Beta Public Comment: EPA Proposed Protocol on Biofuels

In its public comment submitted to the U.S. EPA, Beta Analytic recommends the use of ASTM D6866 to determine the biogenic fraction of fuels derived from biomass. Beta points out that ASTM D6866 can precisely and accurately quantify the biogenic fraction of any type of fuel derived from biomass and blended fuel mixtures that contain both fossil and biomass fuels.

Excerpts from Beta’s Public Comment submitted on May 12, 2009:

In Section V, Subpart MM (Suppliers of Petroleum Products – pages 16569 to 16575) of the proposed greenhouse gas reporting protocol, the EPA solicits comments on how to better quantify the biogenic fraction of fuels derived from biomass. There is a readily available method called ASTM D6866 that can precisely and accurately quantify the biogenic fraction of any type of fuel derived from biomass and blended fuel mixtures that contain both fossil and biomass fuels.

The ASTM D6866 method is already adopted in the current reporting rule under the Tier 4 sampling protocol for municipal solid waste (pages 16636 to 16639). The EPA should broaden the use of this method for all biomass-derived fuels and blended fossil and biomass fuel mixtures since municipal solid waste is, in essence, a heterogeneous fuel with biomass and fossil components.

We believe that the ASTM D6866 method should be allowed for all heterogeneous fuels (i.e. those that contain a biomass fraction), not just municipal solid waste as cited in the current EPA reporting rule. The ASTM D6866 method would be ideal for determining precisely and accurately the biomass carbon fraction of fuels under the requirements of Section V, Subpart MM of the proposed greenhouse gas reporting rule.

We would also like to mention that the ASTM D6866 is the only analytical method that can determine the biomass carbon fraction of fuels that are chemically identical. For example, synthetic ethanol made from fossil fuels is chemically indistinguishable from bio-ethanol made from a biomass feedstock. ASTM D6866 is the only method that can determine precisely the percentage of biogenic carbon in ethanol samples. The same holds true for methanol from biomass and fossil fuel sources. In a similar light, the ASTM D6866 method can help resolve biomass fraction ambiguities in complex fuel mixes such as Hydrogenation-Derived Renewable Diesel (HDRD).

To further add weight to our argument that ASTM D6866 should be allowed in the greenhouse gas reporting rule to determine the biogenic carbon fraction of biomass-derived fuels, we are including three links of recently published research notes on the carbon-14 technique for these types of fuels. As can be seen from these research notes, the carbon-14 method works very well in determining the biomass fraction of fuels.

Dijs, Ivo J; van der Windt, Eric; Kaihola, Lauri; van der Borg, Klaas. QUANTITATIVE DETERMINATION BY 14C ANALYSIS OF THE BIOLOGICAL COMPONENT IN FUELS. RADIOCARBON, Vol 48, Nr 3, 2006, p 315-323.

http://digitalcommons.library.arizona.edu/objectviewer?o=http://radiocarbon.library.arizona.edu/Volume48/Number3/315-323.pdf

Reddy, C.M., J.A. DeMello, C.A. Carmichael, E.E. Peacock, L. Xu, and J.S. Arey, Determination of Biodiesel Blending Percentages Using Natural Abundance Radiocarbon Analysis: Testing the Accuracy of Retail Biodiesel Blends, Environmental Science & Technology 2008 42 (7), 2476-2482.

http://pubs.acs.org/doi/abs/10.1021/es071814j

Lastly, it must be mentioned that ASTM D6866 is an accepted method for measuring the biomass fraction of fuels in the Australian, European Union, and other regional greenhouse gas protocols, such California’s AB 32 and the Western Climate Initiative.

Beta’s public comment can be found in Regulations.gov Document ID EPA-HQ-OAR-2008-0508-030.

This entry was posted on Tuesday, May 12th, 2009 and is filed under Beta Analytic in North America, Beta Analytic Updates, Biofuels .