The Center for Environment, Commerce and Energy (CfECE) supports the use of palm oil.
We support palm oil as a food additive and as a fuel that can mitigate greenhouse gas emissions.
CfECE will pursue entrepreneurial activities involving palm oil production and distribution.
Determination of GHG contributions by subsystems in the oil palm supply chain using the LCA approach
With increasing attention on sustainable development, the environmental and social relevance of palm oil production are now important trade issues. The life cycle assessment (LCA) study of Malaysian oil palm products from mineral soils including palm biodiesel was aimed to provide baseline information on the environmental performance of the industry for drawing up policies pertaining to the sustainable production. The share of greenhouse gas (GHG) contribution by the various subsystems in the oil palm supply chain is considered here.
GHG contribution by the nursery subsystem was found to be minimal. In the plantation subsystem, the major sources of GHG were from nitrogen fertilizers, transport and traction energy. For the mill, biogas from POME was the major contributor if biogas was not trapped. Excluding contribution from upstream activities, boiler fuel and transport were the major sources of GHG in the refinery subsystem. In the biodiesel subsystem, activities for production of refined palm oil and methanol use were the most significant contributors.
A decidedly significant amount of the GHG emissions associated with the whole life cycle of the oil palm supply chain was from the agriculture stage in the plantation. Emissions were mainly from the use of fertilizers. Another source of GHG was from the biogas (methane) in the POME released in the milling process.
Efforts should be focused on reduction of GHG emissions within the control of the managers of the defined subsystems in the oil palm supply chain. Production of raw materials for use in the oil palm industry is beyond the management of the oil palm industry, although one mitigation option is through the implementation of green procurement. Salient recommendations for reduction of GHG can be summarized as follows:
Reduction of inorganic fertilizers by applying more organic nitrogen fertilizer. Returning the nutrient-rich slurry from the POME treatment to the field or applying compost (EFB+POME) as fertilizer, thereby reducing inorganic fertilizer application.
Judicious application of fertilizers using precision application based on diagnosis of nutrient requirements from soils and foliar analyses.
EPA Issues Notice of Data Availability RE: Renewable Fuels Production from Palm Oil Under the RFS Program: The U.S. Environmental Protection Agency (EPA) is issuing a Notice of Data Availability (NODA) to release its lifecycle greenhouse gas (GHG) analysis of palm oil used as a feedstock to produce biodiesel and renewable diesel under the Renewable Fuel Standard (RFS) program. The release of the NODA provides the public an opportunity to comment on EPAs analysis.EPAs analysis shows that biodiesel and renewable diesel produced from palm oil do not meet the minimum 20% lifecycle GHG reduction threshold needed to qualify as renewable fuel under the RFS program. Background: In the final RFS2 rule, published in March 2010, EPA assessed the lifecycle GHG emissions of multiple renewable fuel pathways (defined as feedstock, fuel type, and fuel production process). Assessment of lifecycle GHG emissions is necessary to determine which fuel pathways meet the GHG reduction thresholds for the four renewable fuel categories specified in Clean Air Act (CAA) Section 211(o), as amended by the Energy Independence and Security Act of 2007 (EISA). The CAA requires a 20% reduction in lifecycle GHG emissions for renewable fuel produced at new facilities (those constructed after EISA enactment), a 50% reduction for biomass-based diesel or advanced biofuel, and a 60% reduction for cellulosic biofuel. Assessing whether a fuel pathway meets these thresholds requires a comprehensive evaluation of the lifecycle GHG emissions of the renewable fuel as compared to the GHG emissions of the gasoline or diesel fuel that it replaces. The CAA defines lifecycle GHG emissions as follows:
The term lifecycle greenhouse gas emissions means the aggregate quantity of greenhouse gas emissions (including direct emissions and significant indirect emissions such as significant emissions from land use changes), as determined by the Administrator, related to the full fuel lifecycle, including all stages of fuel and feedstock production and distribution, from feedstock generation or extraction through the distribution and delivery and use of the finished fuel to the ultimate consumer, where the mass values for all greenhouse gases are adjusted to account for their relative global warming potential1
In the final rule, EPA focused our lifecycle analysis on fuels that were anticipated to contribute relatively large volumes of renewable fuel by 2022, and thus did not cover all fuels that either are contributing or could potentially contribute to the program. In the preamble to the final rule, EPA indicated that we would continue to examine several additional pathways not analyzed for the final rule, including those from palm oil, and would complete this process through a supplemental rulemaking process. This NODA presents our analysis of potential pathways for biodiesel and renewable diesel produced from a palm oil feedstock.
