Posts Tagged ‘environment’

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I TOLD YOU SO!

March 22, 2014

I’ve been waiting for the “I told you so” moment, so I could stop writing about this lunacy.

An article in the Well Servicing Magazine a couple of months ago, probably one among many because I haven’t done much research on this topic lately, sums it up pretty well. (Pun intended) The Renewable Fuel Standard (RFS) in EISA 2007 is imploding. After a search of the Internet I can’t even find where the EPA finalized this years ethanol blending quota, which was supposed to be set by the end of December last year. They don’t even follow their own rules. Here is the EPA proposed 2014 RFS and it is indeed the 2012 quota, but I can’t locate the finalized version.

As any fool could have seen, the constantly increasing quota to blend ethanol in gasoline was unsustainable. And finally this year, the EPA, which has sole authority to set the blending quota, blinked. Instead of increasing the quota as proscribed in the blending table embedded in the act, they decreased mandatory blending levels.

WE HIT THE BLENDING WALL

I doubt there is anywhere to go from here. Without producing copious amounts of E85, which isn’t going to happen, there is no way to fulfill the ethanol blending quota table in the RFS. E15 was dead on arrival when the EPA made it voluntary. The auto producers have wisely refused to warranty their products for anything above E10 in a non flex-fuel vehicle car. Producers and gas station chains will not sell it because they can’t afford the liability. Congress isn’t about to give them a liability waiver. If anything, Congress is trying to repeal the RFS.

On top of everything else, corn ethanol production would be capped next year anyway, so there is no use building more plants. There will be no increase in production, unless they can export it. Cellulosic ethanol was supposed to carry all of the increased ethanol production burden demanded by the quota table, but there are no commercially viable cellulosic ethanol plants, and without a market, which would have been available if E85 took off, there is no incentive to even try to perfect a process, unless it can be produced at a lot less cost than corn ethanol, which appears unlikely after three decades of trying.

I just hope the grownups in the EPA and the Congress will end this charade. Hmmm, “grownups” used in the same sentence as EPA and Congress? Disregard that, because it’s an oxymoron.

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EPA DENIES RFS WAIVER

November 20, 2012

FULL SPEED AHEAD INTO THE BLENDING WALL!

On Friday, November 16, 2012, the EPA denied the waiver petition made by several states to drop mandatory ethanol blending as required by EISA 2007 for one year.  You can find the denial as quoted here, “Based on the entire record before it, EPA has determined that each of the petitions and requests should be denied.” in the EPA document.

This is what the waiver denial portends.  Even with the carry forward RINS, which are delaying the blending wall by maybe 20 billion gallons of E10 / year, by 2014, at the latest, the ethanol quota, cast in stone table, in EISA 2007 will swamp the gasoline pool and there will be nowhere to put the ever increasing ethanol quotas after that and the ludicrous E15 waiver will not delay this fact.

It was clear that the quota table in EISA 2007 was designed to produce Renewable Fuel, which is only defined as E85 in the act. OK, in one place in the act it is defined as E11 – E85, but it is NEVER defined as E10.  However, we produce a minuscule amount of E85 and that will not increase enough in the next few years to avoid the blending wall because of the massive infrastructure that would be demanded to distribute and sell it.  The fact that all of the gasoline in the U.S. is becoming E10 is an unintended consequence of EISA 2007 since E10 is NOT Renewable Fuel as defined by the act.

So here is a suggestion for the states that were denied the waiver.  Any state can prohibit the blending of ethanol in all of the gasoline in their state, except for those few mandatory oxygenate areas that are still left, which are a few big urban areas and most of Southern California.  There is no mandatory federal E10 law.  EISA 2007 certainly isn’t a mandatory E10 law, it is a Renewable Fuel law, and E10 is NOT Renewable Fuel as defined in the act.  So if a state can pass a mandatory E10 law, like my home state of Oregon did, useless as it is now, any state can clearly pass a law prohibiting E10 being sold in the state.  This would certainly accelerate hitting the blending wall thus exposing what a farce and sham the federal Renewable Fuel Standard really is.

