EPA Life Cycle Analysis Causes Uproar

By Tina Caparella


Many in the biodiesel industry are voicing their concerns and disagreement with a portion of an Environmental Protection Agency (EPA) proposed rule changing the agency’s Renewable Fuel Standard program, referred to as RFS2. They are specifically displeased with a draft analysis of the life cycle greenhouse gas (GHG) impact of certain feedstocks, primarily soybeans (see “Biofuels Bulletin” in June 2009 Render).

To qualify for the RFS2 program, which, for the first time, requires a renewable component in U.S. diesel fuel, renewable fuel must reduce GHG emissions by 50 percent compared to the conventional diesel fuel it is replacing, with the EPA administrator having the authority to reduce that target to 40 percent. According to EPA’s draft life cycle GHG emission reduction results, which takes into account indirect emissions such as land use, soy-based biodiesel, at a 22 percent discount rate, would not meet the 50 percent reduction threshold the agency has set. EPA has set waste grease biodiesel at an 80 percent discount, but has not listed animal fats in the draft results.

According to testimony by Manning Feraci, National Biodiesel Board (NBB) vice president of Federal Affairs, at an EPA public hearing on the proposed rule, at contention is that EPA, when calculating a renewable fuel’s emission profile, is using faulty data and unrealistic scenarios that punish the U.S. biodiesel industry for unrelated land use decisions in South America. Feraci stated that under the proposed rule, biodiesel produced from domestically produced vegetable oils are disqualified from the biomass-based diesel program, making it all but impossible to meet the volume goals established by the statute. He went on to provide statistics regarding land conversion in South America and stated that EPA’s GHG emission methodology on nitrogen emissions uses outdated data instead of a 2006 guideline that determined nitrogen fixed in the soil by soybeans should not be considered GHG emissions.

“Because the proposed rule relies on dubious land use assumption and inaccurate data, the EPA’s proposed rule restricts feedstock for low-carbon diesel replacement fuel to only animal fats and restaurant grease,” Feraci testified. “Vegetable oil accounts for more than 60 percent of the feedstock that is available to meet the RFS2 biomass-based diesel targets, and the RFS2 volume goals simply cannot be met if vegetable oils are disqualified from the program.”

The American Soybean Association (ASA) also testified at the hearing, voicing its concerns about the proposed rule, primarily the international indirect land use assumptions that EPA has proposed to use in its life cycle GHG analysis.

“In the proposed rule, soy biodiesel land use factors were focused largely on deforestation in Brazil,” states an ASA press release. “Brazilian soy area increased most significantly in years prior to the existence of U.S. biodiesel production (1998-2004). In the periods from 2004 to 2008, when U.S. biodiesel production increased from 25 million gallons to 700 million gallons, Brazilian soy area has actually decreased.”

Despite soy-based biodiesel’s poor showing in EPA’s GHG calculations, NBB Chief Executive Officer Joe Jobe is looking on the positive side. Currently, biodiesel purchased today will count toward this year’s 500 million gallon requirement set by EPA, no matter the feedstock.

But it appears EPA’s draft life cycle analysis is already having an impact on soy-based biodiesel use. The cities of Seattle, WA, and Berkeley, CA, have decided to stop using the vegetable oil-based alternative fuel because of its impact on GHG emissions.

“We do want to use biodiesel,” said Brenda Bauer, director of Seattle’s Fleets and Facilities Department. “We strongly believe in reducing our consumption of petroleum, but we need cleaner and better alternatives that have a lesser effect on our environment.” The City of Seattle had been using 73,000 gallons of soy-based biodiesel per month at a 40 percent blend in 787 vehicles. Bauer said the city is now working with General Biodiesel in Seattle on testing a 20 percent blend of its waste grease-based biodiesel to ensure it meets ASTM D7467-08. Chris Wiley, Seattle’s Green Fleet coordinator, said currently General Biodiesel does not use tallow in their biodiesel production, but will introduce the animal fat once distillation equipment is installed at a recently acquired plant.

“Seattle believes in ‘reduce-reuse-recycle’,” added Bauer.

As for the City of Berkeley, it too has stopped using soy-based biodiesel on the recommendation of the city’s Community Environmental Advisory Commission, which based its decision on EPA’s life cycle analysis and other studies. However, the city will not be switching to biodiesel produced from waste cooking oil at this time because the age of the city’s underground storage tanks prevent them from storing biodiesel in accordance with California laws. Berkeley had been using biodiesel in its fleet since 2003 and was annually pumping about 200,000 gallons of biodiesel at a 20 percent blend rate. According to Deputy Public Works Director Andrew Clough, the city is reviewing its options to using biodiesel and is in communication with other West Coast cities, including Seattle, in an effort to help make the best decision for the environmentally-conscious city.

