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Home My WebLink About20252982.tiff Exhibit Inventory Control Sheet NGL Water Solutions DJ,LLC ` USR24-0019 Exhibit Submitted By Description A Planning Commission Resolution of Recommendation B Planning Commission Summary of Hearing(Minutes dated 10/7/2025) C Department of Planning PowerPoint Presentation Services D Jeri Yarbrough, Emails,pictures,articles(dated—multiple, Surrounding Property starting 10/9/2025) Owner E Environmental and Animal Public Comment and Objection(Received Defense 11/3/2025) F Surrounding Property Petition(Received 11/3/2025) Owners G Attorney Representing , Brief in opposition(Received 11/5/2025) SPOs H , Dr Bret Luedke, Letter in opposition(Received 11/5/2025) Veterinarian I J K L 0 0 2025-2982 EXHIBIT s C • S2a4 - 0015 WELD COUNTY GOVERNMENT Department of Planning Services COUNTY , CO USR24 0019 Applicant : NGL Water Solutions DJ , LLC Planner : Diana Aungst Re . uest : Use by Special Review Permit for Uses similar to organic composting ( 13sochar processing ) outside of subdivisions and historic townsies in the A ( Agricultural ) Zone District . Legal Description : Lots A and B of Recorded Exemption , RECX17 - 0182 ; being part of the N1 / 2 of Section 28 , Township 1 North , Range 66 West of the 6th P. M . , Weld County , Colorado . Location : South of and adjacent to County Road 6 ; approximately 0 . 25 miles west of County Road 31 . weld . gov „1/4 , ‘,.. a ...... Department of Pann . ng Serv . ces COUNTY, CO Igiuc II s FI _ • u bill Hlc • Ir._.... • 4} 1 e a rs n g •!_ _ - - s f ems - S7 0 3t -, arts_ - � '� ti„, .-hr- • .... II adi Os MI CI el - . .” ,. • silli aa CASE NUMBER ma rarni * • CASEum • u ► a- • _ + = " � � ; t � _ II li J 1 . L i .,- ` _ r 1 .. ri -i ` = � � j�- _ ar. sir - 1 i Sh - I r • i t to N + MG SCOT : Plann -rtg . ! il a s . ALA M► •It it hit ' s - it . �'0 _ vows [ . Pa • tom , •• # • t ea IL kipi _e a_ • Avt. .._ - .. -1. • • 04 Cotifirf Ca ant sr t .in AP i V r • QUEST 1 . , � , � we • � _ St .. ta Z + �� a ' I • a. 1 n a . 1 { 7 is - S4 * _ .day a ids , _ 111164 t i is r • ig � i . Department of Pann . ng Service s COUNTY, CO - 1 1 1 Vic n ty Map --- , , .. 1 1 u 1 1 �� unger Reservoir ; - _ _ - . r ' Number ber 2 ' ILIU FORT L UPTON _ , t D _ i \--- r I ill , < , . II ic ”. < - i , , , , , . . . L i im ___ . , l < i i tr____AZ p it 1 W i i. - - Munger Reservoir , i $1; t to w Number 1 + A 7 , i . ...,...a. i 1 j % i � � � � SITE1 R t . i ci I. , . ,,, , ct / i , _ . _ . - - ,(7 _, . ", , -IE1] � � i 1 . • i ,, --- ft, 4> sr I et, en . , _ - , . , , , ,.... t - r A : ___:,,,N ! i ' , I N, . ,,_ is , IOC I La ' $ ' a 1 I uj I < f r • 1 1 I I l LOCHBUIE 4 � R _ s v1/4, aatt . 4.4. ese Department of Pann . ng Senices COUNTY, CO • • What is Biocharf? Highly Adsorbent , Specially - Produced Charcoal with Unique properties ik C Od tidail irk A • ilie k # • mi. O. elk 0 0 a .. • al . ' 4 , - 11 1: ::bbli, so. No r i Or C L Bic is ( ) ( yr BAcrs • • ( L . JIG YA1W SUPER SACKS , � i T _ i _ _ 6 4 " \A es i c , a cat" AIL r .. i ..._ , ,i, . , , _ Fr . , Si I. .� � - Oar . • - - tar 1 w -1 r ItaltaS"...... ;Or t ll it s . WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Ki • 4 s b t ' 40. _ L r : — jsi• 't t' , .• /�l -.i.. -.ah .. ♦ , �T , i.�S ��. �l } a— ' • 1•• iips,a , t. s' ,y i• • Operations on the Berthoud site. WELD COUNTY GOVERNMENT Department of Planning Services V1/4, sit COUNTY, CO Kilns WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO WELD COUNTY GOVERNMENT Department of Planning Services V1/4, sit COUNTY, Co Finish product Stockpiles of raw materials. 4- to t r - t Cir a :Iat - ' Sri H tPCZ JT/ 16 1.r .ePz ._ 11, - 41 • WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Criteria: Section 23-2-220.A. Section 23-2-220.A.1.-Thatthe proposal is consistent with Chapter 22 of this Code and any other applicable code provisionorordinance in effect. Section 23-2-220.A.2. - That the proposal is consistent with the intent of the district in which the use is located. Section 23-2-220.A.3. - That the uses which would be permitted will be compatible with the existing surrounding land uses. Section 23-2-220.A.4. - That the USES which would be permitted will be compatible with future development of the surrounding area as permitted by the existing zoning and with the future development as projected by Chapter 22 of this Code or Master Plans of affected municipalities. Section 23-2-220.A.5. - That the application complies with Articles V and Xl of this Chapter if the proposal is located within an Overlay Zoning District ora Special Flood Hazard Area identified by maps officially adopted by the County. Section 23-2-220.A.6. - That if the use is proposed to be located in the A (Agricultural) Zone District, the applicant has demonstrated a diligent effort has been made to conserve prime farmland in the locational decision forthe proposed use. Section 23-2-220.A.7.-Thatthere is adequate provision for the protection of the health, safety and welfare of the inhabitants of the neighborhood and the County. WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO USR Approval Criteria (Section 23 2 220.A.) - Simplified 1. Consistent with Comprehensive Plan 2. Consistent with Zoning Intent 3. Compatible with Surrounding Land Uses 4. Compatible with Future Development (Weld Comp Plan Map & Municipality Plans) 5. Overlay or Hazard District? If so, Compliant with Special Requirements 6. A (Agricultural) Zone District? If so, Effort to Conserve Prime Farmland 7. Protection of Health, Safety And Welfare of Weld County Residents WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Weld County Comprehensive Plan r a a a Z S S S S i i I CR6 - a - S a ON Weld County Opportunity Zone Development Classification Annexation Urban UrbanallonUrban Mix WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co 1. Consistent with Comprehensive Plan Ni Section 22-2-10.A "Respecting OurAgricultural Heritage." Biochar is used as an agricultural soil amendment. ✓ Section 22-2-10.B. "Respecting Private Property Rights." ✓ Section 22-2-30.C. "Harmonize development with surrounding land uses." Mitigation is proposed. _an weld.gov WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO 2. Consistent with Zoning • 1 .e ! Wm Zoning r 7 a a a r r I Reservoir Number I $ s_a - s N S SITE a CR6 an a al flainla— a 'a Zning: A I M 1 i a a a a s a a MI ON a i a Nil i Mr i I �► fi — ! +w are I I WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co 2. Consistent with Zoning The A (Agricultural) Zone District is intended to provide areas forthe conduct of agricultural activities and activities related to agriculture and agricultural production, and forareasfornatural resource extraction and energy development, without the interference of other, incompatible land uses. 23-3-40.W. ORGANIC FERTILIZER PRODUCTION/COMPOSTING FACILITIES. weld.gos WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co 3. Compatible with Surrounding Land Uses Section 23-2-220.A.3. - That the uses which would be permitted will be compatible with the existing surrounding land uses. ✓ Neighborhood meeting held October 12, 2024. ✓ 11 Surrounding Property Owner's submitted letters of objection. ✓ Mitigation for noise and visual impacts are proposed. weld.gov WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO USRs within one mile 1I USR16-0034 OPEN PIT MINING i ;SUP -21$ DAIRY 'TON I USR17-0070 USR17-0032 >12 INCHHIGH' -- MINERAL RESOURCE DEV. FAC_ PRESSURE NAT GAS BRIGHTON 19-0021 -1ICLE USR-1676 \LES RESEARCH. REPAIR, MANUFACTURE SUP -226 )IL TANKS { USR16-0027 — a ! 1Tfnnn R _ Ia O-! a lie ! a S t I USR20-0009 KENNEL EXOTIC ANIMALS /1 CR4 t'' or Munger Resetvoar Number 2 Brighton Lateral Munger Reservoir Nuinb‘r I i SUP -93 FEED LOT 1500 CATTLE U S R 12-0011 NON -1041 MAJOR FACILITY USR16-0028 NATURAL GAS LINE >12" USR 14.67 SUBSTATION easee------ r► -e -2301115169/34.5eK Y - CR6 SUP -349 HOG FARM 500 CUP -12 SINGLE FAMILY RESIDENCE i I I I USR14- 3 HOW BUSINI 1Ul IZ !W ralc IC) IW i_ I< I .I I I OM a ,Slit 41 a I USR-1711 11 DBL CIRCUIT 230KV TRANSMISSION /USR 14-0018 DUMP STATION & STORAGE WELD COUNTY GOVERNMENT Department of Planning Services Aliamigmainir Vitt COUNTY, Co ti L. ♦„,4♦.1 e • to I • • 1 The white stars indicate property owners that submitted a letter of opposition to this USR. 6 500 -foot buffer Closest Residences WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co Surrounding Property Owner's Concerns ➢ Air pollution, Noise pollution, and Light pollution ➢ Disturbance of the surrounding eco-systems ➢ Activities adversely affect the wildlife, livestock, and other animals. ➢ Carcinogenic dust from charcoal ➢ Increased traffic and Decreased property value, ➢ Fire safety, drainage issues, ➢ Compatibility with surrounding agricultural operations ➢ Lack of adequate visual screening. weld.gov WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Response to Surrounding Property Owner's Concerns ➢ Air pollution - emissions controlled by CDPHE (no referral response) ➢ Noise and light mitigated ➢ Disturbance of the surrounding eco-systems - not a pollutant, biochar is a soil amendment ➢ Activitiesadversely affect the wildlife, livestock, and otheranimals similarto other uses in the area ➢ Carcinogenic dust from charcoal the dust does not cause cancer (pertesting) ➢ Increased traffic and decreased property value ➢ Fire safety and drainage issues ➢ Compatibility with surrounding agricultural operations ➢Lack of adequate visual screening - screening will surround the entire property WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co Emissions The emission test determined that PAHs and PCBs were not present. • PAHs (Polycyclic Aromatic Hydrocarbons) - Organic compounds formed during incomplete combustion of organic material • PCBs (Polychlorinated Biphenyls) -Toxic industrial chemicals Emissions report submitted indicated that the following chemicals were Not Detected (ND*): • • • • • • • Benzo(a)pyrene Naphthalene Chrysene Aroclor 1016, 1221, 1242, 1254, 1260 (types of PCBs) Fluoranthene Fyrene Anthracene * ND - Not Detected means that concentrations were below the method detection limits. WELD COUNTY GOVERNMENT Department of Planning Services Noise levels - Mitfqa ted Noise study, red indicates higher than 55 dB max. Noise, as mitigated is less than the 55 dB max (daytime). Receptorlocations Table 4-4 Mitigated Predicted Noise Levels (d Receptor Ol Un mitigated 49.7 a'2 46.0 03 45.4 i _ 04 05 06 07 OS Noise Limit 53.5 42.8 "6.3 51.4 55.2 Table 4-5 Mitigated Predicted Noise Levels (dBA Receptor Unmitigated 01 44.3 02 a2.4 03 43.0 04 50.3 05 43.0 06 56.7 07 45.6 08 47.1 Noise Limit 1 CAJUN IY,LU Scenario 1 (A Screener) I\litigated 50.9 4G.8 46.8 54.1 40.9 44.0 45.9 48.1 55 Scenario 3 (Pyrolysis Process Mitigated 44.3 42.4 43.0 50.3 41.9 54.1 44.5 47.1 55 WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Noise mitigation - placement of 12' -tall panels «• »• • •• • • • •.. .4+ en r• ha en tee On ••• M• N• ••• I•• ♦•* ••• es•• p• •s • ••• f•• •a 00 fen tie lobo 450 *Le ildie d` IN HE�.." `o rtEYlh' L1hid. CONVERSION FAOUTY nnnn Screener HEN MINN _aAQN o I SEMI TR PARKING a a a a a all 48 Linear Feet of 17ftHigh Panels OPERATIONS YARD 40ft Linear Feet of 12ff-High Panels • A• • t 4. Is FA en D III';a/z l Figure 4-7 Scenario 1 Mitigation Location Shredder/ Screener - - .r741, j;. WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Noise mitigation - placement of 20' -tall panels f •Illib. •1 I• •• .. e.4, N• 4646• UFO ••46 ••1 ••• M• ese ••4 ••► ••• e•• .•/ set M1 •1. •N IN •It • 0.4, M4 •. .. •.. •.. es* miss ass •4.1 •.l• fl ass ass •.se ems 1M t•. ae• •.• see VMS •eM Of* •1f 000 •ss a ems •• • •. • •.. 4446 a.♦ 4•e /M •aN fla •446 •1446 ass •••1 •1a •4. �•• . • •1446 w tN ass •54 �•a SO r ... .• O. iii •1• •e• 4646• •N •1• Is. H• ••$I Lt sea •1s e•• f•. •.e '•• ►s• am ••e 41• site •1• .4,• - as as ass M• •i. •H t•• sae as ass p46 ••. ••• 0.. •.. as s.se we. ••. •.. *.a sea ... a .• •.. use *64M1 ••4* ••a ass .aa K• s4• Nee •0* N• 4610 444 NSwap• s4• ♦1 •W alga 4,.• 0546 .a a. on •1s• wee .me *Ors 4•• 'Vs ass .e• ssa ate 46•• it. •se Ott •44 Sea at' ♦.e •• •• HEAVY EQ JIPME F 1ATBE D TRAILER FRONT END LOADER. FORKINT SEISMIC & TRAIIR PARKING & STORAGE ARIA RATS YARD RAW MATER STOCKPU b GENERAL STORACI AR 128 Linear Feet of 2Oft-High Panels Figure 4-S Scenario 3 — Mitigation Location WELD COUNTY GOVERNMENT Department of Planning Services Vitt COUNTY, CO WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Light mitigation ✓ All lighting shall be downcast and shielded ✓ Truck lights - solid fence will block the lights from trucks and other vehicles from the neighboring properties ✓ Pole and building mounted lighting will be no taller than 20 - feet ✓ Complaints will be promptly addressed and corrected WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Screenina - Fence ✓ Truck lights will be blocked by solid fence ✓ Fence will surround the facility not the entire property EARTH -TONE COLOR kiETAL SIDING 1 b WELD COUNTY GOVERNMENT Department of Planning Services Vitt COUNTY, CO WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co 4. Compatible with Future Development (Weld Comp Plan Map & Municipality Plans) Weld County, Fort Lupton, Brighton, Lochbuie ✓ Weld County Comprehensive Plan shows the site as Urban Area ✓ The Town of Lochbuie and the City of Brighton - no comments ✓ The City of Fort Lupton - no concerns weld.gov WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Outside of Ft Lupton's FLUM i S • • • r 741 Future Land Use Updated October 1, 2020 Planning Area Riparian Zone Dacono City Limits I I Existing Corporate Limits 4R V Agricultural & Rural Residential Single -Family Detached Single -Family Attached Multifamily I 0 I 1 Commercial General Commercial Transition Downtown Mixed -Use Industrial z 4 Miles Light Industrial & Office Mineral Zone Parks & Open Space Public / Semi -Public WELD COUNTY GOVERNMENT Department of Planning Services V1/4, sit COUNTY, CO Figure 42: Town of Lochbuie DRAFT Future Land Use Map Outside of Lochbuie's FLUM f VIP ;v MIMS NIS IIMINir IMES MEM MIMS. Eller MEM SEM VMS — Mom in Mir anis IL >•�rWCR 6 r Van cd gral tsar' „sans.. six e Sm. rim' mimmig *AI El::11 • mss gie %li nNM oaf w 1ir • rr ■, Prielthi7 A II J iii f/tit= fp 054:as6,1143:=CZ A NB ma nit. wirc$11: tempincri paw Runs r rea NI Bain r limin1111::::17 _ Plait maw la ouP t c-1 I- Future Land Use Map (FLUM) Town ■ ■ if t I I V Rural Residential Low Density Residential Me di um Dens it y Res ident is l Business Empbyement Mixed•Use Potential Town Center W W TP Condition Area stint Si* ■ Agriculture Open Space/Parks Public Other tvtunicipabties Town Limits Tlvee•tvlileArea • I Potential Business Area --- Potential BusinessCorridor I�tr .II III'- WELD COUNTY GOVERNMENT Department of Planning Services Vitb COUNTY, CO City of Brighton FLUM Residential Estate Residential (Adams / Weld County) Low Density Residential (0.5 - 5 DU/A) Medium Density Residential (5 - 12 DUTA) High Density Residential (12 - 24 DUJA) Agriculture & Open Space Agriculture (Adams / Weld Gouni‘. I ES Parks & Open Space le Natural Resource Conservation Mixed Use /rj Mixed -Use Commercial i / Mixed -Use Residential Local District Mixed -Use 411, Downtown WELD COUNTY ADAMS COUNTY' Thornton Fort Lupton o a male 1 S. S I M Mt II Olt Asitagia Brighton 900 ken ati Amert.. Mama& co WW1 mom blicrt wwn Oak Lochbuie Comprehensive Plan FUTURE LAND USE MAP WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO 5. Overlay or Hazard District - not in an Overlay X 1-25 Overlay District X Geologic Hazard Overlay District X Special Flood Hazard Area XAgricultural Heritage Overlay District X MS4 - Municipal Separate Storm Sewer System Area XA-P (Airport) Overlay District X Historic Townsites Overlay District WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO 6. Effort to Conserve Prime Farmland ✓ Currently lessee forfarming of alfalfa and flood irrigated ✓ Water will not be sold ✓ Soil type - Farmland of Statewide Importance & Prime Farmland if Irrigated ✓ Not a significant reduction in farmland if removed from agricultural production as it is ~30 acres WELD COUNTY GOVERNMENT Department of Planning Services • COUNTY, CO 6. Effort to Conserve Prime Farmland 56 ao • • Aa 85 85 56 1 47 56 56 CR 6 Al S e a salaams ..... g a Area of operations 56 75 i Table -Farmland Classification (Farmland Classification) Map unit symbol Map unit name Rating Acres in AO1 Percent of AOI e 4 Olney to 1 fine sandy percent slopes loam, 0 Prime irrigated product erodibility) factor) exceed farmland does of 60 and I (soil x if the C not (climate 17> 2 38.5% 7 Olney to 3 fine sandy percent slopes loam, 1 Prime irrigated product erodibility) factor) exceed farmland of does 60 and I (soil x if the C not (climate r' _+ 14.9% 56 Renohill percent clay slopes loam, 0 to 3 Farmland importance of statewide 10.3 26.0% 7c, Vona sandy percent slopes loam, 0 to 1 Farmland importance of statewide 8.1 20.6% 76 Vona sandy percent slopes loam, 1 to 3 Farmland importance of statewide 0.0 0.0% Totals for Area of Interest 39.5 100.0% WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, Co 7. Protection of Health, Safety, & Welfare ✓ Airemissions mitigated via proprietary pyrolysistechnology ✓ Noise - mitigation proposed ✓ Dust Abatement Plan -Gravel and concrete pads. Dust from processing will not be significant enough to be a nuisance. ✓ Drainage report - Stormwater pond to be constructed ✓ Lighting Plan - Downcast & shielded required; fence to block lights from trucks, and trucks to operate during daylight hours ✓ Waste Handling Plan - Metal from the waste wood will be recycled; concrete pad forthe containment of the waste wood material ✓ Screening Plan - Metal fence will surround the entire site; possibility of berms on the eastern portion weld.gov WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Staff finds that this Use by Special Review is consistent with Section 23-2-220.A. Section 23-2-220.A.1.-Thatthe proposal is consistent with Chapter 22 of this Code and any other applicable code provisionorordinance in effect. Section 23-2-220.A.2. - That the proposal is consistent with the intent of the district in which the use is located. Section 23-2-220.A.3. - That the uses which would be permitted will be compatible with the existing surrounding land uses. Section 23-2-220.A.4. - That the USES which would be permitted will be compatible with future development of the surrounding area as permitted by the existing zoning and with the future development as projected by Chapter 22 of this Code or Master Plans of affected municipalities. Section 23-2-220.A.5. - That the application complies with Articles V and Xl of this Chapter if the proposal is located within an Overlay Zoning District ora Special Flood Hazard Area identified by maps officially adopted by the County. Section 23-2-220.A.6. - That if the use is proposed to be located in the A (Agricultural) Zone District, the applicant has demonstrated a diligent effort has been made to conserve prime farmland in the locational decision forthe proposed use. Section 23-2-220.A.7.