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EPA: jatropha-based biofuels could qualify as biomass-based diesel or advanced biodiesel under RFS

Based on its analysis of the production and transport components of the lifecycle greenhouse gas emissions of biofuel made from jatropha oil, the US EPA anticipates that biofuels produced from jatropha oil could qualify as biomass-based diesel or advanced biofuel under the Renewable Fuel Standard program if typical fuel production process technologies or process technologies with the same or lower GHG emissions are used. EPA has published its analysis in the Federal Register and is inviting comment.

Background. The RFS regulations lists three critical components of an approved fuel pathway: (1) Fuel type; (2) feedstock; and (3) production process. EPA uses lifecycle analysis to assess the overall greenhouse gas (GHG) impacts of a fuel throughout each stage of its production and use.

EPA uses the results of these analyses, considering uncertainty and the weight of available evidence, to determine whether a fuel meets the necessary greenhouse gas reductions required under the Clean Air Act (CAA) for it to be considered renewable fuel or one of the subsets of renewable fuel.

EPA received a petition from Global Clean Energy Holdings (GCEH) submitted under a claim of confidential business information (CBI), requesting that EPA evaluate the lifecycle GHG emissions for biofuels (biodiesel, renewable diesel, jet fuel and naphtha) produced from jatropha oil. The petition also requested EPA provide a determination of the renewable fuel categories, if any, for which such biofuels may be eligible under the Renewable Fuel Standard (RFS) program.

EPA also received a separate petition from Plant Oil Powered Diesel Fuel Systems, Inc., submitted under a claim of CBI, requesting that EPA evaluate the lifecycle GHG emissions for the use of neat jatropha oil as a transportation fuel, and that EPA provide a determination of the renewable fuel categories, if any, for which such neat jatropha oil fuel may be eligible.

Analysis. EPA evaluated the GHG emissions associated with the production and transport of jatropha oil for use as a biofuel feedstock based on information provided in the GCEH petition and other data it gathered.

Based on information from GCEH petition, literature review and expert consultations, EPA concluded that southern Mexico (the states of Yucatan, Oaxaca and Chiapas) and northeastern Brazil are the likely locations for commercial-scale production of jatropha for use in making biofuels for the RFS program.

EPA then evaluated two scenarios:

  1. Jatropha production on grassland in southern Mexico and northeastern Brazil that is not currently being used for crop production or pasture use. EPA estimated that estimate that on average the GHG emissions attributable to jatropha oil extracted from jatropha seeds grown on unused grasslands in southern Mexico are 951 kg CO2e) per tonne of jatropha oil that has been harvested, extracted, pre-treated to lower acidity and delivered to a biofuel producer (“delivered jatropha oil”), compared to 1,425 kg CO2e per tonne of delivered soybean oil.

    If jatropha is grown on grassland in northeastern Brazil that would not otherwise have been used for crop production or grazing, EPA estimated that the GHG emissions would be 1,858 kg CO2e per tonne of delivered jatropha oil. Land use change emissions are higher in northeastern Brazil than in Mexico because, on average, grasslands in northeastern Brazil sequester significantly more carbon than grasslands in southern Mexico.

    EPA evaluated a scenario in which it assumed an equal amount of growth on grasslands in southern Mexico and northeastern Brazil. In this scenario, the GHG emissions are 1,404 kg CO2e per tonne of delivered jatropha oil, which is still lower than the emissions attributable to delivered soybean oil.

  2. Jatropha grown on land that would have otherwise been used for agriculture (crop production or grazing/pasture).

    EPA ran two analyses within this scenario: one assuming that jatropha will displace crops (predominantly corn) in Mexico, and one where jatropha is grown on cropland in Mexico and on agricultural land in Brazil (with the model choosing what land to displace in Brazil).

    The second scenario, where jatropha is grown on land otherwise used for agricultural production, evaluates the impacts associated with jatropha displacing crop and pasture land, including evaluating whether and where increased crop production or pasturage would occur in other regions to compensate for the jatropha displacement.

    For the Mexico cropland analysis, EPA estimated GHG emissions of negative -721 kg CO2e per tonne of delivered jatropha oil. The net GHG emissions in this analysis are negative primarily because jatropha sequesters more carbon than the cropland it displaces and the indirect emissions are relatively small because the displaced corn production is backfilled by higher yield producers (e.g., corn production in the United States).

    For the Mexico and Brazil analysis, the net GHG emissions are 128 kg CO2e per tonne of delivered jatropha oil, which is also significantly less than the emissions per tonne of delivered soybean oil.

Based on those outcomes, EPA applied the GHG emissions estimates already established for the production and transport of soybean oil to jatropha oil when evaluating future facility-specific petitions from biofuel producers seeking to generate RINs for volumes of biofuel produced from jatropha oil.

Jatropha oil is suitable for the same conversion processes as soybean oil and other previously approved feedstocks for making biodiesel, renewable diesel, jet fuel, naphtha and liquefied petroleum gas. In addition, the fuel yield per pound of oil is expected to be similar for fuel produced from jatropha oil and soybean oil through these processes, EPA noted. Jatropha may also be suitable for other conversion processes and types of fuel that EPA has not previously evaluated.

Based on our evaluation of the lifecycle GHG emissions attributable to the production and transport of jatropha oil feedstock, EPA anticipates that fuel produced from jatropha oil feedstock through the same transesterification or hydrotreating process technologies that EPA evaluated for the March 2010 RFS rule for biofuel derived from soybean oil and the March 2013 RFS rule for biofuel derived from camelina oil would qualify for biomass-based diesel (D-code 4) RINs or advanced biofuel (D-code 5) RINs. However, EPA will evaluate petitions for fuel produced from jatropha oil feedstock on a case-by-case basis.

—EPA

The D-code (D#) of a RIN identifies the renewable fuel standard category for a particular fuel based on its projected greenhouse gas reduction requirement. EPA currently has five RIN D-codes (D3, D4, D5, D6 and D7). D3 and D7 are for cellulosic biofuels with a GHG reduction requirement of 60%; D6 is for corn ethanol (GHG reduction 20%); D4 is for biomass-based diesel (50% GHG reduction); and D5 is for advanced biofuels, including sugarcane ethanol and biogas (50% GHG reduction).

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