When it comes to renewable fuels, recent discussions have centered on the effects of small refinery hardship waivers under the Renewable Fuel Standard, renewable identification number (RIN) credits on exported gallons, acceptable RFS mandate levels, and new EPA Administrator Andrew Wheeler. But beyond these high-level topics are a number of less-discussed issues that affect everyday fuel quality issues for fuel retailers.

Alternative fuels such as biodiesel represent an important growth opportunity for fuel marketers nationwide. But for many fuel retailers, myriad state and federal regulations and incentives for alternative fuels can seem like a complex and almost overwhelming system to navigate. In addition, the growing number of fuel offerings and renewable fuel blending options makes fuel quality increasingly important from a product liability and customer retention standpoint.

To help fuel retailers leverage the resources necessary to learn about and incorporate alternative fuels into their supply offerings, NATSO, the national trade association representing travel centers and off-highway fuel retailers, in mid-June launched the Alternative Fuels Council (NATSOAltFuels.com).

Designed to satisfy our industry’s need for expert, convenient and cost-effective solutions that will help bring alternative fuels to market, the Alternative Fuels Council works with all members of the fuel marketing industry to navigate the litany of state and federal fuel regulations and to utilize available government incentives for alternative fuels, including the RFS and state and federal tax credits. The Alternative Fuels Council also helps its partners implement profitable strategies related to alternative fuel supply options and fuel infrastructure.

Among its initial offerings, the Alternative Fuels Council unveiled a biodiesel Fuel Quality Plan designed to help those who blend, market and distribute biodiesel blends ensure the final product that they sell to consumers meets a minimum standard of quality. To assist with new and existing supply relationships, the Alternative Fuels Council will help facilitate fuel testing and analysis for marketers.

There are a number of financial incentives for marketers to incorporate renewable fuels into their supply offerings. For any credits or incentives to be viable, however, the fuel must meet certain ASTM fuel quality standards. If the fuel does not meet these standards and a credit is claimed, then the claimant is open to severe compliance penalties.

While biodiesel producers and ULSD suppliers can provide certain accreditations and quality assurances, the blender must understand that a certificate of analysis rarely represents the actual gallons being purchased. It is imperative that the blender or marketer remains vigilant regarding the quality of the unblended and blended product. To do this, the marketer must consider each step in the blending process and how to mitigate any negative outcomes to their business, while at the same time taking advantage of the incentives that blending fuel has to offer. The Alternative Fuels Council’s Fuel Quality Plan provides further insight into each element of the blending process and delivery to customers, critical points for fuel quality management including sampling procedures, protocols and proposed schedules. This guide also includes cost-saving suggestions for analytical sampling, which the Alternative Fuels Council has negotiated on behalf of its clients and NATSO members. Fuel sampling, prior to blending and post-blending, is at the core of the Fuel Quality Plan.

The Alternative Fuels Council’s Fuel Quality Plan addresses many market factors that impact biodiesel and diesel fuel quality and provides fuel quality guidance in the following areas.

Purchasing: Many biodiesel producers today use different streams of feedstock rather than a single stream. Feedstock streams influence cold weather properties and therefore the quality of fuel. The Alternative Fuel Council’s Fuel Quality Plan outlines various accreditation programs, the EPA’s Quality Assurance Program for RINs, and the importance of a certificate of analysis.

Transporting: The chain of custody dictates who is responsible for fuel quality. If a producer or supplier is also maintaining custody until the product has been delivered, then this allows the buyer to test the fuel prior to taking possession of the product. The Fuel Quality Plan addresses a number of transportation challenges. 

Storage: B100 is a solvent and therefore may loosen or dissolve varnish and sediments in fuel tanks and systems that petroleum diesel has left over time. The Fuel Quality Plan provides a number of housekeeping and maintenance tips related to fuel storage, temperature considerations, equipment compatibility and federal underground storage tank regulations.

Blending: Blending can take place by an upstream supplier or distributor or can be completed downstream by a petroleum retailer. The Fuel Quality Plan provides guidance on splash, terminal or rack blending, and on-site blending equipment. 

Dispenser Labeling: There are a number of federal and state labeling requirements associated with different blends of biodiesel. The Fuel Quality Plan provides guidance on these requirements.

Sampling Protocols: The best way for a fuel marketer to stand behind their fuel quality is through regular and ongoing testing of the fuels they are purchasing and the final blends being sold. But testing fuel can be expensive and time-consuming. The Alternative Fuels Council has partnered with a BQ-9000-certified fuels lab for a fuel quality check sample regiment at a substantially discounted price. This allows participants to sample their supply more frequently and minimize exposure to consumer complaints and regulatory violations.

The Fuel Quality Plan is available to blenders at no cost and is designed to be easily implemented by single-location or large-chain operators. Biodiesel has a tremendous capacity to expand in the U.S. and it is our goal to do this safely and most efficiently with best practices and close oversight.
 
Author: Jeff Hove
Vice President, Alternative Fuels Council
703-739-8560
jhove@natsoaltfuels.com