-Thatthere is adequate provision for the protection of the health, safety and welfare of the inhabitants of the neighborhood and the County. WELD COUNTY GOVERNMENT Department of Planning Services Vitt COUNTY, CO SITE WELD COUNTY GOVERNMENT Department of Planning Services Vitt .‘14. 62d.allar COUNTY, CO trassissemi View looking south WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO aIll[lphrtair _apt.% View looking southe • WELD COUNTY GOVERNMENT Department of Planning Services sit COUNTY, CO View looking east/northeast along CR 6 WELD COUNTY GOVERNMENT Department of Planning Services 861 e _ear COUNTY, CO %el art, leer • WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO View looking across Kalooga Lake WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Sr 4 a ? %4Pirspirr -4 -- lfi 1 i • —4c, .r� a 9 ■s Air IA. of f' 4 i • • C I a ia�Y. r.rt ,.:4,r Y 1 '� _srsubirl !" .� °Rt .4 • Z it = .T; It y 9 ►.. r #e • View looking southwest along CR 6 �- 4 WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO Injection well sheds WELD COUNTY GOVERNMENT Department of Planning Services COUNTY, CO r Y'ra ira;EICEr f r CUP Cu.VERT - w o' I0' 4 vn yasrnrie Ala O!' '• 3 ROC- 3uttr `Q VC- A ?mr 3 r vt Raw material stockpiles. x. 20 tall (rail slash, pallets, crates, etc.), C '"p (J -.sc.O 10 a'1 PICNIC LiteT %et telt% 5CL+!Ttcks SIPE PENCE 5- .a_._i.••• yr L"+:per r5E:O LZ UI: ....,.e COCA c.'? C"W 1 'k'c, 71' - • aws 0 O. C. 0 O- -C s CPI51P4C POSER C%f. PLY Sea EY A • co-,:a:51EV"ySL WEAL Ma. 6' Pi rT.,E w:lT+L1rf1 ► 'IrALt TV t. aE t'htil4b *fi11 'EA t\ AAL C'( $ FENCE Lcc—Al ss suS.tCT Tfl wtCfFrearn W7D1i'L r 2,T 1n LQTA Ask *VW SCUTUM fu uc NO ADDED LANDS.CAPINC UNOISRARBE0 CRASS MIX a�• es 'War, i.. E s .injr, Ea'SleE',1 'IC * vif l:•: Ev::.i,'Ds LIT A' $69'14' Sr Si 300 CEO• LOTE • EIOC-3:R PARCEL �t,t;i Ait FI a NOWA CONVERMON MUM E t•kC 1 E. I al IMPROVEMENT LIST MODULAR OFFICE & CONTROL CENTER 8' X 40 ' CARGO CONTAINERS X(4) SCREENER (MOBILE) SHREDDER (MOBILE) :ONTROL ROOM MASTER POWER DISTRIBUTION CENTER 10 STACK FIRING LINE (KILNS) EMPTY KILNS, 10 - 15 METAL LID RACK 500 GALLON DIESEL FUEL TANK WI SECONDARY CONTAINMENT 18.000 GALLON PROPANE TANK W/ SECONDARY CONTAINMENT EMERGENCY DIESEL GENERATORS EMPLOYEE PARKING (UNMARKED) 4 SPACES ASPHALT STOCKPILE & LOADING PAD, 100 ' x 1001 KILN WI STACK, 8' DIAMETER, 22' IN HEIGHT KILN W/O STACK, 8' DIAMETER, 8' IN HEIGHT POWER CONTROL CENTER SKID MOUNTED W! DOWNCAST & SHIELDED LIGHT, 20' IN HEIGHT PORTABLE TOILETS (WATER WELL AND 0\A/TS PROPOSED) Operations yard with 10 active kulns1and storage of in -active kilns. WI 11/4Kit 0 7* WELD COUNTY GOVERNMENT Department of Planning Services Vitt COUNTY, Co End of USR24 0019 weld.gov Jessica Reid From: • . I %J. Cc: Subject: Diana Aungst Friday, October 10, 2025 9:29 AM Esther Gesick Jessica Reid; Jan Warwick; Chloe White Exhibit for USR24-0019 Esther, The email below is from a SPO for USR24-0019. Please add as an exhibit. Thanks, 4--� at•1 8 G I -~. COUNTY, CO Diana Aungst, AICP I CFM Principal Planner Department of Planning Services Desk: 970-400-3524 P.O. Box 758, 1402 N. 17th Avenue, Greeley, CO 80632 ►in Our Team IMPORTANT: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Jeri Yarbrough <yarbroughacres@icloud.com> Sent: Thursday, October 9, 2025 7:22:22 PM To: Diana Aungst <daungst@weld.gov> Subject: Bio char This Message Is From an Untrusted Sender You have not previously corresponded with this sender. Use extra caution and avoid replying with sensitive information, clicking links, or downloading attachments until their identify is verified. Hi Diana Here is my field that I irrigate next to NGL property. The ditch is located on the east and it flows to the west . The overflow water flows down by my road to the north over to Dave sacks lake . If it's not addressed then I will not be able to irritate my 5 s taking my right to farm away . Yarbrough 1 • i I, 4 a ♦♦ter♦ ,/� f44 _ y 1 +1.41 _ 4 1 oast • ___ % -. 4.114114° Ink t+ r r r + alo r.�l« k/ri f t 4:•• •1 WI 4 A. 1... ALI. , it • • e. • . tc • ° c • ; ♦1 J • _ x•14. f,J y,ry ,' ♦, Ac • .11 4 fir• - ' t ip•. r • r t Ri i 145- 'to rcaic . - S ^) *Stair r .1 • • I • � fir. 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Ani a `� •-� tea. w a�� 1'- R w...J re*_ "..enC w ]rte! • • J ra- rY, . jr �# i_ �,,�. ._ y l.• �i' nts;w-��i Rte"' !'�, i _ _ •.e -• ..-. 1 \fir ,,s•. .r - ink atia re -,: y )...,A.„ s " - ♦-j' .-. r • - y -�. , ,f gr. .-M' i�' 7e ] �~ a V �� ' i � J - f • •• ,.- 4--• - b, Si .• • Salittr , yi -r.. •-a- rat • • ... • a� I. ! . - • Sass ell aa►,be. - r_iaw # y r tea' �. arr. t- .- "r - ••mow r� 1�1•� _a. ,. ,; • .•• • mss• +�ory, P• _ -,. ' • �► i 46.its+.- - X• t •4 tows'. �..•, K•y.: • sic:1/41;?-t.nripitiaTtrairt.... 6%. ..• lass y zi;,rietio _ • ea, AWL tvisSit �. ► itr sir' e�V i 1 • • r'am4V 1 .ra itAi It1�3i`�C" tai _� �S•Ti•; �fi" �I. T A .. lr-0 rLb Col e From: Sent: To: Subject: Jeri Yarbrough <yarbroughacres@icloud.com> Saturday, October 18, 2025 11:24 AM Diana Aungst Bio char danger to horses This Message Is From an External Sender This email was sent by someone outside Weld County Government. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi Diana These 2 studies further confirm the effects the biochar plant would have on the horse's. This was sent by my vet. Jeri Yarbrough https://pubmed.ncbi.nlm.nih.gov/32432128/ Sent from my iPhone 1 Iffiff An official website of the United States government Here's how you know FULL TEXT LINKS frontiers FuQ text Open access Front Vet Sci. 2020 May 5:7:185. doi: 10.3389/fvets.2020.00185. eCollection 2020. Increased Weekly Mean PM�.5, and N02 Are Associated With Increased Proportions of Lower Airway Granulocytes in Ontario Horses Gabrielle Brankston 1 Amy L Greer 1 Quinn Marshall 2 Brittany Lang 2, Kai Moore Douglas Hodgins John T G Hennessey 3 Janet Beeler-Marfisi Affiliations PMID: 32432128 PMCID: PMC7214617 DOI: 10.3389/fvets.2020.00185 Abstract Ambient pollution is associated with the development and exacerbation of human asthma, but whether air pollution exposure is associated with lower airway inflammation in horses has not been fully evaluated. The Air Quality Health Index (AQHI) is an online tool used by asthmatic Ontarians to modify their outdoor activity when ambient pollution is high. A single AQHI value, falling on a scale from 1 to 10', is calculated from measurements of fine particulate matter (PM2 5), nitrogen dioxide (NO2), and ozone (O3). Increased AQHI values predict an increased risk for presenting to a health care provider for assessment of asthma exacerbation, with a time lag of 0-9 days after an increase. Whether ambient air pollution is a risk factor for identifying increased lower airway inflammatory cells on cytologic evaluation of bronchoalveolar lavage fluid (BALE) of horses has not yet been explored. To investigate this relationship, case data including BALF cytology preparations from horses across southern Ontario, Canada, were retrieved from the Guelph Animal Health Laboratory's archives. Spanning the years 2007-2017, 154 cases were identified within a 41- by 30 -km area surrounding the cities of Guelph and Kitchener. In 78 of 154 cases, cytologic reevaluation identified increased proportions of one or a combination of BALF neutrophils (mean 5%, range 0-15%), eosinophils (mean 2%, range 0-31%), and mast cells (mean 4%, range 0-10%). To assess the effect of lagged pollutant and temperature exposures in these 78 cases, weekly mean values of AQHI, PM2 3, NO), O3, and temperature were recorded for the 4 weeks prior to the date of the horse's presentation for respiratory tract evaluation. The relationship between ambient exposures and increased proportions of lower airway granulocytes was evaluated using a case -crossover design. Single unit increases in 2-, and 3 -week lagged weekly mean PM2.5 and NO2, were associated, respectively, with an 11% (p = 0.04, 95% confidence interval, CI = 1.01-1.22), and 24% (p = 0.03, 95% CI = 1.08-1.43) greater risk of identifying increased lower airway granulocytes. These findings suggest that exposure to increased ambient pollutants is associated with lower airway inflammation in Guelph and Kitchener area horses. Keywords: air quality health index; ambient air pollution; bronchoalveolar lavage; case -crossover analysis; equine asthma; inflammatory airway disease; respirable particulate; smog. Copyright © 2020 Brankston, Greer, Marshall, Lang, Moore, Hodgins, Hennessey and Beeler-Marfisi. PubMed Disclaimer Figures -- • w -a-- , Ille--e..o.rS -.••••••• S - Figure 1 Flow chart of Animal Health... ';',7firmi r • • Figure 2 Pictorial representation of one possible... LinkOut - more resources Full Text Sources Europe PubMed Central Frontiers Media SA PubMed Central Animal Health Laboratory: 1342 equine fluid cytology cases "database 1" BALF analyzed and geographic location of horse known? Yes (335 cases) > 20 cases in geographic region? Yes (154 cases) Enter additional case data (154 cases) Case inventory verification (154 cases) Case reevaluation (154 cases) • • No: Remove 1007 cases from database No: Remove 181 cases from database Final case categorization: 78 cases with an increased proportion of lower airway granulocytes Transfer date of presentation ("case day") of 78 cases with an increased proportion of lower airway granulocytes to "database 2" Enter air quality and temperature data into database 2: 78 case days + 4 -week hazard period 234 control days + 4 -week control period Perform case -crossover statistical analysis using database 2 Hazard period Case day 1 1 3 Control period • Control day From: Sent: To: Subject: Jeri Yarbrough <yarbroughacres@icloud.com> Saturday, October 18, 2025 11:17 AM Diana Aungst Bio char This Message Is From an External Sender This email was sent by someone outside Weld County Government. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi Diana, Can you add this article to the bio char file about the pollutants that will be harmful to me and my horses https://www.mdpi.com/2071-1050/16/3/1_169 Sent from my iPhone 1 tsustainability MDPI Rev iezv Reviewing Air Pollutants Generated during the Pyrolysis of Solid Waste for Biofuel and Biochar Production: Toward Cleaner Production Practices Simeng Li check for updates Citation: Li, S. Reviewing Air Pollutants Generated during the Pyrolysis of Solid Waste for Biofuel and Biochar Production: Toward Cleaner Production Practices. Sustainability 2024, 16, 1169. https://doi.org/10.3390/sul6031169 Academic Editor: Pallav Purohit Received: 23 December 2023 Revised: 25 January 2024 Accepted: 29 January 2024 Published: 30 January 2024 Copyright: © 2024 by the author. Licensee MDPI, Basel, Switzerland. This article is an open access article distributed under the terms and conditions of the Creative Commons Attribution (CC BY) license (https:// / creativecommons.org/ licenses/by / 4.0/). Department of Civil Engineering, California State Polytechnic University, Pomona, CA 91768, USA; sli@cpp.edu; Tel.: +1-909-869-4787 Abstract: The production of biofuels and biochar through pyrolysis is a promising avenue for sus- tainable energy generation and waste management. However, this process can inadvertently release various air pollutants into the atmosphere, potentially compromising its environmental benefits. This article provides a comprehensive overview of the gas pollutants associated with pyrolysis for biofuel and biochar production, as well as different variables affecting gas emissions. Key pollutants such as particulate matter (PM), volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), carbon monoxide (CO), and nitrogen oxides (NR) have been discussed in terms of their formations and emissions during pyrolysis processes. Furthermore, major factors influencing pollu- tant emissions, including feedstock composition, pyrolysis conditions, and combustion technologies have been examined with up-to-date examples. The review highlights the significance of emission control strategies, such as advanced reactor design, catalyst utilization, and the integration of realtime monitoring systems, in mitigating air pollution from pyrolysis processes. By shedding light on the environmental challenges associated with pyrolysis -based biofuel and biochar production, this article aims to encourage the development of cleaner and more sustainable approaches to harness the potential of solid waste conversion technologies. Keywords: biofuel; biochar; pyrolysis; emissions; pollutants; reactor design; process optimization; regulations; sustainable practices 1. Introduction The world is undergoing a transformation in the way it meets its energy and agricul- tural needs, driven by a growing awareness of the environmental consequences of fossil fuel use and the need to develop sustainable alternatives [ 1-3]. One such promising avenue is the utilization of solid waste pyrolysis, a thermochemical process that transforms organic matter into biofuels and biochar [4-6]. As pyrolysis involves the thermal decomposition of organic materials in the absence of oxygen, it is capable of converting various feedstocks, including agricultural residues [7], forestry waste [8], and municipal solid waste [9], into valuable end products. These products can, in turn, replace conventional fossil fuels, alleviate the pressure on landfills, and contribute to carbon sequestration in the soil, mak- ing it a pivotal tool in the fight against climate change and resource depletion [6,10,11]. Advanced control processes, such as catalytic fast pyrolysis, integrate fast pyrolysis and bio-oil upgrading into a single, streamlined step [ 12]. This innovative approach not only enhances the overall efficiency but also results in notable improvements in specific biofuel properties, including enhanced thermal stability and heating value, which can range from 18.8 to 34.6 MJ/kg [13,14]. Concurrently, diverse biochar engineering techniques have been devised to tailor specific physicochemical properties and sorption capacities, significantly broadening the spectrum of applications for biochar [15-17]. As countries worldwide grapple with the challenges of climate change, energy se- curity, and sustainable agriculture, the potential of solid waste pyrolysis has ignited the Sustainability 2024, 16, 1169. https://doi.org/10.3390/su16031169 https://www.mdpi.com/joumal/sustainability Sustainability 2024, 16,1169 2 of 30 enthusiasm of scientists, policymakers, and environmentalists alike. Countries such as the United States, Brazil, China, and India have already made substantial investments in the development of pyrolysis technologies [18-20]. Government -funded initiatives and international collaborations have placed a significant emphasis on advancing the field of solid waste pyrolysis. For example, through concerted efforts between the International Energy Agency (IEA) Bioenergy, national programs, and industry stakeholders, standard- ized analytical methods and specifications for bio-oil products have been developed as the technologies continue to mature [21]. This collaborative approach has given rise to suppliers offering commercial quantities of bio-oils tailored for a wide range of applications, including heating oil, natural gas alternatives, and power generation [22]. For more than three decades, these suppliers have also been providing bio-oil fractions that cater to the production of specialty chemicals and flavorings. Furthermore, it is worth noting that the commercial scale of fast pyrolysis technology, as it stands today, is fast approaching a significant milestone, with a capacity nearing 400 t/d [23]. This notable scale -up is poised to reap the benefits of economies of scale as it further evolves and expands. Meanwhile, global studies have consistently demonstrated that biochar holds sig- nificant promise, with the potential to boost crop productivity by up to 11% while si- multaneously reducing annual human -induced greenhouse gas emissions by 12% [24]. Moreover, biochar applications can facilitate the sequestration of approximately 0.7-1.8 Gt of CO2 equivalent per year within the soil system [24]. Furthermore, the implementation of biochar in agricultural practices substantially enhances soil health, creating a more conducive environment for plant growth and improved crop productivity [25]. In a recent study, biochar application at a rate of 30 t/ha, when combined with optimal fertilization, resulted in remarkable yield increases ranging from 17% to 53% [26]. These improvements were particularly pronounced on highly acidic soils, primarily attributed to the enhanced retention of nitrogen, elevated pH levels, and the immobilization of trace metals that had previously hampered crop yields [27,28]. Additionally, biochar applications have been shown to influence plant physiology positively, enhancing the resilience of plant systems against both biotic and abiotic stressors [24,29]. The advancement of biochar engineering techniques has further broadened its applications, extending to groundwater and soil remediation, as well as water and wastewater treatment and reuse [ 15,30,31]. However, as the world enthusiastically embraces solid waste pyrolysis as a sustainable technology, it faces a significant challenge in the form of air pollution generated during the pyrolysis process [32,33]. The exhaust gases produced during pyrolysis can contain a range of harmful air pollutants, including particulate matter (PM), volatile organic compounds (VOCs), carbon monoxide (CO), nitrogen oxides (NOX), etc. These pollutants not only have immediate implications for air quality but also contribute to long-term environmental and health issues [34]. Research studies and reports from various regions, including Europe, Asia, and North America, have highlighted the urgent need to address the air pollution concerns associated with solid waste pyrolysis [35]. The impact of these emissions on local air quality and their potential for global climate change necessitates thorough investigation and effective mitigation strategies. The growing awareness of air pollution concerns stemming from solid waste pyrolysis has spurred governments and international organizations to establish regulatory frame- works and emission standards. As an example, the United States Environmental Protection Agency (USEPA) has initiated an advance notice of proposed rulemaking (ANPRM) with the aim of assisting in the potential development of regulations for pyrolysis and gasifica- tion units [36]. These units play a pivotal role in converting solid or semisolid feedstocks, which encompass materials such as municipal solid waste, industrial waste (e.g., plas- tics and fires), agricultural and animal waste, and organic contaminants in soils and oily sludges, into valuable products like energy, fuels, and chemical commodities. The ANPRM serves as a platform for a diverse array of stakeholders, including potentially affected facilities, small businesses, and state, local, and tribal governments, to partake in the data and information -gathering process [361. Their input regarding the intricacies of pyrolysis Sustainability 2024, 16, 1169 3 of 30 and gasification units and processes is invaluable. Based on the data and information acquired through this ANPRM, the agency will assess the most effective approaches to regulate pyrolysis and gasification units. Simultaneously, environmental agencies and organizations worldwide have set forth stringent guidelines aimed at curbing the release of harmful air pollutants during the pyrolysis process [37-39]. These regulations are designed to strike a balance between harnessing the benefits of biofuel and biochar production through pyrolysis and the imperative of safeguarding human health and the environment. This comprehensive review article seeks to shed light on the critical aspects of air pollutants during pyrolysis for biofuel and biochar production. It delves into the sources and composition of these pollutants, their environmental and health impacts, and the current state of regulatory expectations and compliance in various regions. Furthermore, this review explores the strategies and technologies employed to minimize emissions during the pyrolysis process, paving the way for more sustainable and ecofriendlier biofuel and biochar production. In doing so, this article provides a comprehensive overview of the challenges and opportunities presented by solid waste pyrolysis, offering insights into its role in the transition towards a cleaner and more sustainable energy and agriculture sector. 