In order to calculate lifecycle GHG emissions for the NODA regarding palm oil biofuel pathways, EPA utilized models developed for the final (RFS2) rule. These models take into account energy and emissions inputs for fuel and feedstock production, distribution, and use, as well as economic models that predict changes in agricultural markets.
EPA used the same general approach to estimate global land use change GHG emissions from using palm oil as a feedstock as we have used to analyze other biofuel pathways. Our analysis of palm oil biofuels, however, also considers new data for Indonesia and Malaysia, where close to 90% of world palm oil is currently produced. These data include higher resolution satellite imagery and maps of relevant geographic features, such as oil palm plantations, palm oil mills and protected conservation areas. EPA undertook a more detailed assessment of Malaysia and Indonesia based on a number of factors, including the scale of the palm oil industry in this region and the availability of new data on palm oil land use. The analysis considered past trends to determine likely areas of future palm expansion and classified these areas according to both their land cover and their soil type.
EPAs analysis found that biodiesel and renewable diesel produced from palm oil have estimated lifecycle GHG emissions reductions of 17% and 11%, respectively, compared to the baseline petroleum diesel fuel they replace. These biofuels therefore fail to meet the minimum 20% GHG emissions reduction threshold required by EISA for renewable fuel made in facilities that commenced construction after December 19, 2007.
1 Clean Air Act Section 211(o)(1)
EPAs analysis highlights a number of key factors which contribute to the lifecycle emissions estimate for biofuels based on palm oil. For example, palm oil production produces wastewater effluent that eventually decomposes, creating methane, a GHG with a high global warming potential. Another key factor is the expected expansion of palm plantations onto land with carbon-rich peat soils which would lead to significant releases of GHGs to the atmosphere.
With this NODA, EPA is soliciting comments on our analysis of the pathways for biodiesel and renewable diesel produced from palm oil. We will consider all relevant comments received and will inform the public of any resulting revisions in our analyses. Public notification could be accomplished in one of several formats, such as a Federal Register notice, a rulemaking action or a guidance document. The appropriate form of public notification will depend on the outcome of any reanalysis we deem appropriate after consideration of public comments.
For more information, please vsit the RFS website
The EPA recently released a decision to attribute a GHG savings value to palm biodiesel that does not allow the feedstock to count towards the biodiesel quotas under the Renewable Fuel Standard (RFS2). This decision reflects a significant divergence from previous assessments of the feedstock, ensuring that palm oil does not have access to the US biodiesel market (threshold for access is 20%) under the Renewable Fuel Standard (RFS2). Even the EUs default value for palm oil, 19%, has been classified as a distortion.
The implications for this decision are serious, both for the domestic biodiesel sector, the livestock sector and consumers. This stems from the fact that limiting access to selected feedstocks (which also carry heavy political influence), undermines the ability of biofuel blenders to source the most price competitive feedstock, while increasing demand for domestically produced soybeans beyond the level that makes soybeans price competitive. Palm oil, the most widely traded vegetable oil, and lowest cost, is being directly discriminated against by the EPAs decision.
Palm oils GHG savings value has been varied, with assessments ranging from 38% to 62.9% for palm oil produced without methane capture (a technology employed during processing that significantly reduces emissions). Palm oil produced with methane capture has been attributed with values between 72.6% and 79.1% (the EU has given palm oil produced with this process a value of 56%). The US did not take this type of palm oil into consideration as the technology has been supported by the UNs Clean Development Mechanism, with credits earned from these savings traded in Europe.
While the calculations for the RFS2 take into indirect land use change, this topic has been hotly contested both within the industry as well as Congress, with both sides highlighting the continued uncertainty behind the science of measuring indirect land use change. Californias Air Resources Board (CARB) has reduced the factor by half following new evaluations, while continued research points to the factor meriting even greater reductions (if not removing the factor outright). The indirect land use change debate is generally centered on the expansion of agriculture production in developing countries, which cannot be separated from increased demand for foodstuffs and rising populations.
The decision by the EPA reflects a politically expedient option that satisfies both domestic oilseed producers and the environmental activists that underpin the Obama Administrations support. That their arguments against the use of palm oil are based on distortions and mischaracterizations of the palm oil industry further demonstrates this distance between policy and fact.
