pollutants (HAPs), reducing greenhouse gas emissions (displacing fossil fuels with predominantly biogenic derived fuels), and diverting MSW from landfills as a step toward a zero-waste future. 2 ReEF is a precisely engineered product of advanced manufacturing technology, using mechanical and chemical material sorting and characterization to select discrete components from discarded materials primarily non-recyclable organic fibers (typically paper, cardboard and similar packaging materials) that have quality issues and cannot be sold on recycled materials commodity markets that would otherwise be landfilled. Those fibers are then combined with other specifically selected components from the waste stream and a precise mixture of sorbents and other additives, to create an engineered fuel that matches the desired heating profile and emissions reduction needs of specific coal-fired boilers. ReEF can replace up to 20% of coal used in a combustion unit. In addition, Accordant Energy s manufacturing facilities provide economic advantages to the communities in which they operate in the forms of jobs, tax revenue, and cost savings realized from reduced MSW disposal expenses. Typical Accordant Energy facilities serve communities of 100,000 to 300,000 people, and employ between people. This compares favorably to landfill disposal, which would typically employ only 7-8 people at a site serving a comparable population. 3 Moreover, Accordant Energy returns revenues to local governments, which will also create and maintain jobs in the community. This white paper discusses the technology behind ReEF, and details the numerous benefits of deploying this unique air-pollution control solution to the global power market. 1 U.S. EPA, Municipal Solid Waste Generation, Recycling, and Disposal in the United States: Facts and Figures for 2012, available at (last visited June 19, 2014). MSW (mixed waste streams, i.e. unsorted municipal solid waste) is a non-hazardous solid waste regulated under Subtitle D of the Resource Conservation and Recovery Act. 2 The U.S. EPA has determined that ReEF qualifies as a non-waste fuel under the Non-Hazardous Secondary Materials (NHSM) regulations (40 CFR Part 241). 3 This does not include jobs related to waste pickup and transport, which are similar under both the traditional landfill and Accordant Energy scenarios.

4 2 II. ACCORDANT ENERGY, LLC and the ReEngineered Feedstock Model Today, Accordant Energy is developing ReEF production facilities and working with a network of licensees to commercialize the ReEF technology. We offer communities and utilities reliable, renewable, lower carbon fuel; cost-effective, easy-to-deploy emissions compliance; and increased recycling, recovery, and solid waste diversion. The technology behind the ReEF system has been in development since 2008, starting when the inventors now part of Accordant Energy s executive management and technical team were employed by solid waste management company Casella Waste Systems, Inc. In 2011, ReCommunity Recycling, the largest independent recycling company in the U.S., acquired certain recycling assets and intellectual property from Casella, and created Accordant Energy, LLC in July 2012 to continue the mission of developing an MSW-based engineered fuel. In August, 2013, Accordant Energy was divested from ReCommunity and is now managed by former senior leaders of ReCommunity, who bring deep experience in the waste, recycling, and energy industries. ReEF is the first commercial product in Accordant Energy s path to a zero-landfill future. While other product lines are planned, this white paper is focused on benefits from using ReEF, primarily as an effective technology to achieve environmental compliance. For example, when co-fired with coal at a proportion of 5% - 20%, ReEF can help to mitigate harmful air pollutants as a complement to existing air pollution control equipment, having potential pollutant emission reductions in the following ranges: 4 Additional benefits of implementing of the ReEF system flow back to the communities where the initial source material (MSW) is generated, in terms of jobs, air pollution reduction, waste reduction, and direct revenues to local governments at a time when local communities are increasingly facing budgetary challenges. Accordant Energy has completed numerous pilot-scale combustion tests using ReEF, and in October 2013 completed the first commercial scale demonstration test with an electric generating utility to test the effects of co-firing ReEF with pulverized coal. The boiler was a 125 MW balanced-draft split furnace, tangentially fired Combustion Engineering boiler equipped with four pulverizers operating at about MW for the test. The ReEF injection was through the riffle distributors and fed to four burners on the upper burner level. The full-scale tests demonstrated that co-firing ReEF with coal is technically practical and can significantly reduce SO3, SO2, PCB, and VOC emissions as well as carbon in fly ash. Today, Accordant Energy is actively advancing the ReEF system, and as licensor of the ReEF technology, will enter key markets quickly by moving in parallel on pilot production ramp-up, licensee development, and partner acquisition. Currently, Accordant Energy has one licensee with rights to 14 market clusters in the southeast United States. 4 Actual emission reduction results will vary depending on factors such as combustion unit design, current emission levels, fuel used, co-fire proportion, downstream equipment, and operating and maintenance practices.