Of course until such time as the congress critters repeal the federal RFS in EISA 2007, which they might do if they finally wake up and understand that it can’t possibly fulfill its intended purpose, the gasoline producers will have to deal with ever increasing quotas of ethanol with nowhere to blend it.  If the EPA is as obstinate as it is now with the cellulosic ethanol quotas that the gasoline producers must pay waiver penalties for a product they can’t buy, then the gasoline producers will have to do something with the ethanol they can’t blend.  I have a suggestion.  Start constructing large tank farms in Illinois, as near to ADM headquarters as possible, and the Iowa home of Senator Chuck Grassley, the champion of the RFS and the water boy for ADM.  Just store the billions of gallons of ethanol in their back yards, by 2022 you are going to have to be able to store about 15 billion gallons of the stuff every year that you can’t use.  You can just pass along the costs to us consumers just as you do with the millions of dollars in penalties for the cellulosic ethanol waiver credits.  I’m sure we won’t mind, because we certainly don’t mind that you must pay for a product you can’t even buy, and you are passing along the costs to us right now.

Oh, and by the way, the whole EPA waiver review was a complete farce.  Look on page 79 of the Notice, “The commenter failed to acknowledge that EPA is not required to issue a waiver when severe economic harm to a state, region or the United States is demonstrated. The statute provides that EPA “may” do so in that situation.”  Bazinga!  There was never the remotest chance in Hell that the EPA was going to grant the waiver.  I hope the states wake up and take matters into their own hands.  They have every opportunity to as outlined above, just ban E10 in your state.

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Is EPA Administrator Jackson Waiting For Someone To Die?

February 15, 2011

I sent the following email to EPA Administrator Lisa Jackson:

Dear Administrator Jackson:

The following post was left on the pure-gas.org web site in the Comments section:

“Recently our fire dept. was responding to a brush fire where the fire was about the get into a barn.  Our brush truck has a gasoline powered engine (which is almost new) in which we had a difficult time cranking to extinguish the fire.  Upon our investigation after the fire we found the cause of failure of the pump operating was due to ethanol gas.  The repair agency advised that we should not use ethanol gas on small engines due to this problem and that we should not store ethanol gas no more than 2 weeks.  Unfortunately we must store some gas for emergencies on fire apparatus for calls.  At some times it can be stored for quite some time before we use it.  How are fire dept’s suppose to operate equipment properly and store gas for emergencies with this causing engine problems?  Hope you don’t need to depend on this to save your life, the engine may not start???????  -Tony Collins, Advance, NC  (February 9, 2011)”

You can see it for yourself here:  http://pure-gas.org/comments, use the View all comments button to get to this earlier comment.

Are you going to wait until someone dies when portable equipment won’t start or quits during an emergency because of the unintended consequences of the RFS mandate in EISA 2007 that are turning all of the gasoline in the U.S. to E10?  As it stands now first responders and emergency crews cannot get ethanol free gasoline in California and most of the Northeast.  It is rapidly disappearing in the Northwest too, and it is apparently a serious problem in North Carolina.  I urge you to prohibit the blending of ethanol in all premium unleaded gasoline sold in the U.S., as you were requested by numerous organizations in the E15 comments, before someone is killed.

Regards — Dean Billing / Sisters, OR
www.e0pc.com
www.flyunleaded.com

I would urge others in the Public Safety field to let Administrator Jackson know if you have concerns about how the ethanol mandate is affecting your portable tools and equipment … before it is too late.  You can email her at jackson.lisap@epa.gov

Update 03/30/2011: Apparently the EPA is waiting for someone to die, as the following reply illustrates:

Dear Mr. Billing:

Thank you for your February 15, 2011 email to Administrator Jackson concerning the use of ethanol in gasoline and problems with small, non-road engines in emergency equipment. …

We are aware that some small, non-road engines are having problems with gasoline that contains 10 percent ethanol (E10). Furthermore, we have found that gasoline with 15 percent ethanol (E15) is not suitable for such engines.  As we transition to E10 and E15 we are monitoring the situation.  Please contact us if we can be of further assistance.

Sincerely,

Karl J. Simon, Director
Compliance and Innovative Strategies Division, Office of Transportation and Air Quality

So there you have it in black and white, “… we are monitoring the situation.

Translation from bureaucratese, “Yes, we are waiting for someone to die and if there is a public outcry, we will react.”

