Something has been bothering me quietly for a while and I think it's time to get it out there. I think it's unacceptable that, despite the fact that overall diesel consumption in the US is one-third that of gasoline, the biomass-based diesel carve-out in RFS2 is only 1/36 of the total 2022 volume requirement. What gives?

I understand those numbers are likely based on availability of soybean oil but I don't entirely buy that. Why? I have a couple of different reasons.

One, RFS2 has a mandate for 16 billion gallons of cellulosic biofuel by 2022. From a cost-effective and technological standpoint, there is no way that industry could even produce a small fraction of that today, but the idea is that the mandate will drive research and development so when the time comes, industry will be able to meet the demand. If there's a 16 billion gallon cellulosic ethanol mandate, on top of a de facto 15 billion gallon corn ethanol fuel standard, there is absolutely no reason why the biomass-based diesel carve-out should be so low.

Two, the biomass-based diesel carve-out is not specific to methyl esters, although clearly the only available fuel to meet any appreciable mandate is biodiesel. A biomass-based diesel mandate is technology and feedstock neutral. Therefore how much soybean oil is available is moot. In fact, how much fats, oils and greases are available is moot. Wood waste can be gasified and Fischer-Tropsched into biomass-based diesel and soy oil's availability has no bearing on that whatsoever.

If government and special interest groups think the U.S. can produce 16 billion gallons of cellulosic ethanol by 2022, then surely government and biomass-based diesel special interest groups ought to believe industry can produce a minimum of 5, 10, 15 or more billion gallons of combined methyl esters, renewable diesel, green diesel, biomass-FT diesel, etc. Such a requirement would help restart many of the idled biodiesel plants-U.S. biodiesel production capacity is nearly 3 billion gallons, yet actual production is a dismal fraction of capacity right now. It would provide meaningful goals to help give provide real, significant advancement in feedstock development.

Those who are lobbying for the biodiesel industry's interests need to step up the efforts and convince policymakers to dramatically increase the biomass-based diesel portion of the renewable fuels standard to jump start this industry, and get our national goal of energy independence back on track.