5 3 III. The ReEngineered Feedstock Technology The ReEF technology is the product of two core innovations: an advanced solid waste recycling and recovery process known as the Multi-Material Processing Platform ( MMPP ) and a patented fuel production technology known as Advanced Product Manufacturing ( APM ). The process is illustrated in Figure MSW contracted through municipalities and solid waste companies. 2. Our advanced Multi- Material Process Platform (MMPP) recovers all usable fibers and plastics for sale into the recyling market and uses only non-recylable fibers and plastics as ingredients for the fuel. Figure 1 ~ ReEngineered Feedstock Technology 3. The fibers and plastics processed in our proprietary Advanced Product Manufacturing (APM) system, dechlorinating plastic materials and bonding with the sorbents and integrating the fibers to create an integrated fuel particle, ReEF. 4. ReEF is co-fired with coal in combustion units. 5. The combined fuel/sorbent technology of ReEF helps reduce environmental air pollutants. The technology that makes up the ReEF system is protected by numerous issued patents and pending patent families worldwide with patent protection on specific components, systems, methods, and compositions. Issued U.S. patents include: 8,157,874 8,157,875 8,192,512 8,192,513 8,349,034 8,382,862 8,382,863 8,444,721 8,459,581 8,523,962 8,579,997 8,585,787 8,636,235 8,617,264 8,745,599 8,828,105 8,852,302 8,906,119 8,915,199

6 4 IV. The ReEngineered Feedstock System Three distinct objectives have motivated Accordant Energy s development of the ReEF system: (1) to maximize the effectiveness, scope and financial viability of a single stream recycling process and to reduce landfilling by removing the largest possible percentage of recyclable materials from the waste stream (the MPPP technology); (2) to engineer a customizable fuel from MSW that is recognized as non-waste; is homogenous and consistent over time; provides a cost-effective method for utility scale users to control criteria and HAP emissions associated with fossil fuel combustion; and contributes to reductions in greenhouse gas emissions (the APM technology); and (3) To return value to not only Accordant Energy s stakeholders, but also to the municipalities that serve as integral teammates in the implementation of ReEF system. The ReEF system, when fully implemented, will accomplish those three goals, resulting in significant benefits. The implementation is discussed below, followed by a deeper explanation of the benefits. A. Multi-Material Processing Platform (MMPP) The ReEF process accomplishes Accordant Energy s first objective by aggressively removing papers, paper products, cardboard, PET and HDPE plastics, glass, aluminum, ferrous metals, and a variety of other marketable and valuable recyclable materials from the waste stream The ReEF process begins at the Advanced Material Recovery Facility ( AMRF ), where source materials in the form of MSW commingled municipal, institutional, and commercial waste streams are delivered by the host municipality or independent waste hauler. Unlike traditional recycling methods, which are generally limited to residential municipal waste streams, the ReEF process can accept commercial and institutional waste streams, dramatically expanding the scope of the recycling process. Once the source materials arrive on the AMRF tipping floor, they are pre-sorted to separate out large metals and large rigid plastics to be sent to the recycling commodity market, as well as bulky materials that cannot be processed and unwanted prohibitive materials. The remaining source materials are lightly shredded and then fed into the MMPP, in which those inputs are treated by primarily automated processing lines that employ an optical sorting station, magnetic separators, eddy current separators, fluidized bed separators, filters, shredders, and granulators both to segregate and recover marketable recyclables and to remove all hazardous, prohibitive 5, and non-combustible residues. After the presorted source material enters the MMPP, it is shredded and sent through a fiber separator that extracts all fibers from the waste stream. The extracted fibers are then sent through optical sorting stations calibrated respectively to remove any remaining rigid plastics and segregate old corrugated containers (OCC) and old newspapers (ONP) for recycling. The optical sorting stations also segregate any remaining non-recyclable plastics and remove them to the plastics processing flow. The remaining non-recyclable fibers are finely shredded and sent through a fluidized bed separator. Fluidized bed or equivalent separation removes all nonconforming particles (i.e. heavy inerts and non-combustibles) and any microscopic metal fragments attached to the fibers that are too small for magnetic or eddy current separation. The pure fibers are then granulated and sent to the fiber silo. 5 Accordant Energy considers prohibitive materials to be those with significant contaminant concentrations, particularly when combusted. Examples of prohibitive materials include polyvinyl chlorides ( PVCs ), electronics, batteries, drywall, and similar items.