The National Renderers Association has already submitted preliminary comments on EPA’s proposed rule, encouraging the agency to not delay implementation of the proposed RFS2 beyond 2009 so that the program applies to “all renewable fuel produced on or after January 1, 2010.” The association further commented that unnecessary regulatory burdens or uneven treatment of biofuel made from recycled materials are counterproductive for the rendering industry and the environment.

Initially, EPA provided a 60-day comment period to the proposed rule until July 27, 2009, but then extended it an additional 60 days to September 25, 2009, to allow more time to comment. The extended comment period raises concern for all parties in the biodiesel industry in that it delays implementation of the program, which could cause further harm to an industry already suffering from a downturn in production.

Europe Extends Duties on U.S. Biodiesel

In a further blow to a struggling industry, the European Union (EU) has voted to impose duties on imported U.S. biodiesel for five years. The action followed provisional duties placed on March 12, 2009, after a formal complaint from the European Biodiesel Board (EBB) stated that imports of U.S. biodiesel represented dumping, U.S. subsidies to encourage biodiesel production were unfair, and that the situation is causing severe damage to the EU’s biodiesel industry. The five-year tariffs went into effect July 12, 2009, and range from 213 Euros (about $300 U.S.) to 409 Euros (about $575 U.S.) per ton.

The EBB applauded the decision, stating that it “confirms that the U.S. claims were misleading and self-defeating. They could not break the strong causality link between unfair U.S. biodiesel trade and the damage suffered here in Europe.”

The European Commission launched an anti-dumping and anti-subsidiary investigation into U.S. biofuels in June 2008 after EBB filed its complaint, claiming that for more than two years, U.S. biodiesel was sold in Europe at a substantial discount, even lower than vegetable oil feedstocks purchased by the EU industry for producing biodiesel.

The National Biodiesel Board (NBB) called the EU’s action an unfortunate decision.

“Throughout this case, we have constantly put data on the record that clearly shows the European biodiesel industry was not being harmed by U.S. competition,” stated Manning Feraci, NBB vice president of Federal Affairs. “In fact, some EU companies have fared quite well. For those that have not, it is factors unrelated to U.S. competition – bad business models, high feedstock prices, and detrimental EU member state policy – that are to blame. The decision to ignore these fundamental facts has yielded a protectionist result that is detrimental to all parties involved.”

EBB said its next priority is to ensure the full respect of the EU measures by remaining vigilant regarding any possible circumvention attempt. The board is already working with EU authorities to track and report any shipment of U.S. biodiesel fraudulently entering the European market directly or indirectly via third countries.

Just days after the duties were imposed, production figures released by the EBB showed the European biodiesel industry increased production in 2008 by 35 percent compared to 2007 levels, to 7.7 million metric tons (about two billion gallons). The board stated the increase in production is still not in line with the ambitious European Union objective for climate change mitigation outlined in the recently published Renewable Energy Directive 2009/08, and is a lower increase than what was seen in 2005 and 2006, when biodiesel production increased by 65 and 54 percent, respectively. Biodiesel production in 2007 declined by 16 percent over 2006.

Currently, there is nearly 21 million tons (5.7 billion gallons) of installed production capacity, an increase of 31 percent compared to 2008, with 276 biodiesel plants as of July 2009. EBB stated that statistics show that at least 50 percent of existing plants remain idle.

Canada’s Biofuels Industry Examined

The U.S. Department of Agriculture’s Foreign Agricultural Service released a Global Agricultural Information Network (GAIN) report June 30, 2009, on Canada’s biofuels industry, which states that Canada’s limited biofuel production capacity, both in the short and medium term, suggests that the country’s entry into the global ethanol market is still quite distant.

As for biodiesel, the report states that the growth in production capacity has not increased significantly until very recently, with the strong driver being provincial mandates that are likely to go into force ahead of a federal mandate. Canada has a patchwork of provincial mandatory renewable fuel mandates, ranging from two to five percent in diesel fuel mostly by 2010, but the timeline for the details and exact implementation date of the federal mandate of an annual renewable content of five percent in gasoline by 2010, and a two percent requirement for renewable fuel in diesel by 2012, remains somewhat elusive. The report states current estimates are that the proposed regulations will be published in the fall of 2009 for comment.