It is also important to consider the extent to which this decision is a cost for taxpayers, who have been asked consistently to provide subsidies to offset the costs of biofuels in the energy supply. Without free market competition between biofuel sources, government will continue to turn to the taxpayer to support this subsidy boondoggle, and undermine the USs commendable strategy of energy diversification, and thereby energy security.
Palm Oil Biofuels Under the Renewable Fuels Standard
March 29, 2012
The Honorable Lisa Jackson, Administrator
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Re: The Treatment of Palm Oil Biofuels under the Renewable Fuels Standard from the Center for Environment, Commerce & Energy (Center); Docket ID No. EPAHQOAR20110542
Dear Ms. Jackson:
The Center for Environment, Commerce & Energy (Center) is a national environmental organization dedicated to protecting the environment, enhancing human, animal and plant ecologies and increasing participation in the environmental movement. We focus on regulations, taxes, trade policies, monetary policies, and environmental issues as they relate to energy policy.
The Center is a strong advocate for U.S. energy prosperity and our organization raises awareness of the costs and consequences of policy changes for consumers. We believe it is important to ensure that minority communities are not burdened by artificially high energy costs. We also believe communities should be free to exercise a full range of choices in the marketplace, unburdened by short-sighted regulation or market manipulation.
To that end we stand in firm opposition to the EPAs recent decision to penalize palm oil under the Agencys management of the Renewable Fuels Standard. Palm oil is by far the lowest-cost biodiesel fuel source on the international market. By not allowing the lowest cost vegetable oil into the U.S. biofuel market, the EPA is ensuring that the RFS2 will lead to significantly higher prices at the pump as blenders rely on more costly vegetable oil feedstocks, like soybean oil and canola.
Blocking its trade in the United States will unduly burden poor communities. We have already seen the baleful effects of higher energy costs in recent months as prices paid at the gas pump have risen steadily. These price increases have meant minority households have had less money at their disposal for food, clothing, shelter, education, health care, savings and investment, and more. The EPAs decision will make an unfortunate situation worse.
More choices means more options when prices of one fuel rise. More choices means greater predictability and security when it comes to planning for the future. Restricting choices means minority groups are acutely vulnerable to price shocks in other sectors of the energy market.
Businesses and their workers are also keenly interested in policies regarding energy availability and affordability. For example, truckers and independent rail and transportation owner operators are significant consumers of diesel energy, including biodiesel. Many of these workers are minorities, and many of the businesses are minority owned and managed. Indeed, the transportation sector has been important to ensuring upward mobility and economic growth for minority communities.
As such, denying these communities the widest range of options in the energy market reduces their flexibility and their earnings prospects. It makes it more difficult to plan for growth, to hire workers and to expand operations that create opportunities and jobs for others.
The advance of sophisticated biodiesel systems is one of the most promising technological developments in recent memory. It promises to lower costs and generate long-run efficiencies that will benefit all stakeholders. But the full promise of biodiesel will not be realized without ample global competition and diversity of supply. As such, the EPA would be wise to avoid manipulating the market for biodiesel and let competition and consumer choice determine the ultimate shape and contours of market.
While we appreciate the EPAs interest in ensuring a healthy domestic environment, we believe its rush to penalize foreign biofuel will do little to help Americas ecology and a great deal of harm to Americas minority communities. The EPA should reconsider its decision.
JENA ECONOMIC RESEARCH PAPERS
Recalculating Default Values for Palm Oil
On December 5, 2010, the Renewable Energy Directive (RED) came into force in the EU. Member States are still working to fully transpose the Directive into national law and establish a framework for achieving their legally binding greenhouse gas (GHG) emission reductions. However, governments got off to a slow start as debate continues on the validity of the directives foundations including the default values used to measure the sustainability of biofuels. Only sustainable biofuels can be counted towards Member State targets. This, as a matter of principle, makes sense with respect to the very aim of renewable energy policies. On the other hand, the vague and distortive formulation and values regarding what is to be classified as sustainable have negatively impacted the perception of the underlying scientific base and methodologies as well as the reliability in the European biofuels sector. This uncertainty and the ongoing controversial debates are affecting investment and progress in the biofuel sector not just in Europe but all over the world. Producers of soybeans in the US, sugarcane in Brazil and palm oil in Malaysia and Indonesia as well as European importers and end-users of these products have all been sharply critical of the default values, citing significant variations in calculations that undermine the credibility of the values contained in the Directive.