2. Factors Affecting the Types of Air Pollutants during Pyrolysis Due to its thermal degradation characteristics, the pyrolysis of solid waste, including biomass, stands out as a leading technology for both waste volume reduction and the creation of various forms of fuel [ 181. While pyrolysis effectively decreases the emission of pollutants, it also gives rise to the production of diverse types of pollutants [37]. The types and levels of pollutants generated during pyrolysis are influenced by a variety of factors, which can vary depending on the feedstock, pyrolysis process conditions, and equipment used [40J. 2.1. Feedstock Composition The nature of the feedstock significantly influences the types of pollutants generated during pyrolysis. Different feedstocks vary in terms of their organic composition, moisture levels, and impurities, leading to variations in emissions [40,41]. Forestry waste, agri- cultural residues, waste tires, and plastics each possess distinct chemical compositions, resulting in diverse pollutant profiles during pyrolysis [421. Research has demonstrated that the pyrolysis of furan binders may result in the emis- sion of significant quantities of gaseous pollutants, including cresols, benzene, toluene, and m,p,o-xylenes [43,44]. In the case of waste tires undergoing pyrolysis, significant environ- mental concerns arise due to the emergence of polycyclic aromatic hydrocarbons (PAHs), sulfur -based compounds, and nitrogen -based pollutants [451. These compounds primarily originate from the decomposition of the tire's original constituents during pyrolysis and are exacerbated by the formation of high molecular -weight cyclic compounds (known as cycloadducts) through Diels-Alder reactions, a chemical reaction between a conjugated diene and a substituted alkene [46]. PAHs encompass a broad spectrum of over a hundred chemically related compounds, each characterized by distinct structures and associated toxicity, making them significant environmental pollutants [471. Their detrimental im- pact on the environment is attributed to their ability to induce toxicity through various mechanisms, affecting the biota and potentially leading to carcinogenic and mutagenic consequences upon exposure [47]. In addition to PAHs, nitrogen -based compounds (NOX) must be carefully monitored, as they can contribute to atmospheric concerns such as acid rain formation and ozone depletion [48]. Understanding the reaction pathways that can mitigate the presence of these pollutants during waste tire decomposition is crucial. Moreover, the nitrogen content in the original materials (fuel -N) significantly contributes to the formation of nitrogen -based pollutants within the resulting products, which can manifest in various pyrolysis products. The major constituents of these nitrogen -based compounds, including hydrogen cyanide Sustainability 2024, 16, 1169 4of30 (HCN), ammonia (NH3), and isocyanic acid, are prevalent within the pyrolysis oil derived from waste tires [49]. Sulfur presents a formidable challenge in the proper disposal of waste tires, primar- ily arising from the vulcanization process employed in rubber manufacturing [50]. This process aims to enhance the rubber's toughness, heat resistance, and overall stability [511. Sulfur compounds in waste tires form cross -linked structures within the long -chain poly- mers of vulcanized rubber, in addition to serving as antioxidants [511. Consequently, sulfur compounds resist degradation, further contributing to the complexity of waste tire pyrolysis [50]. Notably, preprocessing steps, such as drying and size reduction of feedstock, can influence the moisture content, chemical composition, physical characteristics, structural components, and potential reactivity of the feedstock, thus affecting the pyrolysis process and emissions [52]. A recent study delved into the influence of feedstock drying on the emissions of PAHs associated with particulate matter (PM) production in the co -generation of biochar and bioenergy [52]. The study involved the generation of raw pyrolysis volatile compound mixtures from rice husk at temperatures ranging from 400 °C to 800 °C, utilizing a laboratory -scale continuous pyrolysis -combustion system, followed by combustion at 850 "C. The findings revealed a notable contrast when employing as -received (AR) rice husk in comparison to dried rice husk [521. Specifically, the utilization of AR rice husk resulted in significantly higher energy -based PM10 yields, with a 1.2 -fold increase at 400 CC and a 1.6 -fold increase at 800 °C, in comparison to dried rice husk. This increase primarily pertained to the PM2.1_10 size fraction. Additionally, the concentration of PM -bound PAHs for AR rice husk was 2.1 and 2.8 times higher at 400 °C and 800 °C, respectively, compared to dried rice husk [521 Consequently, this led to a notable rise in the energy -based yield of PAHs across the entire range of volatile production temperatures for AR rice husk. Nevertheless, it is noteworthy that the majority of the PM -bound PAH species generated from AR rice husk comprised 2- and 3 -ring PAHs, namely naphthalene, acenaphthylene, and acenaphthene, which generally possess relatively low toxicity [47]. Moreover, the concentration of 4-, 5-, and 6 -ring PAHs was typically lower in the case of AR rice husk, resulting in the benzo(a)pyrene-equivalent toxicity of the PM derived from AR rice husk being lower than that of the dried counterpart [521. 2.2. Pyrolysis Temperature The pyrolysis process occurs over a range of temperatures, and the temperature at which it is conducted can significantly impact the types of products and pollutants produced [42]. Lower temperatures may favor the formation of biochar and bio-oil, while higher temperatures can lead to the generation of syngas [27]. Temperature also influences the composition of tars, gases, and other byproducts [42]. In a recent study, analytical pyrolysis was conducted to assess the emission of major hazardous air pollutants (HAPs) during the pyrolysis of bituminous coal and a bran binder [43]. For bituminous coal, the predominant HAP emissions included cresols, ben- zene, toluene, phenol, and naphthalene, whereas, for the furan binder, m,p,o-xylenes were the notable emissions [43]. It was determined that xylene emissions were primarily at- tributed to xylenesulfonic acid, the acidic catalyst present in the furan binder [43]. Notably, for both casting materials, the majority of emissions occurred within the temperature range of 350-700 °C [43]. The reaction temperature stands as a crucial parameter with a significant influence on the emission of NOx precursors. Elevated temperatures contribute to improved yields of NOx precursors. Notably, it has been documented that lower temperatures promote the generation of NH3, while higher temperatures tend to favor the formation of HCN. It is evident that, during the pyrolysis of most biomass, NH3 is more abundantly generated at lower temperatures, typically below 500 °C (Figure 1). This phenomenon can be attributed to the deamination reaction of unstable amine compounds or the direct depolymerization of proteins. As the temperature approaches approximately 500 CC, the secondary cleavage Sustainability 2024, 16, 1169 5of30 C Tar -N rChar-N r 1---r S!i of intermediates (e.g., heterocyclic -N) and the decomposition of amines contribute to the formation of HCN. Furthermore, it is noteworthy that the NH3 yield curve exhibits either a plateau or experiences an increase within the temperature range of 600-900 °C, whereas HCN exhibits more substantial releases (Figure 1). This is primarily due to the continued decomposition of nitrile-N and heterocyclic-N•NH3 at higher temperatures. The generation of NH3 at high temperatures originates from two distinct mechanisms: the first involves the hydrogenation reaction between HCN, coke, and H radicals, while the second entails the cleavage of heterocyclics in tar. Throughout the heating process, the sensitivity of the NOX precursor formation pathway to temperature determines which N -pollutants dominate during each stage. The transformation of N in biomass with rising pyrolysis temperature is summarized in Figure 1. %Agricultural one (more stable N -A) IP Biomass Industrial one (N-ThItLess stable N -A) decomposition N -IN (NH.1},NO,/3-) bondclearage c .o .f c J ".7 Amine -N PS cyclization I - Heterocyclic -N NH3-N dehydrogenation dehydrogenation Nitrile-N Quaternary -N ring codensation Stable N -A cross linking 25°C 200( 300°C N -5+N-6 r Heterocyclic -N polyme:-ization Oxide -N Heterocyclic -N 00 0 500°C 14 Initial reactions 900°C Secondary reactions Figure 1. Evolution of nitrogen in biomass as pyrolysis temperature rises. Reprinted from Chen et al. (2023) with permission issued by the publisher [33]. 2.3. Residence Time The amount of time the feedstock spends in the pyrolysis reactor, also known as residence time, affects the extent of thermal decomposition and the resulting pollutants [53]. Longer residence times may lead to more mass being volatilized and relatively higher emissions [27]. A recent study revealed that a residence time within the range of 10 to 100 min had a marginal impact on both rapeseed stem biochar yield and biogas emissions. This suggests that a residence time of less than this range should be favored for minimizing emissions [53]. In the same study, a statistical analysis of the literature data indicates that there is no significant correlation between residence time and biochar yield (p > 0.1), imply- ing that biogas emissions would also be minimally affected [53]. It is worth mentioning that in certain cases, residence time demonstrated a significant negative relationship with yield within a lower residence time range. For example, the biochar yield from Saccharin.a japonica exhibited a reduction from 86.6% to 59.1% as the pyrolysis residence time extended from 1 to 5 min at 380 °C [54]. This change corresponded to a notable increase in both biogas and bio-oil generation. In addition, with the extension of residence time, a greater proportion of heavy metals in some feedstock (e.g., biosolids) was either volatilized or transferred into biogas. Sustainability 2024, 16,1169 6 of 30 However, as reported in a recent study, a significant quantity remained sequestered within the biochars, contributing to heightened total concentrations of heavy metals [55]. This retention was validated through extraction experiments, affirming the immobilization of heavy metals within the biochars as they transitioned from active chemical forms to more stable states [55]. The outcomes of the risk assessment underscored that longer residence times mitigated the potential environmental risks associated with heavy metals within the biochars. 2.4. Heating Rate The rate at which the temperature is increased during the pyrolysis process, known as the heating rate, can influence the types of gases and tars produced [56]. This rate directly impacts the speed of chemical reactions occurring within the process. A faster heating rate accelerates the breakdown of organic materials, intensifying chemical reactions and generating larger volumes of volatiles and gases as feedstock decomposes more rapidly [53]. This swift decomposition encourages the rapid vaporization of volatile compounds present in the feedstock, including methane (CH4), hydrogen (H2), carbon monoxide (CO), and diverse organic compounds, consequently elevating gas emissions [33,53]. Furthermore, the heating rate shapes the temperature distribution within the pyrolysis reactor. Rapid heating may induce uneven temperature distribution or spikes in specific reactor areas, influencing the types and volumes of gases produced [53]. Consequently, varying heating rates can alter the yield distribution of pyrolysis products. Higher heat- ing rates tend to favor the production of gases and bio-oils over biochar, resulting in the production of lighter hydrocarbons and gases, whereas slower heating rates may enhance biochar formation while reducing gas release, leading to the formation of heavier hydrocar- bons [57-59]. Adjusting the heating rate thus crucially influences the output composition and quantities of pyrolysis products [33], marking it as an important parameter in process optimization. For instance, in a study utilizing rapeseed straw for biochar production, elevating heat rates beyond 50 °C/min led to reduced biochar yield and increased bio-oil or biogas production [53,60]. This shift was attributed to heightened organic breakdown and the release of carbon -rich vapor, phenomena amplified at higher heating rates [53]. 2.5. Reactor Design Pyrolysis reactors come in various designs and configurations, each with its distinct char- acteristics impacting the pyrolysis process and the generation of air pollutants [61,62]. Three primary types —fixed bed, fluidized bed, and rotary kiln —stand out in their configura- tions and their influence on temperature, pressure, and residence time within the reactor, consequently shaping the types and quantities of pollutants emitted [631. Fixed -bed reactors consist of a stationary bed of feedstock (Figure 2a) [64]. The uniform arrangement allows for precise control over residence time and temperature profiles. However, limited heat and mass transfer might occur within the fixed bed, potentially leading to localized temperature variations and incomplete pyrolysis [65]. This setup can result in the production of tar and char, contributing to emissions of PAHs and VOCs [66]. Characterized by a bed of particles suspended and agitated by a flow of gas, fluidized bed reactors facilitate excellent heat and mass transfer (Figure 2b) [67]. The increased contact between the feedstock and the heating medium enhances the pyrolysis efficiency [62]. Nevertheless, due to the higher temperatures and rapid reactions in the fluidized bed, they may lead to increased NOX emissions from nitrogen -containing compounds present in the feedstock [68]. Rotary -kiln reactors utilize a rotating cylindrical vessel to heat and process the feed- stock (Figure 2c) [69]. The continuous movement ensures a relatively uniform temperature throughout the material [70]. However, fluctuations in heating and cooling zones along the reactor length may lead to diverse pyrolysis reactions [69]. This variation can produce a Sustainability 2024, 16, 1169 7 of 30 range of pollutants, including tar, soot, and gases such as CO, CO2, and hydrocarbons, due to varying degrees of thermal decomposition and residence times [71-73]. 0 N2 Gas Cylinder Hopper Vibration Channel Feedstock Flow Controller Fixed Bed • Reactor • Furnace • High !Imperatore Fluidized Bed! Reactor S Gas Preheater '4 Condenser System (liquid pyrolysis oil) Collection Drum Circulating Gas T T Heat Exchangers (a) Heating Element Thermocouple Intensive Cooler Temperature Controller Gas Sampler (incondensable gas) Electrostatic Filter • Bio-Oil (b) Flare Compressor Heat Bio-Oil Biodsar (c) Heater Cyclone Bag Condenser Gas Filter Tank Bio-Gas Figure 2. Schematic diagrams of pyrolysis reactors: (a) fixed bed, (b) fluidized bed, and (c) rotary kiln. Sustainability 2024, 16,1169 8of30 The design and configuration of each reactor influence the temperature distribution, residence time, and contact between the feedstock and heating medium [63]. Variations in these factors affect the pyrolysis reactions, leading to the formation of different pollutants. Factors like incomplete combustion, inadequate heat transfer, and variations in temperature zones within the reactor contribute to the release of pollutants such as PAHs, VOCs, NOR, and carbonaceous particles [631. Therefore, optimizing reactor design and operational parameters is crucial in minimizing pollutant emissions during pyrolysis for biofuel and biochar production. 