GAIN estimates Canada’s biodiesel production capacity by the end of 2009 to reach 216 million liters (57 million gallons), a 71 percent increase over 2008 production capacity of 126 million liters (33.2 million gallons), provided two plants currently under construction go online before the end of this year. It is also estimated that 49 percent of the production capacity will be from tallow (an increase from 36 percent in 2008), 37 percent yellow grease based (a decrease from 59 percent in 2008), and 14 percent from canola (an increase from six percent in 2008). By 2010, forecasts are that tallow, yellow grease, and canola-derived biodiesel will account for 46 percent, 37 percent, and 17 percent, respectively.

The 32-page GAIN report is available on the Internet at http://gain.fas.usda.gov/Recent%20GAIN%20Publications/General%20Report_Ottawa_Canada_6-30-2009.pdf.

Canadian Government Invests Millions in Western Biodiesel

Thanks to an investment by the Government of Canada, Western Biodiesel’s facility in High River, AB, will receive up to $19.9 million over seven years to support biofuels development. According to Western Biodiesel, the funds will help develop innovative technologies to help broaden Canadians’ fuel choices.

Through the ecoENERGY for Biofuels program, the Government of Canada will invest up to $1.5 billion over nine years to encourage the development of a strong, competitive renewable fuels industry in the country.

BDI to Build Amsterdam Plant, Partakes in California Meeting

Austrian company BDI-BioDiesel International AG has been commissioned by Biodiesel Amsterdam BV to construct a multi-feedstock biodiesel plant in the port of Amsterdam, the Netherlands. The facility will have an annual capacity of 113 million liters (29.8 million gallons) and produce biodiesel from used cooking oil and animal fats in accordance with the European standard EN 14214.

According to BDI, this will be the largest industrial biodiesel plant of this type in Europe and will become part of the energy park in the port of Amsterdam. In addition to the production of biodiesel, electricity and heat will also be extracted from a biogas plant. The plant is expected to go online in 2010.

In separate news, BDI’s Klaus Ruhmer traveled with Austrian Minister of Environmental Affairs Nikolaus Berlakovich in early June to California to meet with Governor Arnold Schwarzenegger, himself an Austria native, to outline some of the latest advances on how to convert waste oil to biodiesel. The governor and minister also discussed cooperation of the two governments in the areas of environment and reduction of greenhouse gas emissions.

CARB Seeks Comments on Model for Used Cooking Oil Biodiesel

The California Air Resources Board (CARB) is continuing its development of greenhouse gas (GHG) modeling of alternative fuels for California’s proposed Low Carbon Fuel Standard program. Carbon footprint and GHG emissions data for recycled feedstocks were provided by the National Renderers Association (NRA), Fats and Proteins Research Foundation, Animal Co-Products Research and Education Center, and various NRA members, and are being utilized by the CARB GHG emissions modeling team.

On July 20, 2009, the Stationary Source Division of CARB posted their proposed “Detailed California-Modified GREET Pathway for Biodiesel Produced in California from Used Cooking Oil.” This model and other documents are available at www.arb.ca.gov/regact/2009/lcfs09/lcfs09.htm.

The draft Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model calculates that biodiesel produced from used cooking oil achieves a GHG emissions value of 13.7 grams carbon dioxide (CO2) equivalents per megajoule of energy compared with ultra low sulfur diesel at 94.7 grams CO2 equivalents per megajoule, thereby reducing GHG emissions by over 85 percent.

The team has also published initial values for renewable diesel produced from tallow. The draft model calculates GHG emissions at 29.7 grams CO2 equivalents per megajoule, a reduction of almost 69 percent compared to ultra low sulfur diesel.

It is expected that alternative fuels produced from rendered feedstocks will play an important role in reducing GHG emissions in California. Fred Wellons of Tellurian Biodiesel suggests that, “Although California will ultimately require the contribution of many different alternative fuel technologies such as hydrogen and electric vehicles, currently, biodiesel is the only available fuel that can generate quick and substantial GHG emissions that allow the Low Carbon Fuel Standard program to reach its goals.”

CARB’s documents are open for public comment until August 19, 2009, at www.arb.ca.gov/lispub/comm/bclist.php.

Cargill Starts Production at German Glycerin Refinery

Cargill has started production at its new glycerin refinery in Frankfurt, Germany. Construction of the new plant, located adjacent to Cargill’s existing biodiesel production facility in the Hochst Industrial Park, began in September 2008 and was completed within nine months.

The majority of the new refinery’s supply of crude glycerin – a co-product of the biodiesel production process – will come from Cargill’s biodiesel plant.