Given the remarkable difference between the calculation of carbon reduction performance of palm oil based biofuel by the EU and a range of scientific studies which we documented in an earlier paper (Pehnelt and Vietze 2009), we are re-calculating GHG emissions saving potentials for palm oil biodiesel in order to further assess the carbon footprint of palm oil to overcome the lack of transparency in existing publications on the issue and EU regulations governing the biofuel feed-stocks.
The aim of this paper is to calculate realistic and transparent scenario based CO2-emission values for the GHG emission savings of palm oil fuel compared with fossil fuel. Using the calculation scheme proposed by the Renewable Energy Directive (RED), we derive a more realistic overall default value for palm oil diesel by using current input and output data of biofuel production (e.g. in South-East Asia) and documenting every single step in detail. We calculate different scenarios in which reliable data on the production conditions (and the regarding emission values during the production chain) of palm oil diesel are used.
Conservative calculations based on the Joint Research Centres (JEC 2011) background data and current publications on palm oil production result in GHG emissions saving potentials of palm oil based biodiesel fairly above the 35% threshold. We cannot reproduce the EUs GHG saving values for palm oil. Rather, our results confirm the higher values obtained by other studies mentioned in our last paper (Pehnelt and Vietze 2009) and elsewhere in this study.
Results indicate default values for the GHG emission savings potential of palm oil biodiesel not only way beyond the 19 percent default value published in RED but also beyond the 35 percent threshold. Our findings conclude that the more accurate default value for palm oil feedstock for electricity generation to be 52%, and for transportation biodiesel between 38.5% and 41%, depending on the fossil fuel comparator. Our results confirm the findings by other studies and challenge the official default values published in RED. As indicated by lawsuits filed by environmental NGOs against the Commission for greater transparency related to the assessment of biofuels, the process has been severely lacking in full disclosure of metrics used to achieve the values contained in the Renewable Energy Directive. As a result, the reliability of the Directive to support the EUs low-carbon ambitions is being undermined, exposing the EU and Commission to charges of trade discrimination and limiting the ability of Member States to achieve their legally binding GHG emission reductions.
This analysis demonstrates that a full review of the values contained in the Directive should be undertaken and the values revised to ensure their accuracy, and raises questions as to the method that the values were originally established. Were outside parties consulted, including the industries directly affected by the assessments in the Directive? Were these values peer reviewed? In light of grievances expressed by producers throughout the world, including US soybean growers, Brazilian sugarcane farmers, and Malaysian and Indonesian palm growers, ensuring the Directive does not discriminate against imports is critical to the long-term efforts in the EU to reduce GHG emissions.
Summary and Conclusion
The purpose of this review was to gain a comprehensive understanding of the metrics considered in developing the default values in the Directive, utilizing palm oil one of the more controversial biofuel sources as a case study of this process. Unfortunately, the conclusions of this analysis demonstrate that the methodology employed by the JRC lacks credibility, and subsequent efforts to gain further clarity from the JRC were not successful. As a result, the authors of this report support the efforts by environmental NGOs to gain further clarity on the European Commissions and EUs calculations and deliberations on the assessment of biofuels, and institute greater transparency in the process. Based on the standard calculation scheme proposed by the Renewable Energy Directive (EU 2009) and using current data of palm oil biodiesel production published in various reliable sources, we cannot reproduce the default values for palm oil biodiesel given in the annex of the RED. In contrast, our results indicate default values for the GHG emission savings potential of palm oil biodiesel not only far above the 19 percent default value published in RED but also beyond the 35 percent threshold. Our results confirm the findings by other studies and challenge the official default values published in RED.
These findings and concerns surrounding the trade implications of the Directive give cause for serious concern within the EU community regarding the viability of the system to effectively deliver the GHG emissions savings that are required in the legislation. While limiting imports of inefficient and environmentally damaging biofuel sources should be supported, distorting technical parameters in legislation to limit entry into the European market would be costly for consumers and businesses while exposing the EU to unnecessary trade disputes and possible retaliation.
The EU has been a leader in the promotion of low-carbon solutions to energy needs and the development of technologies that will spur a new age of energy generation and transportation. Unfortunately, since the EU began to pursue this goal the debate has increasingly turned to how these efforts can be increasingly limited, through introduction of new, untested sustainability criteria and trade barriers to limit competition from third countries. Not only will these measures undermine confidence in Europes low-carbon ambitions, however, they will also harm the global cooperation that is key to achieving these goals.