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E15 Will Make No Difference Now, Part II

September 7, 2010

Wonder when the EPA and the ethanol lobby are going to wake up?  If anyone ever bothered to read the RFS mandate in Section 202 of EISA 2007, which is driving all of this ethanol blending madness, they would find out that E10 or E15 is never mentioned in the act and that EISA 2007 is NOT A MANDATORY E10 law.  The RFS only deals with bio-diesel, E85 and flex-fuel vehicles.

So why all the  folderol over getting a waiver from the EPA for E15?  Because there is a huge problem buried in Section 202 (A) 2:  APPLICABLE VOLUMES OF RENEWABLE FUEL.  It is a hard coded table.  It outlines the volume of ethanol that must be produced and blended into gasoline by year:

Applicable volume of renewable fuel

Calendar year:                                   billions of gallons
2006 …………………………………………………………………… 4.0
2007 …………………………………………………………………… 4.7
2008 …………………………………………………………………… 9.0
2009 …………………………………………………………………… 11.1
2010 …………………………………………………………………… 12.95
2011 …………………………………………………………………… 13.95
2012 …………………………………………………………………… 15.2
2013 …………………………………………………………………… 16.55
2014 …………………………………………………………………… 18.15
2015 …………………………………………………………………… 20.5
2016 …………………………………………………………………… 22.25
2017 …………………………………………………………………… 24.0
2018 …………………………………………………………………… 26.0
2019 …………………………………………………………………… 28.0
2020 …………………………………………………………………… 30.0
2021 …………………………………………………………………… 33.0
2022 …………………………………………………………………… 36.0

Now keep in mind that the U.S. uses about 135-140 billion gallons of gasoline / year.  It has been in that range since the economic collapse started in 2008 and won’t likely rise in the foreseeable future unless the economy improves markedly.  If every drop of gasoline was E10, it would take, at most, 14 billion gallons of ethanol and the apparent advantage is that the refineries would only have to produce 126 billion gallons of gasoline so it appears we would use less oil, although nobody knows if that is actually true, since no one has done a large, statistically significant study of mileage before and after E10 is widely implemented.

Look at the table.  During 2012 the U.S. ethanol industry must produce more ethanol than can be put into all of the auto gasoline.  Clearly, after 2012 we are going to have ethanol coming out of our ears.  Are you beginning to understand why the RFS portion of EISA was clearly written for E85 and why the unintended consequences of the act are getting ugly?

So 2012 is the “Blending Wall” and in order for the ethanol industry to “delay” the blending wall while they try to get more taxpayer money out of Congress and state governments (which are going bankrupt, so not too likely) to add E85 infrastructure and get laws passed to force the auto industry to build more dinosaur “flex-fuel” vehicles, they figure the easiest way to delay the blending wall is to get the EPA to force gasoline companies to make E15 and force you to use it in your non flex-fuel vehicle.  And how long might that delay the blending wall?  Well, we would need 21 billion gallons of ethanol to take all of the gasoline E15, so the delay would be out to about 2016, maybe a four year delay, max.  But then we would still be at a blending wall.  Unless the U.S. starts making “Renewable Fuel”, which is E85, we are going to face a blending wall.

But it turns out there are a lot of niggling little details that need attention in order to actually implement the E15 waiver, if it is even granted.  The simple problems involve the EPA’s own set of rules about how they can go about raising the ethanol blending limit for non flex-fuel vehicles and they mainly involve a whole lot of testing.  That testing is beginning to indicate that E15 might be allowable in a range of cars, say 2007 and newer, perhaps 2001 and newer, but the testing won’t be finished for at least another couple of months, maybe more.  So the earliest that the EPA could grant some kind of waiver is looking like the end of 2010, leaving only two years until hitting the wall.

Now comes the real Gordian knot.  According to the API (American Petroleum Institute), the “evil foe” of the ethanol lobby, there are a few more hoops to jump through before you can actually foist E15 on an unsuspecting public.  They are outlined in this report.  The gist of the report is that it is going to take time, in some cases a long time, to implement E15, to say nothing of whether service stations are going to want to handle a new product with unknown liability, other than it will increase property damage.

