Posts Tagged ‘RFS 2’

Producers must re-register plants under RFS2

Sunday, February 28th, 2010

Buried in the middle of the RFS 2 regulations published in February by the EPA are the new requirements for producer program registration. The rules as posted are only the proposed modification to 40 CFR 80, pending publication of the final regulations in the Federal Register, a legal requirement for final adoption.

If you are not already aware, even if your facility was registered under the first version of RFS, it must re-register prior to July 1, 2010 to participate under the auspices of the new program.

The new producer registration requirements are detailed in a densely packed section of the 120 page document.

Occupying roughly four (4) pages, the requirements include a description of the type of fuels produced at the facility (or possibly produced with little modification to the production process),  feedstock used in the production process, the co-products produced with each fuel type,  and the submission by a state licensed, third party, chemical engineer the results of a careful review of your facility process and capacity expectation.

These requirements come at a time when producers are particularly sensitive to issues surrounding cash flow and operating costs, and expenses like a third-party engineering review may seem ill-timed.

RFS 2 participation is important to us here at Promethean. It is a personal initiative for me and I am focused on preparing us to meet the July start date.

There still exists a subset of mysteries whose answers are yet to be revealed by the EPA regarding what the EPA will specifically require as an ultimate demonstration of conformance.

I hope clarity is imminent.

Make it a better place,

Todd

On biodiesel, feedstock, and production as a service.

Monday, February 8th, 2010

This week the National Biodiesel Boards annual conference will be held in Texas.

With last week’s release of the EPA’s final rules related to RFS 2, a biodiesel mandate will be in place this year.  I suppose a good deal of time will be spent discussing the mandate, the future of renewable identification numbers (RINS), and the current situation with the lapsed excise tax credit.

But whether or not a new mandate is in place or the excise tax credit returns, the core industry problem remains; feedstock.

The life blood of any biodiesel production plant is feedstock. Whatever the feedstock, be it virgin vegetable oil, yellow or brown grease, or animal tallow, in general it must be tracked and prepared for its future conversion to methyl esters.

Feedstock represents the majority of the cost of operation, and its secure and consistent acquisition is a daily challenge. Preparing the oil in a way that facilitates its consistent conversion requires the development and maturation of a carefully coordinated system of processes and practices that allow incoming oil to be collected, cataloged, tested, categorized, filtered, de-watered, neutralized, at times blended, and stored prior to processing.

Promethean is fortunate to have a relatively large facility space, but early  decisions made about our approach to storage has meant that the focus here is on high throughput.

It is easy to build excessive capacity in the biofuels arena and it is more important to conserve cash at startup than to spend it on potential future capacity. The issue here is that we have recently been approached by groups or organizations that want us to stretch the limits of our capacity. Although I am a proponent of service delivery based on just in time manufacture, in this industry issues related to transportation are relatively common, and it is best to have a cushion for problems that may arise from timing or the myriad other things that can interfere with the scheduled drop off of feedstock or pick up of finished product.

I am not conservative. I am a risk taker. The proof of the latter is my participation in this industry.

Feedstock prices in California remain high, and may remain so over the next few months.

At Promethean we view the production of biodiesel first and foremost as a service. This view means that we must constantly explore ways to add value to our customers as well as reduce the costs related to production. Focusing on manufacturing as a service has other consequents as well, some yet to be discovered.

As it stands, an increased level of vertical integration is required in our collection approach and infrastructure, since it is obvious that without the ability to obtain some percentage of the feedstock required for production we cannot sustain-ably render our services in the long term.

Problems are opportunities, and the feedstock problem for a plant of our scale is easily solved with hard work, a commitment to service, and time.

Make it a better place!

Todd

The first post of the new year!

Wednesday, January 13th, 2010

2010. A new year. Almost everything seems possible; everything except the passage of the biodiesel blenders credit renewal.

Everyone I have spoken to seems certain that the credit will be reinstated in a retroactive fashion. I’m pretty certain.

In an interview published in the Wisconsin Ag Connection Michael Frohlich, the NBB’s Director of Federal Communication, was quoted as saying “Pretty much every plant is idle.”

Strangely enough, things do not feel very idle at Promethean. I believe the same may be true for the majority of small poducers I have spoken to.

Oil prices seem to have remained steady.

The big news is related to RFS2. I called the EPA on Monday in the hopes of getting an updated status on the progress of the rulemaking as well as some sort of advanced information on what may be included that would interest the biodiesel industry. I received nothing more than a statement that sounded pre-canned saying that the rules would be out soon. The rest was classified, or as close to classified as the EPA gets.

RFS2 is potentially an industry game-changer. Optimistic estimates place final rule implementation sometime in the Spring of 2010.

We have been working on MRU’s (Methanol Recovery Units) this month, primarily on design/build projects for other plants.

Strangely enough I almost always fall in love with the things we build, and really hate seeing them go into service somewhere else. So much time and energy goes into the design and fabrication, and we view our equipment not only in the sense of its utility and efficiency of performing its function but also as a quasi-artistic endeavor and the opportunity to demonstrate good old-fashioned American ingenuity.

This year, with all its promise, may be more challenging for the biodiesel industry than the last.

RFS 2 will bring new compliance challenges, and organizations will need to adapt their business processes appropriately. Lack of a tax credit may make it difficult for existing producers to maintain profitability, or maintain staffing levels. It may alos be an opportunity for new entrants to carve out a niche in makets that may have been dominated by large but credit dependent competitors.

Only time will tell.

Make it a better place!

Todd

RFS 2 Rumour Mill

Wednesday, November 11th, 2009

The EPA is getting closer to final decision making related to the new set of rules slated for implementation in RFS 2 (renewable Fuel Standard v2).

Rumors abound, but I do have some interesting tidbits related to some of the biodiesel producer requirements that seem sure to become fact.

The first is that biodiesel producers everywhere will be required to re-register their facilities.  This re-registration may require a plant engineering review, ostensibly to ascertain the ability of a plant to actually produce ASTM quality fuel. This requirement may also be an attempt for the EPA to regain a certain amount of credibility as well as limit the currently overwhelming number of new producer registrations.

Another item that seems to be the next sure thing is that the future EPA hosted RIN tracking system will be added as a module to the current Central Data Exchange (CDX) registry system. I would suggest that any producers out there may want to check the accuracy of their CDX records sooner rather than later.

Make it a better place.

Todd