Yes, you can help too. Your comments matter too

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You an eview some of the guidance provided on the pages below​ and you can review and use other guidance in the appendix of information below.  Also, review the slideshows pasted below.

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APPENDIX and More Resources below:

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Appendix: Concerns about “Carbon Fertilizer” (i.e. biochar)

1. “We are concerned about the lack of information the company has provided on the biosolids it intends to turn into biochar”

2. We are also concerned by the failure of SbS to definitively prove that the biochar produced at the faiclity will be free contaminants:

·     The European Environmental Bureau is Europe's largest network of environmental citizens' organizations, comprised of over 170 civil society organizations from more than 35 European countries

o   The Bureau has drawn attention to the possibility that biochar can release “carcinogenic polycyclic aromatic hydrocarbons” in soils

     “Pyrolysis can produce carcinogenic polycyclic aromatic hydrocarbons, which could be emitted during production or released to soils by biochar. These risks require robust rules to ensure clean and controlled processes, yet only a private standard exists to date.”

     Source: https://eeb.org/wp-content/uploads/2021/10/Carbon-Farming-Report-FINAL-WEB.pdf

·     The European Commission is a regulatory body of the European Union.

o   In 2018, a European Commission Expert Group has raised concerns that biochar may introduce contaminants into soil:

     “if the pyrolysis process is poorly managed, polycyclic aromatic hydrocarbons (PAHs) are formed, and will be present in the biochar as contaminants…”

     The Expert Group’s concerns were particularly pronounced for biochar produced from municipal wastes:

·     “As long as plants or untreated wood are used as feedstock for biochar production, the Group is not concerned about contaminants other than PAHs. However, the Group points out that if other materials such as municipal wastes were used, other pollutants could also occur (e.g. heavy metals, dioxins, PCBs)… In the case of municipal wastes, the Group would be concerned about the presence of other kinds of contaminants, in addition to those which might be present in all biochar products.”

     Source: https://agriculture.ec.europa.eu/system/files/2019-01/final-report-egtop-fertilizers-iii_en_0.pdf

·     In fact a 2021, amendment to a European Commission regulation specifically bars pyrolysis materials made from sewage sludge from being sold as “EU Fertilizing Products”

o   In issuing this regulation, the Commission determined that sewage sludge “is and should remain excluded from the list [of biochar waste streams] because it is, for the moment, unclear whether contaminants of emerging concern, such as pharmaceuticals, contained therein are completely eliminated following the processing methods for pyrolysis and gasification materials.”

“We are concerned that the climate change benefits of biochar are overstated”:

·     European Commission’s Expert Group also cast doubt on Biochar’s climate mitigation benefits:

·  “The use of biochar is proposed as a method for carbon sequestration (‘carbon sink’). Obviously, the effect depends on the stability of biochar in the soil, and of the quantities applied. A critical review (Gurwick et al., 2013) screened a large number of publications (>300) and concluded that there is insufficient empirical evidence to support the alleged claims for mitigation of climate change… biochar has a very limited potential for climate protection in the Group’s opinion.”