De Forest Biodiesel Plant Shuts Down

Due to the current economic situation, Sanimax has temporarily shut down its De Forest, WI, biodiesel plant, and laid off 20 of the plant’s 30 employees. The remaining 10 employees will maintain minimal operations at the plant.

Sanimax spokesperson Daniel Hansen said a combination of climbing fat markets and decreasing oil prices was putting pressure on margins at the plant. He said the company remains committed to its renewable energy sector and will assess the situation continually in hopes of reopening the plant in the future.

“We want to remain in the renewable fuels industry,” Hansen stated. “In no way are we talking about closing our energy division.” He added that it was difficult to let the 20 employees go as they were valuable to the company. Sanimax’s De Forest plant began producing biodiesel from a variety of feedstocks, primarily recycled cooking oil, in mid-2007.

General Biodiesel Buys Seattle Biodiesel

General Biodiesel Seattle, LLC, has completed the acquisition of the former Seattle Biodiesel facility, a Seattle, WA-based commercial biodiesel plant, from Imperium Renewables, Inc. General Biodiesel is converting the facility to produce biodiesel from waste oils such as recycled cooking oil and animal fat, which the company collects from restaurants and grocery stores around the region.

Neste Oil to Construct Renewable Diesel Plant in Rotterdam

Neste Oil has begun construction on its renewable diesel plant in the Port of Rotterdam, the Netherlands. Upon completion, the plant will be the largest renewable diesel plant in Europe with an annual production capacity of 800,000 metric tons (217 million gallons).

The plant’s production capacity will be a major step forward to reaching the European Union’s 10 percent renewable fuels target in transport. NExBTL, Neste Oil’s proprietary technology, contributes a 40 to 80 percent reduction in carbon dioxide emissions, and independent research has proven that it significantly reduces tailpipe emissions. 

At its current production plant in Finland, Neste Oil uses palm oil, rapeseed oil, and animal fats as feedstock. The company is dedicated to sustainability in its feedstock sourcing, committing to solely using certified palm oil by the end of 2015 or even before if sufficient volumes become available. Most of Neste’s research spending is used in developing new renewable raw materials.

Green Fuels UK Acquires U.S. Biodiesel Firm

The United Kingdom’s Green Fuels, Ltd., has purchased the physical assets of Renewal Fuels, Inc., and Renewal Biodiesel, Inc., Milwaukee, WI, to create Green Fuels America, Inc. with headquarters in Sparks, NV, where Renewal Fuels had manufactured its FuelMeister personal biodiesel processor. The plant will continue to manufacture the personal biodiesel processors as well as Green Fuel’s own more automated Fuelpod systems. More significantly, this facility will act as a U.S. base to market its line of Fuelmatic commercial biodiesel processors, of which 18 are currently operating in Europe processing some 30 million gallons of used cooking oil per year into biodiesel, some of which is used to power the British Royal Family’s personal train.

Green Fuels America is a wholly-owned subsidiary of the Stonehouse, England-based Green Fuels.

James Hygate, co-founder of Green Fuels, said the company is looking forward to its expansion into the U.S. market.

“We believe that the United States has a terrific future for biodiesel production from yellow grease and tallow,” he said. “We think our business model in the UK should be even more profitable for our clients in this domestic environment.” The company has projects and joint ventures in Eastern Europe, Africa, India, Japan, and China.

Nevada Researchers Make Biodiesel from Feather Meal

Researchers at the University of Nevada-Reno (UNR) have developed a new and environmentally friendly process for developing biodiesel from feather meal.

Feather meal is currently used as an animal feed, given its high protein content, and also as a fertilizer because of its high nitrogen content. In this new process, the UNR researchers have extracted fat from the feather meal in boiling water and then transesterified the fat into biodiesel using potassium hydroxide and methanol; seven to 11 percent biodiesel (on a dry basis) is produced in this process.

According to a paper produced by the researchers, ASTM International analysis of the prepared feather meal biodiesel confirmed that the biodiesel is of good quality and comparable to other biodiesels made from other common feedstocks. The UNR researchers estimate this process can create 150 to 200 million gallons of biodiesel in the United States, and 593.2 million gallons worldwide.

The team’s paper, “A Green Process for Producing Biodiesel from Feather Meal,” was published in late June by the Journal of Agricultural and Food Chemistry. The four authors from the university’s Chemical and Materials Engineering Department are Narasimharao Kondamudi, Jason Strull, Mano Misra, and Susanta K. Mohapatra.