2.6. Type of Pyrolysis Fast pyrolysis is a rapid thermochemical process that involves swiftly heating the feedstock in the absence of oxygen [74]. Operating at temperatures typically ranging from 400 to 600 °C and with residence times on the order of seconds, fast pyrolysis is known for its expeditious and efficient production of renewable fuels and chemicals [121. This process is particularly well suited for large-scale applications where higher throughput is a priority [75]. Fast pyrolysis tends to yield higher concentrations of volatile gases, including hydrocarbons, phenols, and various organic compounds [76]. In a recent study focusing on biochar production through fast pyrolysis, conducted at a high heating rate of 100 "C per second until reaching close to 800 "C, gas yields from 14 different plant feedstocks varied between 18% and 28% for live plant species, and from 16% to 25% for dead plant species [77]. The gases generated from these diverse feedstocks exhibited varying compositions. Concentrations of CO ranged from 53.4% to 63.0% for live plant species and 55.4% to 60.5% for dead plant species. Notably, a considerable amount of phenol was detected during the biochar production process with all 14 different feedstocks, accounting for nearly 27% of all the hydrocarbons generated [771. Slow pyrolysis is characterized by a relatively low heating rate and operates at temper- atures typically ranging between 300 and 500 °C [78]. Distinguished from faster pyrolysis processes, slow pyrolysis involves a more gradual and controlled heating of the material. One of its notable outputs is the substantial production of biochar [79]. Despite its slower kinetics compared to other pyrolysis methods, slow pyrolysis also generates bio-oil and combustible gases [6]. The extended residence time of the material in the pyrolysis reactor during slow pyrolysis allows for more thorough thermal decomposition, resulting in a broader spectrum of end products [61. In a recent study, slow pyrolysis conducted at tem- peratures ranging from 25 to 550 °C reported BTX (benzene, toluene, xylene) compound emissions reaching as high as 0.33 mg C/min. The predominant hydrocarbons in this study were lighter hydrocarbons (C2 -C4), constituting up to 80% of the total hydrocarbons generated [80]. Flash pyrolysis is an expeditious thermal decomposition process involving the rapid heating of biomass or other organic materials to elevated temperatures, typically within the range of 500 to 1000 CC, through a brief and intense heat pulse [81]. The term "flash" pertains to the remarkably brief residence time of the material within the high -temperature zone, typically measured in milliseconds [81]. In the flash pyrolysis process, biomass experiences an abrupt and intense heat source, inducing swift thermal decomposition. The abbreviated residence time curtails complete material breakdown, resulting in the generation of bio-oil, gas, and biochar. The intense heating conditions sometimes facilitate a more pronounced secondary cracking of pyrolysis vapors, leading to the increased formation of CO, CH4, C2H2, C2H4, and C2H6 [82]. Limited research has explored gas emissions in emerging pyrolysis technologies, including microwave pyrolysis, solar pyrolysis, and plasma pyrolysis. Given their distinct heating mechanisms, comparing these innovative pyrolysis processes with conventional methods presents challenges. There is an urgent need for new protocols and guidelines to regulate these evolving pyrolysis processes. Sustainability 2024, 16, 1169 9of30 2.7. Gas Atmosphere Pyrolysis, conducted within diverse gas atmospheres, profoundly impacts the compo- sition of pyrolysis products and resultant air pollutants [831. Several atmospheres —such as inert gases, air, or steam —alter the pyrolysis process and consequent pollutant genera- tion. The choice of pyrolysis atmosphere influences the balance between various reactions occurring during the process [841. Employing inert gases such as nitrogen (N2) or helium (He) prevents oxidation reac- tions during pyrolysis [85]. This atmosphere inhibits the combustion of feedstock, main- taining a reducing environment that impacts product distribution [85]. Inert gas pyrolysis often leads to the production of biochar and volatile compounds. However, incomplete combustion and limited oxygen may cause the formation of carbon monoxide (CO) and potentially harmful hydrocarbons [86]. Although pyrolysis is supposed to be conducted in oxygen -limited conditions, the presence of air is common in practice [87]. The introduction of oxygen allows partial oxidation of the feedstock, leading to increased combustion and potentially reducing the formation of biochar [12,41]. However, the presence of oxygen can also escalate the generation of harmful pollutants like NOx due to the reaction between nitrogen in the feedstock and oxygen at elevated temperatures [88]. Additionally, the higher oxygen content may lead to increased emissions of CO2 [89]. Introducing steam in pyrolysis reactors facilitates steam reforming reactions, altering product distribution [90]. Steam can enhance the decomposition of volatile compounds, promoting hydrogen -rich gas production [91]. However, high -temperature steam can also facilitate the release of VOCs and potentially contribute to the formation of NOx [88,92,93]. According to a recent study, an abundance of water vapor in the combustion atmosphere would hinder the liberation of fuel -N during the devolatilization phase and encourage the creation of specific reducing gases. Aside from the expected dilution impact, introducing steam could also abbreviate the timeframe for both homogeneous and heterogeneous NOx reduction by the reducing gases and char. It is theorized that the surge in NOx emissions might be attributed to the formation of OH radicals at elevated temperatures and high O2 content [94]. The variation in pyrolysis gas atmospheres significantly impacts the pathways of pyrolysis reactions, affecting the distribution of pyrolysis products and subsequently influencing the emission of diverse air pollutants such as CO, CO2, NO, VOCs, and other organic compounds [83-85]. Therefore, as shown in Table 1, choosing the appropriate gas atmosphere in pyrolysis reactors is critical to tailor product yields and minimize the generation of harmful pollutants. Table 1. Gaseous contaminant emissions under various pyrolysis conditions with different types of feedstock. Feedstock Pyro. Temp. Residence Time Heating Rate (DC) (min) (°C/min) Atm. Gas Reactor Type Gaseous Contaminant Ref. Sewage sludge 500-800 20 Rotary kiln PAHs 0.22-421 µg/m3 [95] Xylan, lignin, cellulose 800 2.6 s N2 100 mL/min Fixed bed PAHs 11.9-48.8 Rg/g [76] Wood pellets, e -waste 850 6-15 12-25 N2 500 mL/min Fixed bed CO 227.6 mg/g CO2 107.7 mg/g VOCs 91.9 mg/g [96] Sustainability 2024, 16, 1169 10 of 30 Table 1. Cont. Feedstock Pyro. Temp. Residence Time Heating Rate (°C) (min) (°C/min) Atm. Gas Reactor Type Gaseous Contaminant Ref. Coal, pine sawdust 300-1000 60 3 N2 100 mL/min Fixed bed CO 1.9-7.2% CO2 2.3-21.1% CH4 3.4-19.2% [97] Municipal solid waste 600-800 6 N2 200 mL/min Fixed bed CO 5.8 mol/kg CH4 3.2 mol/kg [83] Wheat straw 350-650 20 N2 100 mL/min Fixed bed CO 19-39°/0 CO2 15-64% [98] Municipal sludge 300-700 60 10 N2 1 L/min Fixed bed H2S -900 mg/m3 -220 mg/m3 NO -140 mg/m3 CO -26,000 mg/m3 [99] Municipal sludge 300-700 60 10 CO2 1 L/min Fixed bed H2S -620 mg/m3 -280 mg/m3 NO -120 mg/m3 CO -24,000 mg/m3 [99] Furfural residues 500 60 10 N2 60 mL/min Fixed bed CO 34.66-62.29% CO2 12.17-48.26% [ 100] Rice husk 400-800 N2 250 mL/min Screw reactor CO 20-25% CO2 8-27% CH4 2-6% PM 21.50/0 [ 52] Dairy manure 200-500 60 Fixed bed PM 12.5±2.7mg/g [42] Conifer chip 300-500 120 Fixed bed CO 28,000 ppm VOCs 634 ppm [101] 2.8. Catalysts The incorporation of catalysts in the pyrolysis process introduces a versatile avenue for tailoring product composition. While catalysts can enhance targeted product yields, various types of catalysts exhibit distinct functionalities, influencing the pyrolysis reactions and subsequent pollutant formation [79,102,103]. Zeolites and metal catalysts are commonly employed to enhance specific product yields during pyrolysis [ 104]. Zeolites act as solid acidic catalysts, promoting dehydration and cracking reactions [ 104]. Metal catalysts, such as nickel or iron, facilitate reforming reactions, particularly in the presence of steam, leading to an increased production of hydrogen -rich gases [105,106]. However, the use of metal catalysts may also contribute to Sustainability 2024, 16, 1169 11of30 the generation of NO), due to their role in nitrogen -containing compound reactions. Accord- ing to a previous study, the emission of NO„ was suppressed under catalytic conditions at elevated combustion temperatures, whereas it was encouraged at lower temperatures [ 107]. The impact of catalysts on NOx emission levels indicates how significantly the catalytic effect influences both char -N oxidation and the NO -char reaction in the combustion process of nitrogen -containing char. Basic or alkaline catalysts, such as alkali metals or alkaline earth metals, can influence the pyrolysis process by promoting deoxygenation reactions and reducing the oxygen content in the products [108]. While they enhance the yield of bio-oils and decrease oxygenated compounds, they may also contribute to the formation of carbonates and potentially emit CO2 during the pyrolysis process [108]. Earlier research indicated that alkali metals have the potential to stimulate the depolymerization and fragmentation of feedstock constituents. For example, Banks et al. explored the influence of potassium on the rapid pyrolysis of beech wood within a bubbling fluidized -bed reactor, revealing that the presence of potassium resulted in a decrease in bio-oil yield, accompanied by an increase in both noncondensable gases and char yield [109]. Compared to alkali metals, alkaline earth metals exhibit stronger Lewis acid characteristics, which enhances the formation of dehydration products [108]. In a study by Case et al., pine underwent pretreatment using different calcium compounds to generate bio-oil in a fluidized bed pyrolysis reactor. Calcium formate served as the pretreatment compound due to its role as a hydrogen donor upon heating. At temperatures exceeding 450 °C, pyrolysis of calcium formate leads to the breakdown of the formate salt, resulting in the formation of solid calcium carbonate alongside gaseous CO and H2 [ 1101. 3. Environmental and Health Impacts of Air Pollutants During pyrolysis for biochar production, several air pollutants can be emitted, de- pending on various factors as described above. Some of the major air pollutants typically emitted during pyrolysis include particulate matter, VOCs, PAHs, NOR, CO, and sulfur compounds. 3.1. Particulate Matter (PM) Pyrolysis stands as a promising technique for biochar production, yet it generates particulate matter (PM) emissions comprising carbonaceous particles, ash, and solid residues [42]. These diverse particles, varying in size and composition, wield significant implications for both air quality and human health [111]. Recognizing the environmental and health impacts of PM emissions from pyrolysis is pivotal in implementing effective mitigation strategies and fostering sustainable biochar production practices. The PM emissions from pyrolysis constitute a complex amalgamation of carbonaceous particles, ash, and solid residues derived from the feedstock [52]. The composition and size distribution of PM exhibit variability influenced by distinct feedstock properties, pyrolysis conditions, and reactor designs [42]. For instance, studies on different feedstocks such as wood, agricultural residues, or waste materials showcase the diverse composition and emission levels of PM, highlighting the nuanced impact of operational parameters on PM characteristics [421. These emissions significantly contribute to air pollution, influencing atmospheric visibility and contributing to smog formation [ 112]. PM can undergo long-range transport, affecting regional air quality and ecosystems [111]. For example, research demonstrates the role of PM in altering precipitation patterns, influencing cloud formation, and impacting environmental health and ecological systems [112,113]. Instances of PM's impact on atmo- spheric processes, especially in regions affected by biomass burning or industrial pyrolysis, underline its far-reaching consequences on ecosystems and human health [ 113,114]. The health risks associated with exposure to PM emissions from pyrolysis are sub- stantial. Fine and ultrafine particles possess the ability to penetrate the respiratory system deeply, leading to respiratory diseases, cardiovascular issues, and heightened mortality Sustainability 2024, 16,1169 12 of 30 rates [1111. Numerous studies establish the direct correlation between PM exposure and various adverse health outcomes [ 111,112,115], emphasizing the urgent need to mitigate PM emissions from pyrolysis operations. Efficient mitigation strategies demand technological advancements, enhanced reactor designs, and stringent emission control measures [115]. Research initiatives focusing on refining pyrolysis technologies, optimizing operational parameters, and implementing robust particle capture and filtration systems are pivotal. Developing cleaner pyrolysis methodologies and efficient filtration systems, as evidenced by studies exploring advanced filtration materials or modified reactor designs [75,78,116], illustrates the potential for reducing PM emissions and associated environmental and health impacts. 3.2. Volatile Organic Compounds (VOCs) Volatile organic compounds (VOCs) released during pyrolysis constitute a diverse array of organic chemicals that readily vaporize at ambient temperatures [1171. Benzene, toluene, xylene, and other VOCs contribute significantly to air pollution and entail potential health hazards [118]. VOCs discharged during pyrolysis actively partake in air pollution by interacting with nitrogen oxides and sunlight, culminating in the formation of ground -level ozone and secondary organic aerosols [119J. These compounds hold a critical role in fostering smog and instigating photochemical smog incidents [119]. Extensive research in urban and industrial locales affected by pyrolysis activities substantiates the correlation between VOC emissions and escalated concentrations of ground -level ozone, highlighting their contribution to regional air pollution [120-122]. Furthermore, VOCs are capable of long-range dispersion, contributing to the genesis of atmospheric particulate matter [117]. Research instances accentuate the involvement of VOCs in the creation of secondary organic aerosols, impacting atmospheric visibility and influencing climate dynamics [1191. Investigations were conducted in regions affected by biomass burning to elucidate how VOC emissions influence aerosol formation, thereby shaping atmospheric processes and impacting environmental health [ 123,124]. Exposure to VOCs emanating from pyrolysis poses substantial health risks to in- dividuals through inhalation or skin contact, leading to adverse health outcomes [ 118]. Epidemiological studies consistently associate VOC exposure with respiratory issues, exac- erbating asthma, bronchitis, and other pulmonary ailments [125]. For instance, research in proximity to pyrolysis facilities underscores elevated respiratory symptoms and heightened hospital admissions among exposed populations [126]. Moreover, several VOCs, such as benzene, ethylene oxide, and formaldehyde, are classified as carcinogens or suspected carcinogens by regulatory agencies [127]. A plethora of studies establish the nexus between occupational or chronic exposure to specific VOCs and heightened cancer risks [128-130]. This underscores the pressing need for stringent regulatory interventions and control measures to mitigate these health risks associated with VOC emissions. Continued research aimed at elucidating VOC composition, expo- sure levels, and their variable impacts across diverse pyrolysis settings is imperative in safeguarding environmental quality and human health. 3.3. Polycyclic Aromatic Hydrocarbons (PAHs) Polycyclic aromatic hydrocarbons (PAHs) are a cluster of organic compounds syn- thesized through incomplete combustion or pyrolysis of organic materials [131]. The US Environmental Protection Agency (EPA) has identified 16 PAHs as high -priority sub- stances due to their potential toxicity in both humans and other organisms, as well as their widespread presence and persistence in the environment. Notably recognized for their carcinogenic nature, these PAHs pose significant environmental and health hazards when released during biochar production via pyrolysis [52]. PAHs discharged during biochar production via pyrolysis contribute substantially to environmental pollution. These compounds traverse the environment, depositing in Sustainability 2024, 16, 1169 13 of 30 various matrices [ 132]. Research demonstrates the persistence of PAHs in soil and sedi- ment, posing risks to terrestrial and aquatic ecosystems [133]. Investigations conducted in pyrolysis -affected regions highlight correlations between PAH emissions and adverse impacts on soil microbial communities and aquatic organisms [134,135]. Furthermore, PAHs exhibit a propensity for bioaccumulation in food chains, posing threats to higher trophic-level organisms [136]. Studies exploring PAH accumulation in plants and aquatic species underscore their ability to traverse the food web, potentially disrupting ecosystem dynamics and imperiling biodiversity [ 137,138]. Human exposure to PAHs released during biochar production via pyrolysis presents substantial health risks [ 138]. Inhalation or dermal contact with PAHs leads to adverse health outcomes [ 139]. Epidemiological studies consistently associate PAH exposure with respiratory issues and cardiovascular diseases. Proximity to pyrolysis sites correlates with heightened incidences of respiratory symptoms and cardiovascular ailments among exposed populations [140-1431. Moreover, specific PAH compounds like benzo[a]pyrene (BaP) are identified as potent carcinogens by regulatory agencies [1441. Extensive research establishes a direct association between chronic PAH exposure and heightened cancer risks [145,146], underscoring the imperative for stringent regulatory measures and effective control strategies to mitigate the health hazards linked to PAH emissions. 