The wait for canola oil as a U.S. EPA-approved biofuel pathway is over. Five months after releasing the final rule for the revised renewable fuel standard (RFS2), the EPA released a Notice of Data Availability, stating that the canola oil biodiesel pathway creates a 50 percent reduction in greenhouse gas emissions compared to the diesel fuel baseline. Using the same RFS2 lifecycle analysis modeling for other biofuels already approved, the EPA also compared canola oil conversion efficiencies to biodiesel produced from soybean oil. Not surprisingly, the final analysis shows one pound of canola produces 0.40 pounds of oil compared to soybean's 0.18 pounds of oil.
EPA also created a Delayed RINs provision. "This proposed provision…would apply only to those producers who use canola oil, grain sorghum, pulpwood or palm oil to produce renewable fuel, only for renewable fuel produced in 2010," EPA said. Noting a current annual capacity of canola-based biodiesel production of 226 million gallons, spread between Archer Daniels Midland Co., Imperium Renewables Inc., Western Dubuque Biodiesel LLC, Inland Empire Oilseeds and Sun Power Biodiesel, EPA indicated the amount of canola-based biodiesel produced in 2009 was roughly 35 million gallons, down from 96 million gallons in 2008.
Even with the possibility of generating delayed RINs in 2010, Dale Thorenson, assistant director for the U.S. Canola Association, said he believes no producers will opt to create delayed RINs for canola biodiesel. "Producers large and small have had to stop production due to lack of demand since biodiesel buyers are unwilling to take the risk that canola might not qualify," Thorenson said. "There may be increased use of canola," he also added, "because some biodiesel plants that are regionally located far from soybean supplies (West Coast) will increase production from canola oil to meet the RFS2 mandates."
Regardless of 2010 canola-based biodiesel production amounts, EPA estimates that by 2022, there will be 200 million gallons of biodiesel coming from canola per year. To create this projection, the EPA used a number of factors including historical volumes, potential feedstock availability and competitive uses, potential increases in both crop acreage and yields. By 2022, EPA projects 0.9 million acres of canola will be harvested, but with increased canola-based biodiesel production, harvest totals will equal 1.2 million acres. In 2008, canola crop yield equaled 1,461 pounds of seed per acre, and in 2022, the projections used for the 200 million gallon estimate show a crop yield equal to 1,681 pounds per acre.
Higher yield improvements, which could show a greater reduction of land use impacts and improve projected GHG performance, were given to EPA by industry members but not used. Thorenson said he believes EPA used fairly conservative yield trends and oil content data in the lifecycle analysis.
Barring any changes coming from a 30-day comment period, canola is the first of several fuel pathways not included in the original RFS2 decision. Other pathways, particularly palm oil and pulpwood, which the EPA said were not being analyzed before the RFS2 came out, should be completed before the end of 2010. Currently, the only way a feedstock such as palm oil or jatropha can qualify for RFS2, is through the grandfathering provision. While the EPA would not speculate on the analysis of new pathways, palm oil modeling is expected to come out mid-November.
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