RFS2 in the Real World

By Joe Jobe | August 19, 2009
We know RFS2 is at a critical juncture that will certainly impact the face of our industry. We know that implications of the rule making process will have a direct and measured impact on our industry for years to come. Ensuring the RFS2 is implemented in a workable fashion tops the National Biodiesel Board's list of priorities.

The RFS2 was always intended to be a "safety net." The sad truth is that, right now, it would be more like a "lifeline" if only it were in place.

But what does it matter beyond production levels, outside Biodiesel Magazine readers, and aside from feedstocks? What is RFS2 in the real world? How does it impact the Americans who have chosen to make biodiesel their fuel of choice and, in turn, what does it do to the progress we've made on national energy security?

To find the answer to those questions, I returned to our roots and visited with one of biodiesel's longest-standing customers. More than 15 years ago, North Carolina's visionary fleet managers started looking into biodiesel as a reliable alternative fuel, and as a solution to reduce air pollution. Today the state is home to one of the largest biodiesel-powered fleets in the country.

The state needed to cut emissions, and biodiesel was the only thing that made sense according to Drew Harbinson, director of the North Carolina Department of Transportation Equipment and Inventory. He told me, "it was the most effective and easiest way to transition to an alternative fuel."

North Carolina first used B20 in select areas, and then in all non-attainment counties. Three years ago it expanded to statewide use of biodiesel blends.

Of the DOT's 23,000 pieces of equipment, 8,000 are powered by B20. Among the 8,000 is every single diesel-powered vehicle and piece of support equipment except standby generators. In a normal year, the fleet burns 11 million gallons of B20.
As strong biodiesel advocates, the people of North Carolina have stood up to would-be challenges. In the early part of this decade, the state worked with North Carolina State University for a research project on real-world duty cycles to test NOx emissions. That study showed a drop in measured NOx emissions and helped drive current accepted conclusions that NOx change can be assumed neutral. From the program's beginnings they have also had a tight watch on quality and now require the state fuel contractor to be BQ-9000 certified. Now they are watching the EPA closely for fear their success is about to be derailed.

The EPA has proposed requiring a minimum level of certain types of feedstocks in all gallons of biodiesel and has proposed one of the most complicated and costly certification and tracking programs imaginable. The result would be the distortion of markets and a costly and burdensome compliance program. All of this would be aimed at ensuring a feedstock mix that would most likely occur anyway in overall volumes based on price, region and availability.

"I see [the proposed rule] driving costs up to double the 30 cent [premium] we currently pay," Harbinson said. "It's going to have a real negative impact on the growth of the industry-I don't see how it can't. Fewer producers will drive the price up further. At that point you have significantly increased the price of the fuel, and we would have to rethink our approach."

"Rethinking" for some fleets could mean a return to petroleum, which is exactly what the RFS is intended to discourage.

"The good we've done with our own fleet, the millions of tons of carbon reduction is significant," Harbinson pointed out. "You can make a significant impact on air quality."

In the real world, biodiesel's future impact on air quality will depend on how the EPA's final rule calculates biodiesel's greenhouse gas impact, and will determine whether fleets like those in North Carolina can continue using biodiesel, an alternative fuel that has been working for them for more than a decade.

We cannot possibly know where this industry will be in six months, but we are working tooth and nail to ensure that North Carolina and the many thousands of biodiesel users there retain access to the renewable fuel that works.

Visit our RFS2 Action Center (http://www.biodiesel.org/news/RFS/) if you haven't already, and send your comments to the EPA today. Your input will make an impact on the final rule, and ensure that biodiesel is a part of our nation's "real world" energy plan.

By Joe Jobe
National Biodiesel Board CEO
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