3.4. Nitrogen Oxides (NOX) Nitrogen oxide (NOx) gases, composed of nitric oxide (NO) and nitrogen dioxide (NO2), are produced during pyrolysis processes due to high -temperature reactions involv- ing nitrogen -containing compounds [88]. The N content of the feedstock is a primary determinant of NOx formation. During pyrolysis, the breakdown of N -containing com- pounds releases N as molecular N and other reactive N species [33]. Studies have shown that rapid heating rates and short residence times may favor NOx formation [147-149]. At the same time, surface reactions involving N -containing compounds on the char surface, especially in the presence of reactive C radicals, can also contribute to NOx emissions [88]. NOx emissions contribute notably to environmental degradation, inducing smog formation that hampers air quality and visibility [150]. Additionally, these gases undergo atmospheric reactions, generating nitrogen -based aerosols that contribute to the formation of acid rain, harming soil, water bodies, and vegetation [151,152]. Studies in pyrolysis - affected regions demonstrate the direct link between NOx emissions and detrimental effects on ecosystems and biodiversity [33,88,153]. Furthermore, NOx gases play a role in the creation of secondary organic aerosols, exacerbating air quality issues and influencing atmospheric processes [1541. Investigations into NOx-related atmospheric transformations highlight their significance in atmospheric chemistry, impacting environmental health and ecological systems [1501. Anthropogenic NOx and VOCs are widely acknowledged as precursors that contribute to the formation of near -ground O3. Analyzing the interconnected patterns among the time series of O3 and its precursors alongside their temporal changes, nonlinear techniques like the empirical kinetic modeling approach (EKMA) and air quality models (AQM) offer insights into how O3 reacts to its precursors across various time scales [155]. Exposure to NOx emissions from pyrolysis poses significant health risks to human populations 1150]. Inhalation of these gases can trigger respiratory issues, worsen asthma, and cause irritation in the respiratory tract [156]. Consistent epidemiological studies link NOx exposure to increased occurrences of respiratory ailments and exacerbation of existing conditions [157]. Additionally, NOx exposure can heighten susceptibility to respiratory infections, lung diseases, and potentially cancer. It also contributes to the formation of the brownish haze observed in overcrowded regions and plays a role in the occurrence of acid rain [158]. Sustainability 2024, 16,1169 14 of 30 3.5. Carbon Monoxide (CO) and Carbon Dioxide (CO2) Carbon monoxide (CO) and carbon dioxide (CO2) are commonly produced as byprod- ucts of incomplete combustion or pyrolysis processes [152]. While CO is a colorless, odorless gas posing severe health risks when inhaled due to its interference with the blood- stream's oxygen -carrying capacity [1591, CO2 functions as a greenhouse gas, significantly influencing climate change [160]. During pyrolysis operations, especially those involving biomass or fossil fuel feed- stocks, significant emissions of CO can occur [161]. For instance, recent studies on biomass pyrolysis have highlighted the considerable release of CO due to incomplete combustion or inefficient pyrolysis conditions [12,161,162]. Similarly, when waste materials are burned or subjected to incomplete combustion during pyrolysis processes, elevated levels of CO2 emissions are observed [12,73,1521, impacting both local air quality and global climate dynamics. Robust control measures and the adoption of cleaner pyrolysis technologies are imper- ative to mitigate CO and CO2 emissions, addressing their detrimental impacts on both local air quality and global climate stability. For instance, ongoing research focuses on optimiz- ing pyrolysis conditions to minimize CO emissions [ 163] and developing carbon capture and storage techniques to mitigate CO2 release [164], aiming to promote environmentally sustainable pyrolysis practices. 3.6. Sulfur Compounds Sulfur compounds present in specific feedstocks have the potential to emit gases like hydrogen sulfide (H2S) during pyrolysis, significantly contributing to air pollution while often carrying a distinct and unpleasant odor [165,166]. In recent research, investigations into biomass pyrolysis involving sulfur -rich feed- stocks have highlighted the notable generation of hydrogen sulfide (H2S) during the process [165]. Additionally, studies focused on waste materials, such as tires or rubber - based compounds, have demonstrated the liberation of sulfur compounds, notably H2S, when subjected to pyrolysis conditions [ 166]. These findings emphasize the diverse sources of sulfur emissions in pyrolysis and their consequential impact on air quality. The emissions of sulfur compounds like H2S not only contribute to air pollution but also possess an identifiable odor that serves as a marker for environmental contamination. The odoriferous nature of these emissions signals their potential adverse effects on both environmental and human health. Prolonged exposure levels below 10 ppm have long been linked to odor aversion, along with ocular, nasal, respiratory, and neurological effects. Remarkably, exposure to even lower levels, under 0.03 ppm (30 ppb), has shown an increased incidence of neurological effects, while concentrations below 0.001 ppm (1 ppb) of H2S have been linked to ocular, nasal, and respiratory effects [167]. Efforts to curtail the release of sulfur -containing gases during pyrolysis are paramount to prevent air quality degradation. Ongoing research is focusing on refining techniques to handle sulfur -rich feedstocks more efficiently and innovating pyrolysis methodologies aimed at minimizing the liberation of sulfur compounds [ 168]. These advancements aim to mitigate the negative implications of sulfur emissions on air quality and their associated risks to human health, aligning with sustainable pyrolysis practices. 4. Current State of Regulatory Expectations and Compliance in Various Regions In the global context of waste management, diverse regulatory frameworks govern the disposal and treatment of solid waste. The current state of regulatory expectations and compliance in various regions regarding emissions from pyrolysis processes reflects an evolving landscape focused on mitigating environmental and health impacts. This section explores the regulatory landscapes of key regions, including the United States, the European Union, and the Asia —Pacific Region, shedding light on the distinct approaches and policies influencing waste management practices. Sustainability 2024, 16, 1169 15 of 30 • 4.1. United States In the United States, the regulatory landscape regarding emissions from industrial processes, including pyrolysis, is governed by a mix of federal and state -level regulations aimed at safeguarding air quality. The Environmental Protection Agency (EPA) plays a pivotal role in establishing and enforcing guidelines to limit air pollutants. The EPA's regulations encompass a wide array of air quality standards applicable to various industries, including those employing pyrolysis for biochar or biofuel production. The Clean Air Act, administered by the EPA, sets national ambient air quality standards (NAAQS) for specific pollutants like particulate matter (PM), nitrogen oxides (NO,t), sulfur dioxide (SO2), and volatile organic compounds (VOCs), which may be emitted during pyrolysis [ 169]. By setting these standards, the Clean Air Act provides a regulatory founda- tion for monitoring and controlling air pollution, ultimately contributing to the broader mission of environmental protection. Compliance with NAAQS requires industries to adhere to emission limits and implement control technologies [1701. States often adopt and enforce regulations that align with federal standards while addressing localized concerns. States may impose additional regulations or more stringent standards based on specific air quality challenges within their jurisdictions. For instance, California's stringent air quality standards often exceed federal regulations, influencing industries operating within the state [171]. In addition, California has implemented robust climate change mitigation measures aimed at improving air quality while also reaping public health benefits. These initiatives encompass advanced clean car standards, the promotion of renewable energy sources, a sustainable community strategy to curb subur- ban sprawl, the establishment of a low -carbon fuel standard, and initiatives focused on enhancing energy efficiency. Among these measures is a market -based mechanism known as the cap -and -trade program, permitting capped facilities to trade greenhouse gas (GHG) emissions allowances issued by the state. The "cap" sets a ceiling on total GHG emissions from covered sources, progressively decreasing over time to effectively reduce overall emissions [172]. Compliance with EPA regulations involves implementing emission control technolo- gies and practices to mitigate pollutants stemming from pyrolysis [173]. Continuous monitoring of emissions, regular reporting to regulatory authorities, and strict adherence to emission standards are essential components of compliance measures. Technologies such as tar scrubbers [174], catalytic converters [ 175], and advanced filtration systems [176] are deployed to reduce and control emissions of pollutants like PM and VOCs. For instance, the utilization of a catalytic converter containing palladium and platinum catalysts re- sulted in an approximately 20% reduction in PAH emissions [177]. In recent years, studies have emphasized the importance of compliance with EPA regulations in industries using pyrolysis [ 178,179]. Research efforts have demonstrated the efficacy of various emission control technologies in reducing pollutants emitted during pyrolysis processes [ 1801. For instance, studies on biomass pyrolysis have highlighted the effectiveness of advanced gas cleaning systems in lowering emissions of PM and VOCs, aligning with EPA emission standards [181,182]. 4.2. European Union The European Union (EU) has a robust regulatory framework in place to address emissions from industrial processes, including pyrolysis, ensuring stringent environmental standards. The European Environment Agency (EEA) plays a crucial role in monitoring and reporting on environmental issues across the EU. It supports the development and imple- mentation of policies aimed at reducing emissions and improving air quality [183]. The Industrial Emissions Directive (IED) sets comprehensive standards for controlling emissions from industrial activities, encompassing pyrolysis operations. It establishes emission limit values (ELVs) for various pollutants, including particulate matter, nitrogen oxides, sulfur dioxide, and volatile organic compounds, which may arise during pyroly- Sustainability 2024, 16, 1169 16 of 30 sis [184,185]. Compliance with ELVs is mandatory for industries and requires the adoption of best available techniques (BAT) to minimize emissions [1861. Recent studies conducted in the EU have focused on the implementation of BATs in pyrolysis facilities to comply with emission standards. For example, research has evaluated the effectiveness of advanced scrubbing and filtering technologies in reducing PM and other pollutant emissions from biomass pyrolysis [187]. Data from compliance reports highlight the successful implementation of these techniques [1881, showcasing reduced emissions and improved air quality outcomes in areas with pyrolysis operations. The Integrated Pollution Prevention and Control (IPPC) Directive is another regu- latory instrument within the EU that aims to prevent or reduce emissions from various industrial activities to achieve a high level of environmental protection. Pyrolysis facilities fall under this directive and must adhere to stringent emission standards and permit re- quirements [ 189]. Additionally, the EU develops BAT reference documents (BREFs) that provide guidance on best practices and techniques to minimize emissions from specific industrial sectors, including pyrolysis. These documents outline efficient methods and technologies to control and reduce pollutant discharges [1901. The IED and IPPC Directive are closely related and often used interchangeably. The IED aims to regulate and control industrial emissions, ensuring a high level of environ- mental protection. Whereas, the IPPC, initially introduced in 1996 and later replaced by the IED in 2010, focused on preventing and controlling pollution from various industrial activities. The IED builds upon the principles of the IPPC Directive but expands its scope and strengthens the regulatory framework. It addresses a broader range of industrial activities and introduces more stringent requirements for environmental performance. The goal of both directives is to achieve a high level of protection for the environment as a whole by controlling emissions and promoting the use of best available techniques. 4.3. Asia -Pacific Region The Asia -Pacific region has been increasingly proactive in addressing air quality concerns through evolving regulatory measures, especially concerning industrial emissions like those from pyrolysis processes. China has been focusing on stringent emission standards to curb air pollution. For instance, the country has implemented the "Air Pollution Prevention and Control Action Plan", setting specific targets for reducing air pollutants [1911. Regulations include emission standards for various industrial processes, emphasizing the reduction of PM, SO2, NO,r, and VOCs. As of August 2015, China had issued a comprehensive set of 1890 environmental protection standards, with the environmental quality standard serving as the primary component of the environmental standard system. This is complemented by supplementary standards for pollutant emissions and pollutant monitoring [1921. Continuous monitoring and stringent compliance measures are central to these initiatives [193]. A sustained national commitment to biochar production, utilizing about 33% of the sustainably available crop residues in China, holds the potential to cut China's GHG emissions significantly by approximately 54.27 Mt CO2-eq annually [18]. Assessing the future impact on GHG emissions under a "moderate" scenario that involves processing 73% of crop residues into biochar and biofuels using carbon -negative technologies from 2020 to 2030, followed by coordinated deployment with bioenergy with carbon capture and storage (BECCS) post -2030, could yield a cumulative reduction in GHG emissions of up to 8620 Mt CO2-eq by 2050 [18]. India, too, has been strengthening its regulatory framework to address air quality issues. The country has introduced the National Clean Air Programme (NCAP), aiming to reduce air pollution levels in various cities [ 194]. The program emphasizes the reduction of PM, SO2, NO,t, and other pollutants. Emission standards for industrial processes, including pyrolysis, are being revised and implemented to align with cleaner technologies and strict emission limits [ 194]. As an illustration, the Indian National Ambient Air Quality Standards stipulate that the annual average PM2.5 emissions from the power, industry, Sustainability 2024, 16,1169 17 of 30 and transportation sectors must be brought below 40 µg/m3 nationwide. This stringent benchmark is comparable to the 35 µg/m3 in the United States but considerably higher than China's 150 µg/m3 [195]. Addressing this challenge necessitates a coordinated approach involving urban, rural, and interstate responses. Recent data from air quality monitoring stations in major cities across the Asia -Pacific region indicate the severity of air pollution caused by industrial emissions. Studies on emissions from pyrolysis and related processes in this region have highlighted the need for stricter regulations to control pollutants [81,196]. Regulatory measures across the Asia —Pacific region aim to mitigate the adverse impacts of industrial emissions, including those from pyrolysis processes, on air quality and public health. The focus is on enforcing stringent emission standards, promoting cleaner technologies, and fostering compliance to combat air pollution effectively. 4.4. Global Trend Globally, there is a noticeable shift towards comprehensive regulatory frameworks that address emissions from pyrolysis and analogous processes, reflecting an increased emphasis on environmental sustainability and pollution control. Various regions are investing in research and development to advance technologies that minimize emissions during pyrolysis [70,78,164]. For example, the integration of catalytic converters, advanced filtration systems, and gas -cleaning technologies in pyrolysis plants has shown significant promise in reducing pollutant emissions [ 163,166,175,176]. These advancements highlight the trend toward adopting cleaner and more efficient pro- duction methods. Countries and regions worldwide are progressively setting stringent emission stan- dards for pyrolysis operations. These standards encompass limits for PM, SO2, NOR, VOCs, and other pollutants generated during pyrolysis. Compliance with these standards is being enforced through continuous monitoring, reporting, and inspection measures. Notably, considerable disparities persist in the regulations pertaining to pollutants, encompassing variations in the criteria for setting limits, average timeframes, and concentration thresholds among these standards [197]. A comparative study conducted to assess these standards revealed that Mongolia, Russia, and many Central and Eastern European countries uphold comparatively stringent norms. In contrast, Central and Southeast Asian countries tend to have relatively lenient standards. Additionally, there significant diversity in the stringency of standards across South Asia, West Asia, and the Middle East regions [197]. Global initiatives are also encouraging sustainable practices in pyrolysis and related industries. These practices include the utilization of biomass and waste materials as feedstocks [64,79], promoting circular economy principles to reduce waste [3,185], and emphasizing the importance of reducing environmental footprints [89,198]. As shown in Figure 3, there is a growing trend toward international collaboration and knowledge sharing among countries and regions to develop harmonized standards and best practices for emissions control in pyrolysis [199]. This collaboration fosters the exchange of information, technological innovations, and strategies aimed at achieving global environmental goals. Between 2017 and 2022, China emerged as the dominant contributor to pyrolysis research, accounting for 56% of the published articles in this field. The USA and India followed, contributing 12% and 5.4%, respectively [ 199]. China also led in collaborative articles, with 968 publications during the same period, representing around 35% of the total output. Pakistan (84%), Germany (83%), and the United Kingdom (82%) had the highest proportions of collaborative articles. This collaborative trend has persisted consistently. Sustainability 2024, 16,1169 18 of 30 Cuba Kazakhstan VOSviewer Tulsa Ronal. - c- ., - Stove* Aua • POrelkal.. Ecuador Estenla Algeria Ii eland Soutl4frica Litht nia Uganda Ethiopia Morocco Keoya Hungary Trey Indeesia Philioines nd , Kuwait Pakistan Egypt Jordan la Bi one' Bangladesh Figure 3. International collaboration in pyrolysis research: clustering of countries by relevance and geographical regions [199]. Blue cluster: most relevant countries; red cluster: European and Latin-American countries; green cluster: Asian countries; yellow cluster: Middle Eastern countries. Software: VOSviewer 1.5.5. The evolving global trend is directed toward establishing comprehensive regulations that not only set strict emission standards but also prioritize the adoption of cleaner technologies and sustainable practices. This shift signifies a concerted effort to reduce the environmental impact of industrial processes like pyrolysis on a global scale, ensuring a more sustainable future. 5. Strategies and Technologies Employed to Minimize Emissions during Pyrolysis The emissions of these pollutants can vary based on the feedstock characteristics, pyrolysis conditions (such as temperature, heating rate, and residence time), reactor design, and the gas atmosphere employed during the process. Proper control measures and optimization of pyrolysis conditions can help minimize the generation and release of these pollutants into the atmosphere, reducing their environmental impact. Strategies and technologies are integral to the ongoing efforts to mitigate emissions during the pyrolysis process, fostering cleaner production methods and ensuring sustainable practices in biochar production and similar industrial processes. 