US EPA publishes direct final rule for camelina RFS2 pathway
January 5, 2012
BY Erin Voegele
On Jan. 5, the U.S. EPA issued a direct final rule regarding RFS2 pathways for four new biofuel feedstocks, including camelina oil, energy cane, giant reed and napiergrass. While the energy cane, giant reed, and napiergrass pathways apply to ethanol and drop-in biofuels, the camelina pathway applies specifically to biodiesel and renewable diesel production. This includes jet fuel and heating oil. The rule was published in the Federal Register on Jan. 5, and is scheduled to become effective on March 5, unless the EPA receives adverse comments or a hearing request by Feb. 6.
According to information published by the EPA in the rule, approximately 50,000 acres of camelina are currently being cultivated in the U.S. Most of this production is centered in Montana, eastern Washington, North Dakota and South Dakota. The EPA also noted that trial plots of the crop have been cultivated in 12 states.
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To analyze the life-cycle greenhouse gas (GHG) emissions associated with the camelina, the EPA noted that production patterns for the feedstock are likely to focus on the use of camelina as a rotation crop that is grown on acres that would otherwise remain fallow. For this reason, the EPA determined that additional acres of land would not be brought into production to support cultivation of the crop, and that camelina planting would not displace other crops. In fact, the EPA estimates that at current yields of approximately 800 pounds per acre, nearly 100 million gallons of camelina-based renewable fuels could be produced with the crop grown in rotation with others, without resulting in any direct land use change impacts.
As far as converting camelina oil into biodiesel, the EPA said that the lifecycle GHG emissions are highly similar to those associated with soy biodiesel. The agency also said in the rulemaking that camelina biodiesel will meet the 50 percent GHG reduction, thereby allowing it to qualify as both biomass-based diesel and an advanced biofuel. Regarding the converstion of camelina oil into renewable diesel, including biojet and heating oil, as well as naphtha and liquefied petroleum gas (LPG), the EPA said all of these biofuel products would meet the 50 percent GHG reduction threshold, qualifying it as an advanced biofuel.
The rule also adds esterification as a new production process that can be used as a production pathway to produce biodiesel using specified feedstocks. According to the EPA, it believed there was some ambiguity that stemmed from the fact that the pathway for biodiesel from biogenic waste oils, fats and greases used an esterfiication pretreatment process, but that esterification was not stipulated as a qualified production process. As a result, the EPA has clarified that esterification is a qualified process by which to produce biodiesel.
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The EPA also made several additional small changes to the RFS2 program in the rule. For example, it has added ID letters to pathways to facilitate references to specific pathways. It has also added “rapeseed” to the existing canola oil pathway.
The National Biodiesel Board spoke out about the rule, noting it is pleased with the changes. “As it has with other biodiesel feedstocks such as animal fats, recycled cooking oil, soybean oil and canola oil, the EPA's proposal shows that biodiesel produced from camelina oil reduces greenhouse gas emissions by at least 50 percent compared with diesel fuel,” said Anne Steckel, NBB’s vice president of federal affairs. “This is good news for our industry and will give biodiesel plants another tool in the toolbox as they continue producing record quantities of America's Advanced Biofuel.”
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