7 5 Figure 2 ~ The Multi Material Processing Platform The non-fiber stream is exposed to a drum separator, a magnetic separator, and an eddy current separation to recover all recyclable metals. The magnetic separator removes the vast majority of the ferrous metals from the waste stream. Ferrous metals contain iron (e.g. steel, pig iron, and other iron alloys such as stainless steel) and as a result can be removed with magnets. The eddy current separator creates an energy field around the non-ferrous metals (e.g. aluminum, copper, brass, etc.) that causes them to repel from the other waste. After the ferrous and non-ferrous metals are removed, the waste stream moves through an optical sorting station. The optical sorter is calibrated to separate out high-density polyethylene ( HDPE ) and polyethylene terephthalate ( PET ) from the waste flow for recycling. The optical sort module will substantially remove 98 % of the polyvinyl chloride ( PVC ) material from the stream. The removed PVC will be separated and sold into the PVC recycling market. The remaining post-sorted plastics are further subjected to thermal treatment to remove any remaining amounts of chlorine embedded in remaining plastics. The PVC thermal treatment module is located following the low speed shredder on the non-fiber stream. The thermal treatment system uses thermal energy to actuate the devolatization properties of PVC material remaining in the non-fiber plastic stream following PVC optical sort removal. PVC has as an attribute, the ability to completely devolatize the chlorine attached from the remaining hydrocarbon structure when exposed to temperatures above 500 F. The free chlorine is then directed to a packed Trona reactor designed to convert free chlorine into salt, preventing any release of off-gas to the atmosphere. This two-step process brings the entire discrete constituent stream down to comparable levels of chlorine found in other fuels. The remaining non-recyclable plastics are then subjected to fluidized bed separation to remove all nonconforming particles (i.e. heavy inerts and non-combustibles) and any microscopic metal fragments attached to the plastics that are too small for magnetic or eddy current separation. Fluidized bed separation also separates and segregates hard plastics and soft plastics. The segregated hard plastics and soft plastics are then granulated and sent to their respective silos. Implementing this sophisticated process means that virtually no marketable recyclable materials are used in the production of ReEF. As a direct result of Accordant Energy s recycling maximization, the percentage of commercial and municipal waste streams destined for landfilling is dramatically reduced. Although the contents of individual waste streams varies considerably among municipalities, on average the ReEF process reduces the amount of landfilled material from the current average of 54% 6 down to approximately 10-20% of the waste stream. Increased recycling also reduces greenhouse gas emissions and reduces air and water pollution associated with making new products from raw materials. 6 EPA, Municipal Solid Waste Generation, Recycling, and Disposal in the United States: Facts and Figures for 2012, available at (last visited June 19, 2014).