5.1. Improved Reactor Designs Fluidized -bed reactors suspend feedstock particles in an upward -flowing stream of gas, facilitating excellent heat transfer and uniform temperature distribution. Research on fluidized -bed reactors, like the work done by Pienihakkinen et al. (2021), has shown significant promise in achieving high biochar yields with minimized emissions [74]. The Sustainability 2024, 16,1169 19 of 30 dynamic nature of fluidized beds allows better control over reaction conditions, ensuring efficient pyrolysis with reduced environmental impact. In their design, the issues related to bed agglomeration in the BFB unit were resolved by introducing a high-speed rotating mixer within the reactor to disrupt the agglomerates [74]. Fixed -bed reactors are known for their simplicity and reliability. They enable precise control over residence time and temperature distribution, critical factors influencing py- rolysis reactions [64]. Recent studies, such as those conducted by Al -Salem (2019), have focused on optimizing fixed -bed reactor designs to achieve higher biochar quality and quantity while limiting emissions of VOCs and other pollutants [200]. It was reported that The gaseous product contained over 70% of C2 to C4 hydrocarbons, primarily due to the increased activity of the carbon -carbon (C -C) chain scission reaction [200]. Cylindrical rotating kilns facilitate continuous feedstock movement, ensuring uniform heat distribution and residence time [69]. Innovative rotary kiln designs, as explored by Hu et al. (2022), have demonstrated improved energy efficiency and reduced emissions by precisely controlling the pyrolysis process parameters [2011. Research from Sekar et al. (2022) has emphasized the critical role of reactor design in achieving optimal pyrolysis performance [63]. Their findings underscore how specific design modifications in these reactors can significantly influence temperature gradients, residence times, and ultimately, emission profiles during the pyrolysis process [201,202]. Furthermore, computational fluid dynamics (CFD) simulations, such as those con- ducted by Yang et al. (2021), aid in modeling and optimizing reactor designs [203]. These simulations provide valuable insights into fluid flow dynamics, temperature distribution, and residence time, guiding the development of more efficient and environmentally friendly pyrolysis systems [204]. 5.2. Gas Cleaning and Filtration Systems Electrostatic precipitators use electrostatic forces to remove particulate matter and pollutants from the gas stream [205]. They have been widely applied in pyrolysis setups to capture fine particles effectively [206]. For instance, Zhang et al. (2023) successfully integrated electrostatic precipitators into their pyrolysis facility, resulting in an impres- sive reduction in fine particle emissions of over 94%, as observed through long-term monitoring [207]. Cyclone separators leverage centrifugal force to separate particulates from the gas stream [208]. Recent advancements in cyclone separator design, such as those studied by Duan et al. (2020), have shown increased efficiency in capturing smaller particles generated during pyrolysis [209]. The findings demonstrate that the new cyclone design expedites the discharge of purified gas through the vortex finder. Additionally, it prolongs the movement distance and residence time of fine particles, eliminates short-circuit flows and the vertical vortex under the vortex finder, prevents interference between the upflow and downflow in the cylinder, and expands the quasi -free vortex area in the cone [209]. Baghouse filters use fabric bags to capture particles and pollutants from the gas stream. Shewartz et al. (2020) introduced innovative baghouse filters in their pyrolysis plant, showcasing an impressive reduction in emissions [37]. The combustion of pyrolysis products complied with EPA emissions standards for CO at 10.6 ppm, NOX at 16.8 ppm, and SO2 at 2.3 ppm [37]. Studies indicated a consistent removal efficiency of over 95% for fine particulates, significantly improving air quality standards [210,211 1. The advancements in gas cleaning and filtration systems underscore the commitment of the industry and research community to mitigate emissions effectively, ensuring envi- ronmentally friendly pyrolysis practices. Efforts to optimize and innovate these systems are crucial steps toward achieving cleaner emissions in pyrolysis operations. Sustainability 2024, 16, 1169 20 of 30 5.3. Catalytic Converters Catalytic converters play a pivotal role in reducing harmful emissions in pyrolysis processes. They are designed to accelerate the conversion of harmful compounds into less hazardous substances through catalytic reactions [73]. Jacob et al. (2022) implemented a novel catalytic converter in their pyrolysis setup, resulting in a significant reduction in NO„ emissions [212]. The findings demonstrated a reduction in NO„ concentrations by 55-60% compared to traditional systems [212]. The catalytic converter facilitated the conversion of NO,t into nitrogen and oxygen through selective catalytic reduction, thereby minimizing their release into the atmosphere [213]. Furthermore, recent research focuses on developing novel catalyst formulations tai- lored for pyrolysis conditions [214]. Preliminary results indicate that these advanced catalysts exhibit superior performance in reducing emissions of specific pollutants like PAHs and sulfur compounds [215,216], showcasing a potential breakthrough in emission control strategies for pyrolysis systems. 5.4. Controlled Pyrolysis Conditions Controlled pyrolysis conditions represent a fundamental strategy in emission reduc- tion during pyrolysis processes [217]. Optimization of key parameters such as temperature, heating rate, and residence time enables a more efficient process while mitigating harmful emissions [7,53,55]. Biochars usually exhibit reduced VOC levels as the pyrolysis temperature increases [218]. High-VOC biochar, releasing vapors and leachates, completely hindered the germination of cress seeds, indicating potential environmental risks [219]. It has been reported that postheating the softwood pellet biochar at 200 CC led to a 95% reduction in VOC concentrations [220]. Mixing high- and low-VOC biochars has shown promise in mitigating VOC toxicity [2201. Furthermore, pretreating VOC-rich biochar (e.g., through storage and rinsing) presents an alternative strategy to alleviate their phytotoxic effects [219]. Nevertheless, the most effective approach to prevent VOC contamination in biochar remains conducting pyrolysis in controlled conditions within well -designed pyrolysis units. 5.5. Renewable Energy Integration Renewable energy integration into pyrolysis processes presents a significant opportu- nity to mitigate environmental impact and reduce reliance on nonrenewable resources. The incorporation of solar, wind, or other renewable energy sources offers promising avenues for cleaner and more sustainable pyrolysis operations. Li et al. (2023) implemented a solar pyrolysis setup where solar thermal energy was used to pyrolyze feedstock [8]. This approach significantly reduced the energy demand from conventional sources, thereby diminishing the carbon footprint of the process [8]. Hou et al. (2022) revealed in their comparative study that the solar -powered process not only reduced overall energy consumption and carbon emissions but also yielded biochar with equivalent efficacy in enriching and stabilizing heavy metals in Chinese medicine residues when compared to traditional heating methods [221]. In a study by Li et al. (2019), they introduced the concept of a negative emission hybrid renewable energy system and explored its design for a self-sufficient rural island striving for net -zero emissions [222]. For an island covering 22.05 km2 and housing 10,881 individ- uals, the optimal system presented a substantial negative emission capacity, potentially sequestering 2795 kg of CO2-equivalent daily, along with an estimated daily profit of 455 US dollars [222]. 5.6. Realtime Monitoring and Control Systems Realtime monitoring and control systems integrated into pyrolysis operations are integral for ensuring compliance with emission standards and optimizing processes [223]. These systems, equipped with advanced sensors and analyzers, provide immediate in- Sustainability 2024, 16,1169 21of30 sights into emission levels, enabling swift corrective actions and aiding in regulatory compliance [223]. Gas sensors are capable of detecting the compositions of various gases and vapors generated during pyrolysis. Utilizing the sensing data from these gas products allows for the adjustment and optimization of operating parameters within the pyrolysis and upgrad- ing processes, thereby enhancing pyrolysis efficiency and the quality of synthetic energy products [224]. Many available gas sensors exhibit robustness, withstanding temperatures up to 1000 DC, offering advantages such as good selectivity and long-term stability [223]. These sensors prove highly useful for monitoring and optimizing pyrolysis and upgrading processes. Analytical feedback control plays a pivotal role in refining pyrolysis efficiency and curbing emissions. Aboughaly et al. (2020) recently introduced a closed -loop control system tailored for pyrolysis reactors [225]. This intelligent feedback mechanism utilized realtime feedback signals from three online gas analyzers —CO, CO2, and NOR [225]. The controller's output signal governed the radio frequency thermal plasma torch current, ensuring immediate temperature regulation. By merging realtime analytical data with au- tomated control, this system could swiftly identify and adjust deviations in crucial process parameters like temperature and heating rates, thus optimizing pyrolysis conditions and minimizing emissions [225]. This innovative setup was able to ensure precise tempera- ture profiles for both pyrolysis and gasification, elevate end -product yield, and effectively eliminate undesired byproducts like tar and char [225]. 6. Conclusions The process of pyrolysis, while effective in reducing emissions, generates a diverse range of pollutants influenced by various factors. Feedstock composition, such as forestry waste or plastics, yields different pollutant profiles. For instance, waste tires produce concerns due to the emergence of PAHs, sulfur -based, and nitrogen -based pollutants during pyrolysis. Moreover, factors like pyrolysis temperature, residence time, healing rate, reactor design, gas atmosphere, and catalysts all significantly impact the types and quantities of pollutants generated. These variables can influence emissions of PM, NOR, VOCs, CO, CO2, and other hazardous compounds, necessitating careful monitoring and process optimization to minimize environmental risks while producing biofuels and biochar. The discourse on emissions from pyrolysis processes reflects a dynamic landscape underscored by both challenges and innovative strategies. From examining the diverse pollutants generated to delving into regional regulatory expectations and compliance measures in the United States, European Union, Asia -Pacific, and global trends, it is evident that a concerted global effort is underway to mitigate environmental impacts. Strategies including improved reactor designs, advanced gas -cleaning systems, cat- alytic converters, biochar activation, and controlled pyrolysis conditions represent sub- stantial strides in emission reduction. The integration of renewable energy sources and realtime monitoring systems further highlights the commitment to sustainable practices in pyrolysis. With ongoing research and innovation, the synergistic approach between regula- tory frameworks, technological advancements, and sustainable practices holds promise in fostering environmentally responsible pyrolysis processes for a greener future. Funding: This research received no external funding. Institutional Review Board Statement: Not applicable. Informed Consent Statement: Not applicable. Data Availability Statement: Data is contained within the article. Conflicts of Interest: The author declares no conflicts of interest. Sustainability 2024, 16,1169 22 of 30 References 1. Oakleaf, J.R.; Kennedy, C.M.; Baruch-Mordo, S.; Gerber, J.S.; West, P.C.; Johnson, J.A.; Kiesecker, J. Mapping global development potential for renewable energy, fossil fuels, mining and agriculture sectors. Sci. Data 2019, 6,101. [CrossRef] [PubMed] 2. Vo, D.H. 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MDPI and/or the editor(s) disclaim responsibility for any injury to people or property resulting from any ideas, methods, instructions or products referred to in the content. Jessica Reid From: F. i0: Subject: Diana Aungst Monday, October 20, 2025 7:53 PM Esther Gesick; Jessica Reid Fw: Bio char file Hi, Please add this email to the Bio Char file. USR24-0019. Thanks, v .1136i,,..;•-r, COUNTY, CO Diana Aungst, AICP I CFM Principal Planner Department of Planning Services Desk: 970-400-3524 P.O. Box 758, 1402 N. 17th Avenue, Greeley, CO 80632 >in Our Team IMPORTANT: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Jeri Yarbrough <yarbroughacres@icloud.com> Sent: Monday, October 20, 2025 5:55:34 PM To: Diana Aungst <daungst@weld.gov> Subject: Bio char file This Message Is From an External Sender This email was sent by someone outside Weld County Government. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi Diana Was wondering if you could add this photos. The Sacks crawfords and Tony hale wanted them added to show how close they are to their lake and horse pen and the view bio char will take away from Tony place . Thank you 1 �} -D �� ,ail l ��IL� � I.�..�i. {1�-�a. fllit- -1 `L r_. ,. � (r li {:fit Y III r X11 .'{'..�1 '.rD�Ai 1 ; y;•;rra : 17T•r'+ .+�4_ Il! }' ir � n • .tfllwllT ' •'ll' Qt 1 fI r •• • y �� r`• \`'�. erl. I `li,I -'1 '-- _ - .. hi��►..�P _{k ll� f • - s] II`. • r.. ;:inii Y IL .d • _II • }' .•� trilkagiet .le.'Q r , t 7� pt... •, 4 ♦ • • • I -♦ 11r .s %is A. 1 • f. - •, •.•.•--i. .• • • 4 t • • • _ • ♦ • • •. ♦ x •. .4.'4 • '• 1'.;1• • tee r• ♦. • - _ A. I. _ r • • N. A - ' ` t t is • Or; • ••••• •10, ✓ •1. or • I - �' l• • • • • • a • ♦ • at • S. • • • •• _ 1. • � ... S t• • I• a • l •. • • a - f R • r• 1r Jr, s • a ' ♦ S. ' f 1• tf St % - - I J,a J• • {� • Alr- la _A. _ •' I r t r - P. • •• •` • ..• . • •• a - _ ^�•- - • • • a • %, ♦ 1 A4 Ca P _ I s. • + • l - - .00 • sit. • .. • •.. t • • a• 1 lti• • s • • • . • s • Page 1 of 6 EXHIBIT I Case No: Name: Proposed Project: Planner: November 3, 2025 Cts Tes_4,7 Environmental and. Animal Defense r (720) 722 - 0336 business@eadefense.org U) I www.eadefense.org PUBLIC COMMENT & OBJECTION USR24-0019 NGL Water Solutions DJ LLC USR for uses similar to an organic composting (Biochar Processing) in the (A) Agricultural Zone District Diana Aungst Dear County Commissioners, Environmental and Animal Defense is a Colorado -based nonprofit focused on environmental and animal protection. We believe all communities have a right to a healthy environment and work to maintain and improve the places that are homes to our communities and wildlife. Here, we have drafted a comment on behalf of Jeri Yarbrough, who opposes the proposed project to issue a Use by Special Review to NGL Water Solutions DJ LLC for uses similar to an organic composting (Biochar Processing) in the (A) Agricultural Zone District adjacent to her property. Additional comments submitted October 9, 2024, and October 7, 2025, are prior submissions to the record. Weld County Board of County Commissioners should not approve the proposed project due to its violations of municipal law. Rather than re -iterate information already provided on record, we take this opportunity to correct the record made by the applicant at the October 7, 2025, meeting as well as provide additional information about Ms. Yarbrough's property. As detailed in prior written comment and by Ms. Yarbrough during her verbal comment, she owns parcel 147128100005 at 14512 COUNTY ROAD 6 FORT LUPTON, CO 806218216. At the October 7, 2025, meeting, applicant incorrectly stated that Ms. Yarbrough should not be considered under the right -to -farm ordinances because she leases land for crops from NGL; this is not true. She owns her property land and utilizes it for agricultural purposes, including raising and 501 S. Cherry Street, Suite 1100 Denver, CO 80246 Maxar Weld County Government Powered by Esri Page 2 of 6 Environmental and Animal Defense managing livestock and engaging in flood irrigation to grow alfalfa hay. Her parcel and ownership rights are reflected in the below image taken from the Weld County Property Portal. Account Owner Name Address R8984068 YARBROUGH JERI E 14512 COUNTY ROAD 6 FORT LUPTON, CO 806218216 (Close Section A i J • . • b.. t . ‘6.1.,'• . . a . •; .o.+ es Document History Building Information Valuation Information Tax Authorities Notice of Valuation (NOV/NOD) Photo Sketch • + • . Q 3 a` Map '4n Get additional detail with the Map Search. . + e• ,egsils V; . n Y V V A Print Open/Close All Sections T The historic flood irrigation ditch is located on the east end of her property, and floods to the west on lower elevation before running down her driveway and under road 6 to the Kalooga Lake. The water will sometimes pool on the northwest corner of her driveway although there is a culvert there that takes the water underneath it and feeds it into the lake. Ms. Yarbrough owns 8 paired shares of the Burlington / Page 6 of 6 Environmental and Animal Defense Star � .^`-�--- '� �"�YI � rte � �3w'"��;-�_I� s `&i�\,w�t/�iy�-� i� i5a r`r�:--t"r`°�",f1c.Y i"`c'�3szr:._3y`u":'2:7iY- q a,.Zw. , w+=c:.M1.• _ vs .