I think the most ironic problem is that ethanol blending caps are built into a lot of state laws, as outlined in Appendix A of the report.  I live in Oregon, a mandatory E10 state.  The mandatory E10 law, passed in 2007 before the federal law passed, has infuriated a lot of our citizens.  But we are lucky in a way because embedded in that law is a 10% ethanol cap, so it is going to take a legislative change to remove the 10% limit, and this time we are prepared to fight, especially when you consider that the federal RFS mandate is supposed to be for “Renewable Fuel” which is E85.

In the final analysis though, we will be at the blending wall before E15 ever reaches the market, as I have predicted in past blogs.  It will be interesting to see the reaction of citizens when they can’t find ethanol free fuel anymore and the property damage increases and the economic impact to the aviation, marine and public safety industry spreads through an already fragile economy.

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Where Are The “Renewable Fuel” Cars?

April 28, 2009

Flex-Fuel Car Is An Oxymoron

“Renewable Fuel” is definde as E85 in the federal RFS mandate, EISA 2007.  So why doesn’t anyone make a “Renewable Fuel” car?  All we have are these bastardized Flex-Fuel vehicles that try to live in two worlds and don’t do either very well.  It all started out so car companies could get around the CAFE standards because flex-fuel vehicles had huge CAFE credits and big federal tax incentives, and when ethanol was $1 / gallon cheaper than gasoline, E85 was attractively priced even after your Yukon took a 30% mileage dive because it was just a regular gasoline engine with a big computer and bigger fuel injection rails.

Those days are gone.  But the ethanol quotas in EISA 2007 are hard coded, in ever increasing amounts, year after year until 2022.  The only way the ethanol is going to be used after about 2013 is if we have lots of cars that use E85.  So why isn’t anyone working of the design of engines that can efficiently use just E85, an engine with the high compression ratio that E85 allows and a computer that can figure the timing for that fuel.  If these engines were available for the car bodies people want, they should sell just as well as today’s cars that have engines that were never designed for ethanol.

Instead of raising the blending limit for non flex-fuel cars, why isn’t the ethanol industry demanding the solution that EISA 2007 was designed to do, E85 cars and the fuel delivery infrastructure to support them.  God knows that they got an incredible number of tax incentives in EISA 2007 to do just that.  So why are they putting their money on cramming E15 down our throats for cars and engines that were never designed for “Renewable Fuel”?  With all the negative publicity, property damage, lawsuits and possible deaths when public safety devices that have engines that were never designed to run on ethanol blended gasoline fail, you would think that the ethanol industry would be working on getting E85 car engines designed and E85 fuel delivery infrastructure in place for them.

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Ethanol Mandates, A Black Swan?

February 27, 2009

Nassim Taleb defines The Black Swan as “The Impact of the Highly Improbable.”  It has led me to the conclusion that the ethanol mandates of the states and especially the federal RFS mandate of EISA 2007 are a Black Swan.  Who could have predicted the negative economic impacts that are being caused by the misguided government manipulation of the gasoline market by forcing ethanol blending.

First, everyone should understand that ethanol blended gasoline on a mass scale should only be allowed in computer controlled, fuel injected cars.  It has no place in fixed jet, carbuerated engines, especially in humid environments.  This is why every state that passed a mandatory ethnol fuel law provided for the availability of ethanol free gasoline for certain engine applications, most notably marine and aviation use, antique and classic cars and motorcycles, snowmobiles and like recreational vehicles, and small engines used in stationary applications like generators and pumps and 2 cycle engines used in tools.  None of the states, except Missouri, made ethanol free gasoline easy to get, but all of the statutes have exemptions.  Missouri did the right thing and prohibited the blending of ethanol in premium unleaded gasoline so it was widely and easily available for everyone that needed it.  Be advised that there are only five states with active mandatory E10 laws, the rest of you have no exemptions and no protection.

Having said that, one must wonder what the federal politicians were thinking when they passed EISA 2007.  It contains a massive production quota that does not take into account what the annual gasoline consumption in the US might be.  Of course the entire RFS portion of the bill is predicated on a massive build up of Flex-Fuel cars and fueling infrastructure to support them.  But there was no guarantee when the bill went into effect in 2008 that the auto industry was going to embrace Flex-Fuel cars on a massive scale and gasoline dealers were going to install the expensive infrastructure to support them, especially considering that this created a chicken and egg scenario.  The gasoline distributors and stations would only add infrastructure if there were cars to buy E85, and Detroit would only build cars if there was demand created by the availability of cheap E85 pumped at omnipresent gas stations.  None of that is going to happen in this crumbling economy.  But the inflexibility in the federal statute is forcing the gasoline distributors to put the ethanol in every bit of gasoline that they can find, even though in a couple of more years they will crash into the “blending wall“.