8 6 Energy Recovery as Re-Engineered Feedstock Figure 3 ~ MSW disposition currently and with 100% ReEF participation B. Advanced Product Manufacturing (APM) The second objective of the ReEF process is to create a homogenous fuel that has a comparable heating value relative to traditional fuels and that can be co-fired seamlessly with coal in existing (unmodified) boilers while serving as an effective control technology. The APM process dechlorinates the plastics, and synthesizes the base material with sorbents and additives made from virgin materials with the selected ingredients to create an integrated fuel particle that delivers the precise fuel emissions control capabilities required. The result is a fuel that has a consistent, defined origin (a critical characteristic) and is specifically engineered to match its target fuel. Figure 2 illustrates the constituent ingredients of ReEF. The advanced fuelmanufacturing phase can also be 20% broken down into two distinct but simultaneous stages: product 8% manufacturing and the addition 56% Fibers Light Plastics of sorbents and other chemical additives. ReEF is manufactured in the third stage from the four chemically consistent and homogeneous constituent ingredients: fibers, hard plastics, 16% Figure 4 ~ Consituent Ingredients of ReEngineered Feedstock (percentages vary by formulation) Heavy Plastics Sorbents soft plastics, and sorbents. The addition of sorbents, when sorbents and additives are synthesized into ReEF to control emissions of various air pollutants, is a central component of the manufacturing process. After the completion of the MMPP, the remaining fibers, light plastics, and hard plastics have been segregated into separate silos and are free from any non-combustible materials, inert residues, or prohibitive materials. In the fuel manufacturing and sorbent incorporation phases, the constituent ingredients are carefully metered, volumetrically mixed in the correct proportion, and conditioned to produce an end product that suits the specific energy needs of each end user.

9 7 In order to maximize the effectiveness of the sorbents, as discussed above, hard plastics and sorbents are first precisely metered, mixed, and thermally treated. This ensures that the sorbents are effectively synthesized across the particular ReEF profile so that it is activated to the optimal point in the combustion process. ReEF is engineered to synthesize the sorbents and additives with the other constituent ingredients in such a fashion that they are effectively embedded across the ReEF profile. Those additives are incorporated into the ReEF to alter the chemical composition of the materials and ultimately to produce a fuel product with an emissions profile tailored to the needs of the end user, typically one that reduces emissions of hazardous air pollutants (HAPs) and criteria pollutants (e.g. NOx and SO2) and improves combustion efficiency. The sorbents and additives are synthesized into ReEF mechanically and physically in a way that causes the fluid dynamics and mechanics to be identical to the coal with which it is cofired. This ensures that the sorbent is delivered to the precise reactivity zone in the combustor to maximize effectiveness. For example, the optimal temperature zone to remove SO2 is degrees Fahrenheit. Traditional sorbent injection methods (i.e. injecting the sorbent with the coal) result in sintering of the sorbents at high temperatures, between 3000 and 2500 degrees Fahrenheit (found in the first stage of combustion.) This precludes or retards the reactivity of the sorbent and reduces the effectiveness of the sorbent to as low as 20%. Directly injecting sorbent in the boiler in the optimal temperature zone also reduces the effectiveness of the sorbent because it is not effectively distributed across the profile of the combusted coal. Injecting larger amounts of sorbent in an attempt to distribute across the combusted coal s profile leads to slagging and reduced boiler efficiency. In contrast, ReEF allows the sorbent to be injected with the coal, without being directly exposed to inefficient temperatures, and allows the sorbent to be evenly distributed across the combusted coal s profile to maximize the efficiency of pollutant reductions. Sorbent continuous desulfurization at convection zone where complete burnout and conversion are achieved ReEF fragments while traveling upward to lower T zone, where sorbent reacts with SO 2 to produce CaSO 4 Sorbent protected from exposure to high temperature to minimze sinterizing and slagging ReEF Injection Figure 5 ~ Optimal sorbent injection temperature zone