� i through industrialized production of biochar from woody materials. CDPHE has clearly stated that this new facility will require a nearly identical permit to the Berthoud facility. The application for this facility is based on emissions generated from the Berthoud facility kilns and generators which Biochar Now claims, in its permit application, is a legitimate comparison for its facility here. It is an inescapable fact that this facility while be an industrialized burn facility to produce biochar that will generate harmful air pollution regulated by the Clean Air Act. While Biochar Now appears to be spreading the footprint of that air pollution to two locations for the purpose of avoiding a Title V major source permit under the Clean Air Act, the issue for the county is that this is an industrialized facility generating air pollution that is inconsistent with the surrounding uses, agricultural heritage, and ensures adequate protection of public health and safety in Weld County Ordinance 23-2-220(a)(3), (a)(6) and (a)(7). Planning Commissioner Biwer correctly noted the project's legal deficiencies to the project and voted in opposition. As Commissioner Biwer correctly stated, this project violates the Planning Commission's duties under Weld County Ordinance 23-2-220(a)(3) and (a)(7). The Planning Commission must only recommend a project for approval when, among other conditions, it finds that the "USES which would be permitted will be compatible with the existing surrounding land USES" and "that there is adequate provision for the protection of health, safety and welfare of the inhabitants of the NEIGHBORHOOD and the COUNTY." These violations as described by Commissioner Biwer are in addition to those raised previously by prior public comment. Notably, as Commissioner Biwer stated, while it may be true that the byproduct of this facility's operations is product sometimes used in agricultural practices, the facility that makes this product is an industrial one. Therefore, it should not be permitted at this location. Thank you for your consideration. Sincerely, Alexa McKay, Esq. Jeremy McKay, Esq. Environmental and Animal Defense 501 S. Cherry St. Suite 1100 Denver, CO 80246 720-722-0336 amckay@eadefense.org _rn 3kaytheadefense. orb Page 5 of 6 Environmental and Animal Defense 5. failure to submit Air Pollution Emission Notices for the diesel engines prior to installing and operating them; 6. failed to complete required emissions testing until nearly six months after the deadline; 7. failed to submit an "operation and maintenance plan and record keeping format demonstrating how Biochar will maintain compliance with the requirements of the permit" on time; 8. failed to "mark the permit number on the subject equipment for ease of identification;" 9. failure to submit information on the "manufacturer, model number, and serial number (equipment information) of the subject equipment;" and 10. failed to process "clean" wood and instead burned "processed wood, pressed wood, and construction pallets." In 2020, CDPHE issued a Compliance Advisory notice of enforcement of the Colorado Air Pollution Prevention and Control Act against Biochar's Berthoud facility. At that time, CDPHE found that Biochar: 1. failed to operate its emissions control technology to "ensure the permitted kiln emissions factors for NOx and CO are achieved, and therefore, Biochar has failed to operate the afterburners to ensure satisfactory performance" in violation of its permit; 2. failed to "demonstrate continued compliance with the annual kiln NOx and CO emission limits" in violation of its permit. In 2023, CDPHE issued a settlement agreement related to violations at the Berthoud facility for violations concerning two diesel generators. CDHPE found that Biochar: 1. failed to limit NOx, VOC, and CO emissions based on a rolling twelve-month total CDPHE also ordered that Biochar would need to limit the operation of the diesel generators based upon the emissions violations, and that Biochar pay a penalty. 1 As pointed out by our previous comments, Biochar Now has pending Clean Air Act permits before the Colorado Department of Public Health and Environment: 1) a Title V permit and 2) a synthetic minor source permit. Biochar Now can only obtain a synthetic minor permit by limiting its emissions through one mechanism, using fewer kilns for fewer hours. Biochar Now's Berthoud facility generates air pollution ' The applicant asks for the community's trust in that this proposed site will run according to law — but its willingness to intentionally mischaracterize the problems at its other facility raises serious concerns about the reliability of Biochar Now's statements. b �Q..'ar.. a "VP • y.•' • • .i t • i I a • • v • C•� b.� •• A: el 1,-Z. F y• �, is • e...a a. Y• • •J • ;CI • h.,. • • m et e Page 4 of 6 Environmental and Animal Defense • ,a . 4s . L •.. dt' r IL • x•,'s ro '9 re. • ex • •°vr'.� f • �s• • am• c . .; • a'.° . , •e •- I44 • • tier 6 p•. •!. • • i' .• :.ri, •.t. • a_c °' se. ''. . a - Y• ➢fJ . + ▪ +. a •a. a • 0.1a • • a: • • • 'I - b .`b vro on 'a••.$`'Q+' ..0•d c••° v " a • e A t e • •.,v� .• J . a• b v 9.• 10. • A. o 4r.. w • .a P w ---1';•••• • . �'- al. ,• " • �• Jy •,tip"✓. ,. • • a•'' •• -• •.y .r• . ,t. w�. f• ry°"1 I •mn Cr• •1 I ! • C. • a • i " k° • 11 q•r� 7....X.: • s, a •¢ A; i_ C . 'i - ..'-� :d. �' _ .S Furthermore, we would like to correct the applicant's response to comment regarding its Berthoud violations. While the violations notices speak for themselves, they are not simply "paperwork violations" as the applicant would lead the Board to believe. In 2017, CDPHE issued a Compliance Advisory notice of enforcement of the Colorado Air Pollution Prevention and Control Act against Biochar's Berthoud facility. At that time, CDPHE found that Biochar: 1. exceeded the "PM10 and PM2.5 annual emissions limits" for one of its point sources • 2. failed to comply with Reasonably Available Control Technology requirements under the Clean Air Act for the ozone non -attainment area the facility is located in; 3. "installed and operated unpermitted diesel engines at the Facility;" 4. failure to ensure that its diesel generator meets certain specifications; • a d a•e. Page 3 of 6 Environmental and Animal Defense Wellington Brighton lateral ditch water. A photo taken by Ms. Yarbrough is provided below for reference. When the air and particulate matter pollutants settle on Ms. Yarbrough's land, they have the potential not only to harm her agricultural practices but can be absorbed and transported during flood irrigation practices and rainfall, spreading throughout her property and funneling into the Kalooga Lake. These wildlife species at the Kalooga Lake include bald eagles and pelicans, which are protected under the Migratory Bird Treaty Act, as well as other associated local waterfowl and wildlife. Additionally, Ms. Yarbrough wants to highlight the proximity that this facility will be in relation to her home. The following image was taken by Ms. Yarbrough with a view towards the proposed facility to the north. • nJ::: iY�.�4.� �.—��fv�M+"s4`: iYU:lT.1TlI-a '.,"r. EXHIBIT JACKSC)NJ LAW s t$tV4a OD 19 NOVEMBER 4, 2025 VIA EMAIL TO: Board of County Commissioners Weld County c/o Diana Aungst, AICP I CFM Principal Planner, Department of Planning Services daungst(itweld.gov; egesick@weld.gov Dear BOCC, My name is Dennis Jackson and I am a Colorado attorney. I submit this attached brief on behalf of the adjacent property owners, and particularly Mr. Tony Hale (collectively the "Impacted Property Owners"), in opposition to USR24-0019, an application submitted by NGL Water Solutions DJ, LLC via Biochar Now LLC seeking a special use permit allowing it to run a biochar production plant south of and adjacent to CR 6 and about 0.25 miles west of CR 31, Weld County, Colorado. Sincerely, 'Dennis R. Jackson Jackson Law 5200 DTC Parkway, Suite #200 Greenwood Village, Colorado 80111 303-558-5232 dennis@jaxlawllc.com II Dennis R. Jackson, Attorney at Law 15200 DTC Parkway, Suite 200 I Greenwood Village, Colorado 801111 (303) 558-5232 I dennis@jaxlawilc.com II 1 I. THE INTRODUCTION OF A PRODUCTION FACILITY, REGISTERED WITH THE CDPHE AS AN INDUSTRIAL RECYCLING PLANT, INTO A WELD COUNTY DISTRICT ZONED AGRICULTURAL, DOES NOT MEET THE STANDARDS AND CONDITIONS SET FORTH IN W.C.C. SECTION 23-2-220(B)(1-7), AND ACCORDINGLY USR24-0019 MUST BE DENIED. A. BACKGROUND Biochar Now LLC ("Biochar Now") produces biochar for commercial use in water filtration, carbon capture, and as a soil amendment. It's production process is known as pyrolysis. Biochar Now contracts locally to divert waste wood, specifically wooden pallets, from landfills, for delivery to its production facilities. The waste wood, as delivered is not compostable, is dried, shredded, and loaded into kilns. The kilns are heated up to or in excess of nine -hundred (900) degrees Fahrenheit causing a chemical reaction whereby the shredded waste wood is reduced to biochar. The biochar produced on proposed site will be hauled to another Biochar Now facility in Berthoud, Colorado where it will be pelleted and packaged for sale and use. B. PROCEDURE & LAW Weld County Code, Article II - Procedures and Permits, Section 23-2-220(B) states the Board of County Commissioners shall hold a public hearing to consider the application and to take final action thereon. In making a decision on the proposed Use by Special Review, the Board of County Commissioners shall consider the recommendation of the Planning Commission, and from the facts presented at the public hearing and the information contained in the official record which includes the Department of Planning Services case file, the Board of County Commissioners shall approve the request for the Special Review Permit only if it finds that the applicant has met the standards or conditions of this Subsection B and Sections 23-2- 240 and 23-2-250 of this Division. The applicant has the burden of proof to show that the standards and conditions of this Subsection B and Sections 23-2-240 and 23-2-250 of this Division are met. The applicant shall demonstrate: 1. That the proposal is consistent with in Chapter 22 and any other applicable code provisions or ordinances in effect. 2. That the proposal is consistent with the intent of the district in which the USE is located. 3. That the USES which would be permitted will be compatible with the existing surrounding land USES. 1 4. That the USES which would be permitted will be compatible with the future DEVELOPMENT of the surrounding area as permitted by the existing zone and with future DEVELOPMENT as projected by Chapter 22 of this Code and any other applicable code provisions or ordinances in effect, or the adopted MASTER PLANS of affected municipalities. 5. That the application complies with Articles V and XI of this Chapter if the proposal is located within any Overlay District Areas or a Special Flood Hazard Area identified by maps officially adopted by the County. 6. That if the USE is proposed to be located in the A (Agricultural) Zone District, the applicant has demonstrated a diligent effort has been made to conserve PRIME FARMLAND in the locational decision for the proposed use. 7. That there is adequate provision for the protection of the health, safety and welfare of the inhabitants of the NEIGHBORHOOD and the COUNTY. C. ARGUMENT The following is a comprehensive examination of the seven (7) factors to be considered by the Board of County Commissioners in determining whether the applicant has met the standards or conditions of this Subsection B (the "7 factors"). Ms. Angela Snyder appeared before the Planning Commission on October 7, 2025, on behalf Ms. Diana Aungst, Principal Planner, and presented her recommendation. It's my understanding that presentation was based upon a review of Record USR24-0019 and involved the applicant. Any cite to Ms. Snyder is a reference to her public presentation on October 7th to the Planning Commission whereby she walked through her analysis of the 7 factors and in the end recommended the Planning Commission move Biochar Now's application on to the Board of County Commissioners for consideration. 1. Section 23-2-220(B)(1-7): a. B. 1- PROPOSAL is consistent with the adopted PLAN. The site for the proposed USE is situated in a ZONE A (AGRICULTURAL) DISTRICT. Biochar Now's application was submitted pursuant to § 23-3-40, Uses by Special Review. Ms. Snyder suggested the proposed USE is Consistent with the Plan because the USE respects agricultural heritage because biochar is used as an agricultural soil amendment; and the mitigation proposed will help to harmonize the USE with the surrounding uses. 2 WELD COUNTY GOVERNMENT hepailrnenl ciF PliiiininyServices. , 1, Consistent with Comprehensive Plan- / -Section 22-2-10 A "Respecting Our Agricultural Heritage 'J Biochar is used as an agricultural soil amendment ✓ Section 22-2-10 B 'Respecting Private Property Rights " , Section 22-2-30 C "Harmonize development with surrounding land uses " _Mitigation is proposed Record USR24-0019, PowerPoint Presentation pdf Slide 12 AGRICULTURAL HERITAGE Weld County,Charter and County Code, § 22-2-10(A, B, E, and F, respectfully) reads Historically, Weld County is one (1) of the economically largest agricultural producing counties -in the nation-, regularly the top producer of traditional crops 'IQ e, when 'excluding citrus- or nut -producing counties) The agricultural sector is an important element of -the overall County economy The diversity of agriculture - in the -County , range `s from crops, rangelands' and feedlots to other-form`s of agribusiness, ago- - tourism, agri-tainment and hobby farms „ - - .. t f fY The County recognizes the importance of maintaining large contiguous parcels of productive agricultural lands in nonurbanizing areas of the County to support the" economies of scale required for large agricultural operations, In keeping with the intent of the preamble of the Weld County Charter "to provide uncomplicated, unburdensome government, responsive to the people," development in rural areas provides ;opportunities for land divisions that are exempt from rr -subdivision regulations and allows land use by small agricultural operations and home businesses These lots retain -the agricultural zoning designation and support.a high -quality 'rural character, while maintaining "freedom from cumbersome regulations , Land use policies should support a high -quality rural character which respects the agricultural heritage and traditional agricultural land uses of the County, as agricultural lands -are converted to other uses (excluding urban development) Rural character in the County includes those uses which provide rural lifestyles, rural -based economies and opportunities to both >live and 'work in rural areas The natural landscape and vegetation predominate over the built environment Agricultural land uses and development provide the visual landscapes traditionally found in rural areas and communities 3 And In part, the Weld County Right to Farm Statement (§ 22-2-20) reads: Weld County is one of the most productive agricultural counties in the United States, typically ranking in the top ten counties in the country in total market value of agricultural products sold. The rural areas of Weld County maybe open and spacious, but they are intensively used for agriculture. Persons moving into a rural area must recognize and accept there are drawbacks, including conflicts with long-standing agricultural practices and a lower level of services than in town. Along with the drawbacks come the incentives which attract urban dwellers to relocate to rural areas: open views, spaciousness, wildlife, lack of city noise and congestion, and the rural atmosphere and way of life. Without neighboring farms, those features which attract urban dwellers to rural Weld County would quickly be gone forever. Agricultural users of the land should not be expected to change their long-established agricultural practices to accommodate the intrusions of urban users into a rural area (emphasis added). The Right to Farm Statement clearly explains that persons moving into rural Weld County MUST recognize and accept conflict with long-standing agricultural practices. Here there is a conflict between long-standing agricultural practices i.e., the agricultural heritage and the proposed USE. Ms. Snyder and the applicant rely on the use of the end product to meet this first factor. Both repeat that the biochar produced may be used as an agricultural soil amendment, thus the USE is consistent with the Plan. However, it's the production process, which includes the required infrastructure and necessary evils that comes with the production process that is the USE, not one of many uses of the product produced. What is Pyrolysis? ORGANIC BIOMASS DRYING INPUT (<a PROCESS PYROLYSIS REACTOR is C) °RINMING OUTPUTS t _ BK) Oft BIOCHAR atoc as MEAT a E% ECTRIC/T1► Pyrolysis is a thermal decomposition process in which organic materials such as wood chips, crop residues, manure, and other forms of biomass are heated at high temperatures (typically between 300°C and 700°C) in an environment that severely restricts oxygen. Under these unique conditions, instead of combusting into ash, biomass is 4 transformed into three primary products: Biochar (a carbon -rich solid), Bio-oil (a liquid that can be refined into fuel or chemical products), Syngas (a mixture of gases used for energy production). Pyrolysis: Key to Biochar Production - BiocharDaily. I don't pretend to be a pyrolysis expert. The Chart and description above is general and may not be indicative of the "patented technology" claimed to be used by Biochar Now. That said, PYROLYSIS is an operation. Admittedly it requires heavy machinery including but not limited to mobile shredders and other heavy equipment. It requires many people. And significant labor. The Site Plan (see insert below, Record USR24-0019, PowerPoint Presentation.pdf Slide 45) submitted by Biochar Now includes a 1500 square foot office building. Biochar Now stated candidly it will have as many as eighteen (18) employees on - site at any given time. It admits it will have contractors on site as well. Biochar Now intends to build or install forty (40) large kilns on -site. Large commercial trucks are contracted and/or employed to deliver waste wood and haul biochar away, often. Biochar Now has dedicated acres on -site for large fuel tanks e.g., an eighteen hundred (1800) gallon propane tank and stockpiling small mountains of waste wood. And this production site will operate 24 hours a day, seven days a week, three hundred sixty-five days a year. WELD COUNTY GOVERNMENT Department of Planning Services ••••• ISMS 11 •a-' awt .r+.ry •�Maar, .ii 1Rai r [1.11 t/ 114141: - 'at essellumm ./ r • M' r Raw material stocRpi (es �2 i ''tall (rail tie slash, pallets crates, e t. .. 4.Y ICt NGL injection wells M trigit I/M. M�y nsn —" a / AMM wwA smart= .n..,..r._ tn141re IVA IPa cktiinnoiciti .tilt Welt a nfl a .+w. - agrte. .Yt... IMPROVEMENT LIST ►urilk AP rr1►LE4.1:040K!a ate ER 11 x ' .N J YMINFi; RS KU;) .9_14 R &TAM It SKI CUR 'NOW CONTRa WOW Waft PAIR CFIRe111Y.JH'All1 R twit CIRN; t 00 "a i& EMPTY sans 10 IS W 114 UI IIAI:M SKI CAI ON [t5E1 fit 1NIK JAY * CO,40WV 14 4:01 at al PRC.PNIf we a SfCJ01cmv EMERGENCY DIESEL c ENE#t*TC:R5 .14.440:T StOC•RP'tE 6l.y1GNf1 PAD . 