At the recent NBB conference in San Diego, a group of California biodiesel producers, users and advocates formed the California Biodiesel Board (CBB) to promote the use of biodiesel in California. Below you will find the CBB letter to the EPA regarding the need for the EPA to update its biodiesel NOx emissions data and requesting a scientifically based high credit value for biodiesel in the RFS regulations.
For all you regulatory nuts out there, enjoy!
Stephen L. Johnson
US EPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Mail Code 1101A
Washington, DC 20460
March 3, 2006
RE: Biodiesel NOx Emissions and RFS Credits
Dear Administrator Johnson:
The California Biodiesel Board would like to thank you for your recent presentation at the National Biodiesel Board (NBB) Conference in San Diego. We appreciate your willingness to take time from your busy schedule to travel to California and inform the conference about EPA and the President’s commitment to replacing petroleum with renewable fuels.
Our members were in attendance at the conference, along with over 2000 other participants who want to increase biodiesel use in the United States. Our focus as the California Biodiesel Board is to educate Californian’s about biodiesel and to remove barriers, which impede its use.
We would like to have your help in increasing biodiesel use in California. There are two main ways you can help us:
1) EPA should evaluate new sources of biodiesel NOx data and establish a NOx emission rate that states can use in State Implementation Planning (SIP) - In 2003, EPA published a proposed regulation, which was a compilation of studies on biodiesel criteria pollutant emissions. EPA received very few comments on the regulation and, thus, did not issue a final regulation. In the proposed regulation, biodiesel NOx emission data was presented that claimed an increase over petro-diesel. Since that time, new NOx data has become available from sources such as the US Navy and NREL that demonstrates much lower NOx emissions for biodiesel. This important new NOx data has been presented in several public forums, including at the NBB conference. We respectfully request that EPA re-open the proposed regulation so that new NOx data can be submitted by interested parties and considered by EPA as you determine an emission rate for biodiesel NOx. In California, biodiesel NOx emission rates as presented by EPA (in the proposed regulation) are currently the primary barrier to CARB’s acceptance of biodiesel.
2) US EPA should consider the technical data on the total life cycle analysis of ethanol verses biodiesel and the BTU loss in using ethanol verses biodiesel to replace petroleum fuels when establishing a credit for biodiesel in the renewable fuel regulations; EPA should base the biodiesel credit number on science, not politics. In the fall of 2006, EPA plans to propose regulations that will establish the credit value for biodiesel and the credit-trading program rules for all renewable fuels. The credit value for biodiesel and the credit-trading program will have an enormous impact on the biodiesel industry. It is imperative that the rules be established in a fair and scientific way. We understand that EPA is under strong political pressure to favor ethanol in this process. Based on several technically sound methods, biodiesel should receive a credit of no less than 3 to 1 as compared to ethanol. We further understand that EPA is considering a number less than two for biodiesel. A low credit value for biodiesel is advocated by the ethanol industry for obvious reasons. Unfortunately, the dynamics of the NBB have prohibited the NBB from being able to oppose a low credit value for biodiesel. This dynamic exists because many of NBB’s members have ethanol interests. The California Biodiesel Board respectfully requests that EPA consider only the scientific and technical information, and not politics, as you make this important choice. The biodiesel credit value will greatly affect the growth of biodiesel in California and the rest of the US. Furthermore, and of equal if not greater importance, the methods used to determine such credit value will set a crucial precedent for how renewable fuels will be evaluated in the future.
The California Biodiesel Board will be glad to answer any questions you have regarding our requests. Again, please let us thank you for your support of biodiesel.
Eric M. Bowen
California Biodiesel Board
CC: Margo Oge, USEPA, Office of Transportation and Air Quality