10 8 V. Benefits of ReEngineered Feedstock Co-firing ReEF with coal includes both environmental and economic benefits outlined here and discussed in detail below. Environmental Benefits Incremental sulfur, nitric oxide, hydrogen chloride and mercury emissions improvement beyond existing hard asset air pollution controls Displaces 5% - 20% of coal, depending on boiler configuration Reduced CO2 emissions as a result of the biogenic carbon content of the fuel Reduced landfill disposal and resultant greenhouse gas emissions May meet state specific Renewable Portfolio Standards Potential to reduce scrubber water use at power plants Recognized by the EPA as a non-waste fuel, thus boilers combusting ReEF are not subject to the commercial/industrial solid waste incinerator rules Economic Benefits Comparatively priced to coal Pollution control attributes may be eligible for addition to the rate base Lower capital expenditures than traditional air pollution control technologies Potential for improved plant efficiency Potential to decrease parasitic load from existing air pollution control equipment May be eligible for Renewable Energy Credits (RECs) A. ReEngineered Feedstock Heat Value Comparison to Combustion of MSW ReEF is an engineered, valuable, and homogeneous fuel that is the product of a technologically advanced manufacturing process. In contrast, municipal waste is a heterogeneous waste that, when combusted, is done so primarily for disposal purposes. The composition and emissions of MSW are highly variable, it has low heating values, high ash and moisture contents, and it is not treated as a valuable commodity. In contrast, as Table 1 illustrates, ReEF, with its high heating value and low moisture and ash contents, exhibits characteristics that are more similar to coal than to MSW. ReEF also contains sorbents and other additives that, as discussed further below, control specific air emissions such as SO2, NOx, HCl, dioxins and furans, and improve both the product s fuel characteristics and as-fired energy content. The MMPP and APM manufacturing technologies also enable Accordant Energy to produce varieties of ReEF those are homogeneous and chemically and physically consistent, greatly improving boiler performance. Minimum HHV (Btu/lbs, as received) Maximum HHV (Btu/lbs, as received) Average HHV (Btu/lbs, as received) All ranks of U.S. coal 2,810 15,247 11,491 Eastern bituminous coals 8,948 13,080 11,441 Sub-bituminous coals 4,450 13,800 8,600 Lignite 2,800 9,700 6,400 ReEF 9,9847 Table 1 ~ Heat values for a variety of coals and ReEF

11 9 A meaningful heating value, then, would be one that approximates the heating value of the coal fired in a particular combustion unit. Because Accordant Energy can customize ReEF to meet the specific energy needs and emissions limitations of individual combustion units, it can engineer fuel product varieties that produce heating values ranging from 6,500 to 10,000 Btu/lbs. ReEF can therefore match the heating value of the coal with which it will be fired. B. Air Pollution Reductions ReEF controls conventional pollutants, HAPs, and greenhouse gases when compared with boilers fired with solely coal. First, the pollutant profile present in ReEf is significantly more favorable than that of typical Eastern bituminous coal. See Table 5. Eastern Bituminous Coal ReEngineered Feedstock (ReEF) Average Stdev Average Stdev Moisture Moisture Ash, wt.% (db) Ash, wt.% (db) Dehyrdated Sorbent, wt.% (db) Dehyrdated Sorbent, wt.% (db) Volatile Matter, wt.% (db) Volatile Matter, wt.% (db) Fixed Carbon, wt.% (db) Fixed Carbon, wt.% (db) Carbon, wt.% (db) Carbon, wt.% (db) Hydrogen, wt.% (db) Hydrogen, wt.% (db) Oxygen, wt.% (db) Oxygen, wt.% (db) CO2 emission, lb/mmbtu CO2 emission, lb/mmbtu HHV, Btu/lb 11, HHV, Btu/lb 9, Non- metal elements dry basis Non- metal elements dry basis Nitrogen, wt.% (db) Nitrogen, wt.% (db) < Sulfur, wt.% (db) Sulfur, wt.% (db) Chlorine (Cl), wt.% (db) Chlorine (Cl), wt.% (db) Flourine (F) ppm Flourine (F) ppm Metal elements dry basis Metal elements dry basis Arsenic (Se), ppm Arsenic (Se), ppm Beryllium (Be), ppm Beryllium (Be), ppm Chromium (Cr), ppm Chromium (Cr), ppm Cobalt (Co), ppm Cobalt (Co), ppm Mercury (Hg), ppm Mercury (Hg), ppm < Nickel (Ni), ppm Nickel (Ni), ppm Selenium (Se), ppm Selenium (Se), ppm Table 2 ~ Contaminant data for Eastern Bituminous Coal and ReEF 10 7 Although the heating value will vary depending on the sorbent mix, the heating value of a particular type of ReEF is constant and does not fluctuate. As such, there is no true range of heating values for a specific ReEF product line. 8 United States Geological Survey - U.S. Coal Quality Database. 9 The heating value of a particular type of ReEF is determined by the chemical composition of that variety. In other words, its heating value does not fluctuate. The range of heating values presented above merely reflects Accordant Energy s ability to tailor ReEF to meet the specific energy needs of individual combustion units. 10 ReEF chlorine data content based on PVC removal and thermal treatment. HHV and CO2 value assumes ReEF data manufactured with 20% plastic/80% fiber content; results will vary depending on sorbent mix. All Eastern bituminous data taken from the US Coal Quality Database, except for chlorine, which is taken from Bragg, L.J., R.B. Finkelman, and S.J. Tewalt Distribution of Chlorine in United States Coal. In Chlorine in Coal (Stringer, J. and d.d. Banerjee, eds.). Elsevier, Amsterdam.