1;l KLM'N Casa $ cm* TER 2? IN NEN;Hi KI YAlf •TvM P _"Wit1fl d t/lKEW P :61:. • 0.'4, 4. t .f•KIR SKU WI94'Fjl N� O01MMa1St 6 Wit DCI I rota JO mew; w1 ►"IR'eat Pat TS Mgt rls1:1111GnlrT'icgtsiCS :UI orations yard With 10 active and"storage active kilns. • IC Ara(' ti• An around the clock production facility requiring heavy machinery and equipment, an office building for more than fifteen (15) employees to work, tens of kilns burning in excess of 900 degrees Fahrenheit, large commercial trucks coming and going daily, and stockpiles twenty (20) feet high is not a USE indicative of the agricultural heritage of this area. 5 Moreover, in its USR application, Biochar relates its processing "similar to an organic composting." Alternatively, Ms. Snyder explained Biochar Now will be registered as an "Industrial Recycling Facility" with the Colorado Department of Public Health & Environment ("CDPHE"). The Cambridge Dictionary defines "processing" as the act of preparing, changing, or treating food or natural substances as a part of an industrial operation. The Cambridge Dictionary defines "industrial" as in or related to industry, or having a lot of industry and factories, etc. and "industry" as the companies and activities involved in the process of producing goods for sale, especially in a factory or special area. "Producing" is defined as to make something or bring something into existence, with examples being e.g., to build, to construct, to manufacture. To manufacture, according to the Cambridge Dictionary means: to produce goods in large numbers, usually in a factory using machines. In other words, in its registered industrial recycling facility Biochar Now intends to manufacture and/or produce goods (biochar) in large numbers (by the truckload), in a factory (or plant), using machines. Regardless of whether the end or a by-product may be used agriculturally, the "processing" requires a factory using machines. And for this reason alone the proposed USE fails to qualify as AGRICULTURAL. b. B. 2- PROPOSAL is consistent with the ZONING INTENT. Ms. Snyder suggested the proposed USE is Consistent with Zoning because § 23-3- 40(W) permits USES similar to the USES listed above as Uses by Special Review as long as the USE complies with the general intent of the A (Agricultural) Zone District and here ORGANIC FERTILIZER PRODUCTION/COMPOSTING FACILITITES special permits are requestable. WELD COUNTY GOVERNMENT Deportment of Planning Services 2. Consistent with Zoning The A (Agricultural) Zone District is intended to provide areas for the conduct of agricultural activities and activities related to agriculture and agricultural production, and for areas for natural resource extraction and energy development, without the interference of other, incompatible land uses. 23-3-40.W. ORGANIC FERTILIZER PRODUCTION/COMPOSTING FACILITIES. Record USR24-0019, PowerPoint Presentation.pdf Slide 14. 6 ORGANIC FERTILIZER PRODUCTION/COMPOSTING FACILITITES: Composting is a use that requires a special use review and permit. Weld County Charter and County Code defines an "ORGANIC FERTILIZER PRODUCTION/COMPOSTING FACILITY" as Facilities where animal manure and other biodegradable materials are brought from other properties for composting. Biochar Now's plan is to divert waste wood intended for landfills, to this proposed production facility, where it dries and shreds the wood before loading it into large, hot kilns whereby patented technology causes a chemical reaction that produces biochar. If it was compostable there would be no harm for the waste wood to go to a landfill. Pyrolysis is required for the waste wood to become compostable. Moreover, this proposed facility will not be pelleting and packaging the final biodegradable product. Biochar Now explained to the Planning Commission on October 7th the product produced at this site will be "big chunks of black wood, as big as your arm." These large chunks must be hauled to the company's other facility in Berthoud, Colorado to be pelleted to be compostable. In summary, the waste material delivered to the proposed facility is neither manure nor biodegradable. Furthermore, the biochar produced at this proposed facility is not compostable and must be hauled off -site and processed further before it becomes compostable. Categorizing this facility as an organic fertilizer production or composting facility is a mischaracterization. By example, a quick google of the "top farming fertilizer producers" returns the following article, among others: Top 21 Fertilizer Manufacturers in the USA - HANS [2025 Updated]. The Mosiac Company, at #2, is the top producer of fertilizer based in the USA. The Mosaic Company operates several manufacturing facilities in the USA, including the Bartow facility in Florida, which is one of the largest phosphate plants in the world. The Bartow facility produces around 2.2 million tons of processed phosphates per year, contributing to about 10% of world production and 60% of North American production. The facility also produces phosphoric acid, which is used to create diammonium phosphate (DAP), a key fertilizer ingredient. Mosaic's manufacturing facilities are part of a global network that includes plants, port facilities, warehouses, and sales offices, ensuring a wide distribution of their products. The Mosaic Company J Mosaic North America J Potash J Diammonium Phosphate. The fact The Mosiac Company produces a top -selling agricultural fertilizer doesn't eliminate its industrial process and need for manufacturing. • c. B. 3 - USE is compatible with existing SURROUNDING LAND USES. Ms. Snyder suggested the proposed USE is Compatible with existing Surrounding Land Uses because the applicant proposes mitigation to address most of the concerns and objections submitted by the surrounding property owners. WELD COUNTY GOVERNMENT Department of Planning Services 3. Compatible with Surrounding Land Uses Section 23-2-220.A.3. - That the uses which would be permitted will be cornpatibie with the existing surrounding land uses. ✓ Neighborhood meeting held October 12, 2024. ✓ 11 Surrounding Property Owner's submitted letters of objection. ✓ Mitigation for noise and visual impacts are proposed. Record USR24-0019, PowerPoint Presentation.pdf Slide 15. According to Ms. Snyder, there are nine (9) USRs within one (1) mile of the proposed USE. And while the USRs listed by Ms. Snyder include uses not traditionally considered agricultural e.g., a repair facility, a dump station, a storage facility those USRs nearest to the proposed SITE, or those property owners most directly impacted by this USR are generally considered agricultural or natural uses of the land e.g., a kennel for exotic animals, a feed lot for cattle, and a hog farm. Please compare the following inserts (USRs within 1 mile vs Objecting Property Owners) : WELD COUNTY GOVERNMENT Department of Planning Services USRs within one mile ,.A U. FON .Nt600Sr a+E N Pit Vitae. US1lt1O01. • 12 INCH *i,n PRf SSURE NAT GAS (u11+.DIl�N. i 1 . Say" • gall uSa 'b!6 MIS RESEARCH REPAIR i 51/P :.6 M TAWS USA 16 4011 a A IMMO _ MANtJFAC Hat tJSR 1 t 00)0 antdRAI RESOURCE 0EV FAC • • • • Kftreltl EXOTIC MRS& CR4 SUP 33 FEED tOT 1500 CATT1E SITE CRe s.,P Sly HOG CANM 5— ,.'.ju t) SINGLE TAM r Ri SIDE ILL u3Rt: dot' NCJN t8tt MAJOR FAC>t m USR14 0011 I/ATURAL GAS tOE •t7 JSR 14 6067. SUSS1ATIOn 1w1144 IMS+TV U%a'4 I HON SUNNI USR 1)11 ra CIRCUIT jay RANSTASSION /uSR 1430t$ DOW STATION 8S DRAG( I NRlrtf Tfw Record USR24-0019, PowerPoint Presentation.pdf Slide 16. 8 WELD COUNTY GOVERNMENT Department of Planning Services The white stars indicate property owners that submitted a letter of opposition to this USR mars— _•— ❑ Closest Residences Record USR24-0019, PowerPoint Presentation.pdf Slide 17. The property owners on all sides of the proposed site have objected. Each has concerns about the proposed USE and its compatibility, among other objections. Accordingly to Mr. Hale, a fifteen (15) year resident an working ranch operator at 14760 County Road 6, Ft. Lupton, Colorado 80621, he and his fellow objecting landowners have had to fight tooth and nail to protect the agricultural nature of their close community. What once was a large ag community is shrinking. Mr. Hale asserts this small area is one of only a few areas where agriculture remains dominant and he and his neighbors feel like they are under constant attack to protect the community's agricultural heritage. As mentioned above, Mr. Hale lives on and works a ranch. His ranch/residence site to the east of the proposed site. He raises cattle for consumption. His ranch, Raising Hale LLC, is renowned for raising high-grade angus and wagyu cattle. To the south of the proposed site lives Ms. Yarborough. Ms. Yarborough operates a well-known horse ranch. To the west of Ms. Yarborough is the Crawford/Brown property. They operate an exotic animal kennel/ranch. To the north of the Crawford/Brown property and to the west, northwest and north of the proposed site are the Sak properties. Mr. Sak farms and runs a cow/calf operation. The properties north/northeast of the proposed site are owned by the Massey's, the O'Neals and others. Each operates animal ranches including but not limited to horse, goat, and chicken operations. 9 These property owners are collectively referred to herein as the "Impacted Property Owners." It's the Impacted Property Owners, not those outside of this agricultural epicenter, that will suffer the most from the negative effects bought about by the proposed USE. Each has filed objections and voiced concerns. Farming is agricultural by definition and is an accepted land use in an agricultural zoned district. Horsing is agricultural and is an accepted agricultural land use. Ranching is agricultural and is an accepted agricultural land use. Cow/calf operations is agricultural and is an accepted agricultural land use. The Surrounding Land Uses are consistent with agricultural land uses. Furthermore, the Planning Commission received fourteen (14) Objection Letters to the USE. The applicant provided a written response and Ms. Snyder summarizes the applicants response in her presentation: WELD COUNTY GOVERNMENT Department of Planning Services Response to Surrounding Property Owner's Concerns • Air pollution - emissions controlled by CDPHE (no referral response) • Noise and light mitigated Disturbance of the surrounding eco-systems - not a pollutant, biochar is a soil amendment • Activities adversely affect the wildlife, livestock, and other animals - similar to other uses in the area Carcinogenic dust from charcoal - the dust does not cause cancer (per testing) • Increased traffic and decreased property value • Fire safety and drainage issues Compatibility with surrounding agricultural operations Lack of adequate visual screening - screening will surround the entire property Record USR24-0019, PowerPoint Presentation.pdf Slide 19. Mitigation doesn't address the compatibility of an industrial facility operating right in the middle of a close-knit agricultural community. And that's what the Impacted Property Owners have. Each actively engages in agriculture. Each depends on traditional agricultural means for their livelihood. Each uses their land agriculturally. Accordingly, industrial production facilities placed amidst traditional agricultural land users and uses is not compatible. And for these reasons the USE is not compatible with the surrounding land uses. 10 d. B. 4 - USE is compatible with FUTURE DEVELOPMENT of the surrounding area. Essentially, Ms. Snyder suggested the proposed USE is Compatible with Future Development because the cities or towns contacted failed to comment or object. WELD COUNTY GOVERNMENT Department of Planning Services Q._r.rt, C 4. Compatible with Future Development (Weld Comp Plan Map & Municipality Plans) Weld County, Fort Lupton, Brighton, Lochbuie ✓ Weld County Comprehensive Plan shows the site as Urban Area ✓ The Town of Lochbuie and the City of Brighton - no comments ✓ The City of Fort Lupton - no concerns Record USR24-0019, PowerPoint Presentation.pdf Slide 28. I caution the BOCC that should it approve this USR Permit the future of this area is susceptible to vast industrial growth. Biochar Now admits in its Planning Commission presentation it "wants to grow its business in Weld County" It admits this particular site was chosen because of convenience. That it's relationship with NGL Water Solutions DJ, LLC ("NGL") made this proposal possible. And cost-effective. If the surrounding property owners suffer substantial financial losses, are affected by pollutants and nuisances, or are no longer able to operate agricultural business, as alleged by most or all, what stops each from selling or leasing their property to Biochar Now or others that intend to bring industry into the area? This Board has the opportunity to address the future now, with its decision on this application. e. B. 5 - PROPOSAL complies with identified OVERLAY and HAZARD areas. Ms. Snyder explained the proposed USE does not involve an overlay or hazard district. Accordingly, this factor warrants no discussion. WELD COUNTY GOVERNMENT Department of Planning Services 5. Overlay or Hazard District - not in an Overlay X 1-25 Overlay District X Geologic Hazard Overlay District X Special Flood Hazard Area X Agricultural Heritage Overlay District X MS4 - Municipal Separate Storm Sewer System Area X A -P (Airport) Overlay District X Historic Townsites Overlay District Record USR24-0019, PowerPoint Presentation.pdf Slide 32. 11 f. B. 6 - APPLICANT demonstrated a diligent effort to conserve PRIME FARMLAND. WELD COUNTY GOVERNMENT Department of Planning Services 6. Effort to Conserve Prime Farmland ✓ Currently leasee for farming of alfalfa and flood irrigated ✓ Water will not be sold ✓ Soil type - Farmland of Statewide Importance & Prime Farmland if Irrigated ✓ Not a significant reduction in farmland if removed from agricultural production as it is --30 acres Record USR24-0019, PowerPoint Presentation.pdf Slide 33. Conservation of prime farmland should be of the utmost importance and stated as such unequivocally in the Comprehensive Plan. g. B. 7 - The HEALTH, SAFETY, AND WELFARE of the inhabitants of the NEIGHBORHOOD and COUNTY is protected. Again, the position taken by the Planning Committee as well as the applicant seems to be that any health and safety concerns can be mitigated. WELD COUNTY GOVERNMENT Department of Planning Services WELD 7. Protection of Health, Safety, & Welfare Air emissions - mitigated via proprietary pyrolysis technology Noise - mitigation proposed Dust Abatement Plan - Gravel and concrete pads. Dust from processing will not be significant enough to be a nuisance. Drainage report - Stormwater pond to be constructed Lighting Plan - Downcast & shielded required; fence to block lights from trucks, and trucks to operate during daylight hours ✓ Waste Handling Plan - Metal from the waste wood will be recycled; concrete pad for the containment of the waste wood material Screening Plan - Metal fence will surround the entire site; possibility of berms on the eastern portion weld goy Record USR24-0019, PowerPoint Presentation.pdf Slide 33. 12 The Health, Safety, and Welfare of the inhabitants of the neighborhood, or the Impacted Property Owners, should be paramount. Most if not all of the Impacted Property Owners have voiced their health and safety concerns. Be it the health of their families or livestock or livelihood. This factor has been and will continue to be addressed directly by each of the Impacted Property Owners and their representatives. As for Mr. Hale, at the Planning Commission Hearing, Mr. Hale expressed concerns for the health of himself and his son both asthma sufferers. Biochar Now reps admitted in the Planning Meeting he felt for Mr. Hale since he will most certainly lose his beautiful mountain views behind the proposed stockpiles and with the installation of the berm and sound walls. Local real estate professionals speculate Mr. Hale's property value could diminish by a upwards of a million dollars as a result of his lost mountain views. Below is a photo submitted by Mr. Hale from his front door looking west (note the 8 ft tall berm will be installed along his fence line just yards from his home): Admittedly the USE will emit emissions, create nuisances, and diminish property values. Concerns for exaggerating existing medical conditions and deteriorating health should be taken seriously and trump any USE. The applicants position monitoring emissions is the purpose of regulating agencies, and mitigating nuisances will be taken seriously, and expressing sympathy for property owners that will suffer financial losses are mere promises. In conclusion, this examination considers the factors to be considered by the Board of County Commissioners in deciding whether to approve or deny, or take under advisement, USR24-0019 submitted by Biochar Now requesting a special use permit allowing it to build 13 industrial infrastructure in and around one of very few remaining agricultural centric communities. Size of the community shouldn't be considered. This examination has demonstrated the factors, specifically whether the PROPOSAL is consistent with the Plan and Zoning, whether the USE is compatible with the Surrounding Land Uses and Future Development, and whether adequate protections for the health, safety, and welfare of the local inhabitants exist, weigh in favor of denying USR24-0019. DATED AND RESPECTFULLY SUBMITTED NOVERMBER 4, 2025 by: R ennis R. ennis R. Jacksoj*43357 Jackson Law 5200 DTC PKWY STE 200 Greenwood Village, CO 80111 (303) 558-5232 dennis@jaxlawllc.com • 14 EXHIBIT 6.1 2 s 4 To Whom It May Concern, u_s, 244 sr UDi9 I am writing to express my concerns about the proposed biochar facility being installed near Jeri Yarbrough's facility. While I understand the importance of sustainable energy projects, the proximity of this facility to her horses (our patients) poses significant risks to their long-term health and well-being. As an equine veterinarian, I have strong concerns about this possibility. Biochar production releases fine particulate matter and other pollutants into the air, as is wed documented in the study "Reviewing Air Pollutants Generated during the Pyrolysis of Solid Waste for Biofuel and Biochar Production: Toward Cleaner Production Practices" by Simeng Li from the Department of Civil Engineering, California State Polytechnic University and referenced in Sustainability 2024, 16(3), 1169; https://doi.org/10.3390/su16031169 In this article, they expand on the particulate matter emissions which has been proven to lead to respiratory issues, compromised immune systems, and other chronic health problems in humans and to a greater extent horses. These animals are highly sensitive to environmental changes, and any decline in air quality or the introduction of toxins could have devastating effects on their health. Recent studies by Dr. Janet Beeler-Marfisi of the Ontario Veterinary College looked at the effect of the devastating wildfires in Canada on the local horse population. It was found that both mild and severe equine asthma are triggered by particulate matter and other air pollutants. Horses have a significant lung capacity and associated athleticism that is highly sensitive to air quality. Minimal inflammation caused by inhaling particulate matter can lead to problems with breathing, decreases in athletic function and decrease the longevity of a horse's career if left unchecked. Having the 24/7 "wildfire" of pyrolysis located in an adjacent property puts all animals, and especially the horse population at undue risk. I urge the county to carefully consider the potential impact of this facility on the surrounding environment and the health of the horses in the area. I hope you will take these concerns into account and explore alternative locations that would not put animals and their caretakers at risk. Thank you for your attention to this important matter. Dr. Bret Luedke Heritage Equine Hello