New Zealand Grants Help Expand Biodiesel Industry

A new grants program for biodiesel production is aimed at giving the biodiesel industry in New Zealand a kick start.

“By supporting biodiesel production in New Zealand, we can help get a new industry up and running, which can provide jobs for New Zealanders, at the same time as helping to reduce their greenhouse gas emissions,” said Energy and Resources Minister Gerry Brownlee.

The program will allocate $36 million (New Zealand) in grants over three years beginning July 1, 2009. Up to $9 million will be available in the first year, up to $12 million in the second year, and up to $15 million in the third year, at a maximum rate of 42.5 cents per liter of biodiesel. The grants will be available to domestic biodiesel producers selling their product within the country. Some biodiesel is already produced in New Zealand from waste cooking oil, tallow, and rape seed oil. 

Brownlee said the initiative fulfilled the government’s pre-election promise of providing incentives for biodiesel producers, in recognition of the advantage that bioethanol already enjoys.

According to industry analysis commissioned by the Energy Efficiency and Conservation Authority, biodiesel produced in New Zealand is expected to result in reductions of greenhouse gas emissions of between 50 and 90 percent compared to ordinary diesel, will not be produced on land of special environmental value, and will not compete with food production.

Oregon Phases in Biodiesel Blend Mandate

Roughly two years following the implementation of a renewable fuel standard requiring 10 percent ethanol in most gasoline sold in Oregon, the state is taking a similar step with diesel fuel. As of August 5, 2009, with a few exceptions, diesel fuel in nine northwest Oregon counties will be required to contain at least two percent biodiesel. By October 1, 2009, the entire state will implement the new renewable fuel standard for diesel. About a half billion gallons of diesel is sold in Oregon each year.

The new fuel standard was established as part of renewable energy legislation passed in 2007. The only exceptions to the biodiesel blend mandate are rail, marine, and home heating oil applications. The two percent requirement has been recently triggered by Oregon’s biodiesel production capacity now reaching five million gallons.

As part of the new renewable fuel standard, the Oregon Department of Agriculture (ODA) requires testing of 100 percent biodiesel (B100) by the supplier upon receipt of imported fuel at the receiving terminal and by in-state producers prior to it being blended with standard diesel fuel. B100 will also be sampled by ODA from time to time to ensure the fuel meets specifications prior to blending.

USDA Approves Loan for Closed Minnesota Plant

The U.S. Department of Agriculture’s Rural Development has approved a $25 million loan to enable a Minnesota biodiesel facility to diversify its operations and expand its production.

SoyMor Biodiesel will receive the guaranteed loan to purchase equipment that will enable it to convert multiple types of feedstocks, including an unrefined corn oil waste product from nearby ethanol facilities, into biodiesel. Currently, the Albert Lea, MN, plant only has the ability to process soybean oil. The funding will restore nearly 30 jobs. High feedstock prices forced SoyMor to suspend operations in spring 2008. The plant opened in 2005 and has an annual capacity of 30 million gallons.

Washington Plant Suffers Fire After Industry Sends Out Safety Materials

Gen X Energies’ Burbank, WA, biodiesel facility was destroyed by fire over the 4th of July holiday weekend. The plant had just received BQ 9000 status from the National Biodiesel Board (NBB) the day prior to the fire. While company officials look for a new location to rebuild the facility at the Port of Walla Walla, investigators are trying to determine what and who caused the fire. Arson is among the causes being investigated since it is believed the fire began outside the building while the facility was not operating.

The plant began production in May 2007 and was running at half capacity, producing about 7,200 gallons of biodiesel per day.

This fire is just one of several suffered at various biodiesel plants around the country in recent years. And while the biodiesel production process is safe, even the safest facilities can have industrial accidents. That’s why the NBB and the International Association of Fire Chiefs (IAFC) have cooperated for more than a year to prepare and distribute safety training materials.

NBB has posted the new “Biodiesel: Response Considerations” safety resource on its Web site at www.biodiesel.org, and is mailing copies to NBB producer members to work with their local fire departments. The IAFC will distribute 2,700 copies to fire departments and at events, like the International Hazardous Materials Response Teams Conference held in late May.

The materials include training tools as well as a video about response considerations. The video is available on NBB’s YouTube channel at www.youtube.com/nationalbiodiesel. NBB and IAFC developed the materials with the help of a U.S. Department of Energy grant.

Comments on this and any other article in Render are welcome and may be sent to editors@rendermagazine.com.


Biofuels Bulletin – August 2009 RENDER | back