12 10 As another example, Figure 6 below shows the calculated reductions of SO2 and NOx that result from co-firing 20% of a coal-fired power plant by weight with ReEF at 455,460 MWh annual production (based on benchscale testing, as applied to a 100MW coal-fired boiler). 6,000 5,000 4,000 3,000 2,000 Coal fired ReEF Cofiring 1,000 0 SO 2 Emission (tons) NO X Emission (tons) Figure 6 ~ SO 2 and NO x Emissions, calculated, from power plant with 455,460 MWh annual production. Given these capabilities, ReEF can dramatically reduce the costs of reducing pollution, such as the capital costs of NOx controls or flue gas desulfurization shown in Figure 7. As can be seen in the graphs, the capital costs are significantly higher on a per-kw basis for smaller plants, making ReEF an especially appealing option for smaller plants. Capital Costs of FGD Retrofit ($/kw) $1,200 $1,000 $800 $600 $400 $200 $0 $1,137 Coal-Fired Unit Capacity (MW) $784 $607 $526 $470 $420 $401 $ MW 100 MW 200 MW 300 MW 400 MW 500 MW 700 MW 1000MW Capital Costs of NOx Controls ($/kw) $250 $200 $150 $100 $50 $0 $203 Coal-Fired Unit Capacity (MW) $183 $156 $138 $125 $116 $103 $91 50 MW 100 MW 200 MW 300 MW 400 MW 500 MW 700 MW 1000MW Source: EPRI and Bernstein analysis Figure 7 ~ Estimated capital costs of NO x controls and FGD retrofits.

13 11 ReEF also inherently reduces greenhouse gases, as the fuel content of ReEF is primarily sourced from biogenic, renewable fibers. As a result, unlike the carbon emitted from fossil fuels, the carbon emitted from ReEF combustion is largely comprised from CO2 that was recently captured from the atmosphere by plants. Coal (All Ranks, avg.) Petroleum Natural Gas ReEF <180 (100 bigenic CO 2 ) Table 3 ~ CO 2 emission rates (lbs CO 2 /mmbtu) C. Compliance With U.S. EPA Clean Power Plan and GHG Rule for Existing Power Plants On June 2, 2014, The U.S. Environmental Protection Agency (EPA), under President Obama s Climate Action Plan, proposed a plan to cut carbon pollution from power plants. The Clean Power Plan will put in place a national framework that builds on work states are already doing to reduce carbon pollution. The proposed plan will allow states to have the flexibility to choose the best set of carbon pollution reduction strategies for their unique circumstances. By setting a state-specific goal and allowing states to work individually or in regional groups, EPA is making sure states have the flexibility they need to drive low carbon, renewable, and energy efficiency technologies. The EPA is using four building blocks to determine state-specific goals. By substituting coal, a fossil fuel, with ReEF, a low carbon fuel, ReEF meets the EPA s third building block: reducing emissions from affected electric generating utilities. Co-firing ReEF with coal represents a concrete opportunity to reduce the carbon footprint of the power generating fleet, while increasing the growth of renewable electric power generation. In the U.S., coal-fired power plants emit about 5,125 pounds of carbon dioxide per ton of coal combusted, or about 205 pounds of carbon dioxide per million Btu. In contrast to coal, ReEF emits only about 3,700 pounds of carbon dioxide per ton of ReEF combusted, or about 180 pounds of carbon dioxide per million Btu. Most importantly, of ReEF s 180 pounds of carbon dioxide per million Btu, about 100 pounds of carbon dioxide per million Btu or about 55% is biogenic carbon. Combusting ReEF, which contains fiber and plant constituents, results in emissions considered carbon-neutral, because the carbon is generated by the natural carbon cycle. Under a number of greenhouse gas emissions programs, using biomass and biomass by-products as alternative fuels can be classified as reducing greenhouse gas emissions. By differentiating between biogenic- and fossil-derived carbon dioxide, power plants can immediately quantify effective greenhouse gas emission reductions, potentially generate credits to offset fossil carbon emissions, and potentially capitalize on surplus allowances for trading. For example: A 400-MW coal-fired power plant combusting bituminous coal, with a heat rate of 10.5 MMBtu/MWhr and a heat input of 4,200 MMBtu/hour would emit tons of fossil carbon dioxide per hour of electricity production. Alternatively, the same plant co-firing 10% by energy of ReEF would emit tons of carbon dioxide per hour of electricity production with approximately 5% of the total carbon dioxide emissions as biogenic carbon emissions, about 21 tons/hr. Over the course of one year, assuming 8,000 hours of electricity production, about 168,000 tons of fossil carbon dioxide is avoided, while about 42,000 tons of carbon dioxide emissions is avoided, and 154,560 megawatt hours of renewable electricity is generated using ReEF.

