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EPA Issues Draft GHG Analysis For Production and Transport of Jatropha Oil

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Source: Bergeson & Campbell, P.C.

On October 13, 2015, the U.S. Environmental Protection Agency (EPA) issued a notice inviting comments on its analysis of the greenhouse gas (GHG) emissions attributable to the production and transport of jatropha curcas (jatropha) oil feedstock for use in making biofuels such as biodiesel, renewable diesel, jet fuel, naphtha, and liquefied petroleum gas. This notice was issued as a result of two petitions: (1) Global Clean Energy Holdings’ and Emerald Biofuels, LLC’s petition pursuant to the petition process for evaluation of new renewable fuels pathways, 40 C.F.R. § 80.1416, requesting that EPA evaluate the lifecycle GHG emissions for biofuels (biodiesel, renewable diesel, jet fuel and naphtha) produced from the oil extracted from jatropha oil, and that 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; and (2) Plant Oil Powered Diesel Fuel Systems, Inc.’s petition 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.

In response to these petitions, EPA:

  • Conducted an evaluation of the GHG emissions associated with the production and transport of jatropha oil when it is used as a biofuel feedstock, and is seeking public comment on the methodology and results of this evaluation; and
  • Conducted an evaluation of the GHG emissions associated with the feedstock production and feedstock transport stages of the lifecycle analysis of jatropha oil when it is used to produce a biofuel, including the indirect agricultural and forestry sector impacts. EPA is also seeking public comment on the methodology and results of this evaluation.

Based on this analysis, EPA stated that it anticipates that biofuels produced from jatropha oil could qualify as biomass-based diesel or advanced biofuel if typical fuel production process technologies or process technologies with the same or lower GHG emissions are used.

If appropriate, EPA will update its evaluation of the feedstock production and transport phases of the lifecycle analysis for jatropha oil based on comments received in response to this action. EPA will then use this feedstock production and transport information to evaluate facility-specific petitions that propose to use jatropha oil as a feedstock for the production of biofuel. In evaluating such petitions, EPA will consider the GHG emissions associated with the production and transport of jatropha oil feedstock. In addition, EPA will determine -- based on information in the petition and other relevant information, including the petitioner’s energy and mass balance data -- the GHG emissions associated with petitioners’ biofuel production processes, as well as emissions associated with the transport and use of the finished biofuel, and will then combine its assessments into a full lifecycle GHG analysis and determine whether the fuel produced at an individual facility satisfies Clean Air Act renewable fuel GHG reduction requirements.

Comments are due November 13, 2015 (30 days from Federal Register publication).

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