The blending wall is truly a Black Swan.  But there are so many others.  One of the most ironic is the battle over the blender pumps which is causing states to be sued by the American Petroleum Institute for putting into effect laws governing the delivery of ethanol that they believed would economically benefit their citizens.  Now the citizens get to pay for the lawsuits.

The most  unfortunate Black Swans are the economic damage caused by pigheaded greed that could have been avoided had people in the ethanol and gasoline industry recognized that ethanol blended gasoline can cause property damage and should have only been allowed for computerized fuel injected cars.  But it appears that greed and the politicians ignorance got the best of them and now ethanol will be in all of the gasoline, and the only remedy for those who suffer damages is to sue.  The saddest Black Swans are the people put out of business who don’t have the economic clout to sue.  The problems with ethanol and boats and airplanes and 2 cycle engines, etc. have been known for a decade, yet nothing has been done to avoid the negative publicity and lawsuits.  This particular Black Swan could have been avoided by prohibiting the blending of ethanol in premium unleaded gasoline and labeling all gas pumps accurately as to ethanol content.  But then that is what a Black Swan is, the impact of the highly improbable.  I am indebted to Mr. Taleb for helping me understand the world I live in.

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Are You Ready For E15?

February 19, 2009

Minnesota was the pioneer in mandatory ethanol laws, the first state in the US to have a mandatory E10 law.  They want to be the first in the country with a mandatory E20 law.  According to 239.791, Minnesota Statutes 2007:

“Except as provided in subdivisions 10 to 14, on August 30, 2013, and thereafter, a person responsible for the product shall ensure that all gasoline sold or offered for sale in Minnesota must contain at least 20 percent denatured ethanol by volume.”

There are a couple of caveats in this law:

“(1) the commissioner of agriculture certifies and publishes the certification in the State Register that at least 20 percent of the volume of gasoline sold in the state is denatured ethanol; or”

Which means if E85 takes off big time in Minnesota, then this law would not trigger … not likely to happen.

“(2) federal approval has not been granted for the use of E20 as gasoline.”

There has to be an EPA air quality study to satisfy this requirement and car manufacturers must warrant their non flex-fuel cars to be able to use E20.

Federal approval is not proceeding smoothly.

Turns out that UL has given its blessing for regular gas pumps to vend E15, with caveats, but it appears E20 will need new approval.

Notwithstanding Minnesota’s bold leadership, there is another reason that higher ethanol blending will be coming to a service station near you in the foreseeable future, the dreaded “Blending Wall“, so others are pushing for raising the blending limit for non flex-fuel cars.  It was even discussed during the stimulus bill debate so recently signed.

Of course nobody is talking about the unitended consequences of raising the blending limit for non flex-fuel vehicles, and there is the crux of the matter.  All anyone ever talks about is cars.  But what about all of the other engine applications that use auto gasoline, like boats, airplanes, antique and classic cars and motorcycles, snowmobiles, ATVs, small engines both 2 cycle and 4 cycle, that are used in all kinds of tools and stationary applications.  How are they going to do on E15 or E20?

When is it going to dawn on the ethanol and gasoline industry that ethanol blended fuels should only be used in autos with computerized fuel injection systems.  It should not be used in any engine with a fixed jet carburetor.  That is why all of these other engines are exempted in states with mandatory ethanol laws.  The other problem is any vehicle with a fiberglass fuel tank.  There are already class action lawsuits for damage to boats with fiberglass fuel tanks and I have heard of damage in motorcycles and ultralight aircraft that had fiberglass fuel tanks.

You would think that the ethanol and gasoline industry would want to avoid the negative publicity from property damage that their products cause.  There is a simple answer.  Don’t blend ethanol in premium unleaded gasoline and label all of the pumps that have ethanol gasoline.  So far though, greed has triumphed over logic and the lawsuits and negative publicity will continue.

To get a sense of the urgency, google general clark e15 The ethanol industry has hired General Wesley Clark to be their poster boy.