14 12 D. Waste Reduction Accordant Energy s focus on a zero-landfill future led it to invest in and develop the ReEF system, allowing the capture and reuse of between 85-90% of the current municipal waste stream. Importantly, Accordant Energy s technology can be applied to waste streams that have been challenging for traditional recycling to access, including the commercial, industrial, and institutional waste streams. The deployment of the ReEF system would result in reduced landfilling, therefore preserving land area for more beneficial uses also saves communities money by reducing disposal fees. Furthermore, as can be seen in Table 4, landfill gas emissions could also be reduced by the eventual widespread adoption of the ReEF system to the tune of 100 million metric tonnes of CO2E annually. Current ReEngineered Feedstock Potential 250 million tons generated 65 million tons recycled, 20 composted, and 29 combusted 136 million tons landfilled Landfill methane 123 MMTCO 2 E 250 million tons generated million tons recycled and used million tons landfilled Landfill methane 22.5MMTCO 2 E Table 4 ~ Landfill methane emissions with 100% ReEF market adoption. Conclusion Accordant Energy s ReEngineered Feedstock presents a zero-day, adaptable pollution control system that significantly advances beneficial environmental goals in a cost-effective package.

15 13 VI. Appendix A. ReEngineered Feedstock Classification as a Non-Waste Fuel EPA Non-Hazardous Secondary Materials (NHSM) Regulations In , EPA promulgated rulemakings determining whether a material that was once discarded should be considered a fuel or a solid waste when combusted. Accordant Energy has demonstrated to the satisfaction of the U.S. Environmental Protection Agency (EPA) that ReEF should be classified as a non-waste fuel product under the Non-Hazardous Secondary Materials (NHSM) regulations (40 CFR Part 241). NHSM regulations identify which non-hazardous secondary materials are, or are not, solid wastes when burned. To be designated as a non-waste fuel, the regulations require that processing of NHSM meet the definition of processing in 40 CFR 241.2; and that after processing, the NHSM also meets the legitimacy criteria for fuels in 40 CFR 241.3(d)(1). Legitimacy criteria in 40 CFR 241.3(d)(1) include: (1) material must be managed as a valuable commodity; (2) the material must have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy; and (3) the material must contain contaminants at levels comparable to or less than those in traditional fuels which the combustion unit is designed to burn. In a letter dated August 24, 2012, EPA stated based on information provided, we believe the that ReEngineered Feedstock, as described in your letters and supporting materials, meets both the processing definition and the legitimacy outlined above. Accordingly, we would consider this NHSM a non-waste fuel under the 40 part 241 regulations. As a non-waste fuel, ReEngineered Feedstock can be co-fired in an existing coal-fired steam electric generating unit without triggering applicability of the solid waste or hazardous waste incineration rules. Accordant Energy and ReEngineered Feedstock are registered trademarks of Accordant Energy, LLC

16 Accordant Energy is a fuel technology company offering an innovative, renewable fuel ReEngineered Feedstock to enable cleaner coal power generation with improved environmental performance. 225 S. Main Street Rutland, VT (802) energyinfo@accordantenergy.com accordantenergy.com