Institute for Energy and Environmental Research - IFEU
An Assessment of Energy and Greenhouse Gases of NExBTL
Neste Oil of Finland has developed a proprietary technology capable for producing a high quality diesel fuel from animal fats and vegetable oils. The process is called NExBTL (Next Generation Biomass to Liquid). Engine and emission testing results has shown that NExBTL has superior properties over current diesel products or alternative renewable fuels.
A 100 million euro, 170 000 tonne/year plant is currently under construction at the Neste Oil Porvoo refinery with start-up scheduled to begin in the 2nd quarter of 2007.
The NExBTL process is a catalytic hydrotreating process that is integrated into the Porvoo refinery. It utilizes the refinery's existing infrastructure and utilities including hydrogen, steam, electricity, personnel, blending tanks, waste facilities, harbour etc. Feedstocks are received at the harbour or by surface transport and stored in holding tanks before being transferred to the pretreatment unit where, using conventional degumming technology, impurities are removed. From here the feed is heated and pumped into the hydrotreating reactors. In the reactors, oxygen is removed and the feed (triglyceride) is converted into three separate branched chain paraffins. Side products of the process are fuel gas which is used for energy and a small amount of biogasoline. Oxygen in the triglyceride is removed as water and carbon dioxide.
The resultant NExBTL product can either be used as a pure diesel fuel or mixed with diesel to be used as a fuel component. The NExBTL product is a pure hydrocarbon product which meets EN590 diesel specifications except for density which is >> 780 kg/m3. It is free of aromatics, sulfur and oxygen. It has good stability (no unsaturated material). It has a low cloud point which can be adjusted from - 5 to - 28°C by severity of process conditions in order to produce either summer or winter diesel. The renewability of NExBTL can be verified by radioactive C14 analysis.
The Neste Oil Corporation has developed a technology to produce a diesel-like fuel (NExBTL) from animal fats and plant oils. The IFEU-Institute for Energy and Environmental Research Heidelberg, Germany, has been commissioned by Neste to undertake an evaluation of the energy and greenhouse gas balance of NExBTL.
A comparative analysis has been undertaken which uses the methodology of the life-cycle assessment standard ISO 14040-43 and allows to identify the parameters most relevant for the results. The production of NExBTL from rapeseed and palm oil has been analyzed including all materials and processes for the provisions of plant oils and their processing in the NExBTL process. Furthermore, all by-products have been considered as credits for substituting equivalent products. This life-cycle has finally been compared to the life-cycle of conventional diesel fuel. Besides a scenario for the site in Porvoo, Finland, also a scenario for a typical European site has been analyzed.
The results show a clear, but quantitatively different advantage in the energy and greenhouse gas balance if NExBTL substitutes conventional diesel fuel.
That means that the use of NExBTL saves primary energy and greenhouse gas emissions over the entire life-cycle in comparison with diesel fuel from fossil energy carriers for all comparisons, scenarios and sensitivity analyses considered in this study.
The quantitative results mainly depend on the provision of crude plant oil for the process and not very much on the NExBTL-process itself.
That means that all variations in the NExBTL-process, e.g. different provision of required hydrogen or the use of by-products such as fuel gas, bio-gasoline and sludge have a much lower influence on the overall result than the provision of plant oils. Thus it has to be distinguished between the production of NExBTL from rapeseed oil and palm oil.
NExBTL-production from rapeseed oil
As has been described under Result 1, NExBTL shows a clear advantage over conventional diesel fuel. Differences in the results mainly depend on where the rapeseed is grown (Europe or overseas) and on the alternative land use if rapeseed would not be grown (natural or set aside land). The results for rapeseed from overseas are on the upper limit of the bandwidth due to the longer transportation distance. The results over all considered scenarios show the following bandwidths of savings:
Energy savings: 30 - 33 GJ primary energy per t of NExBTL Greenhouse gas savings: 1.2 - 2.5 t CO2-equivalents per t of NExBTL
The results for NExBTL from palm oil mainly depend on the alternative land use on the plantation if no palm oil would be produced:
Case A: If the area would not be used and thus stayed untouched (natural forest), NExBTL, as for rapeseed oil, has a clear advantage over conventional diesel fuel. The production in the Porvoo plant, for which Malaysian palm oil will be used, leads to the following savings:
Energy savings: 44 GJ primary energy per t of NExBTL
Greenhouse gas savings: 1.4 t CO2-Equivalents per t of NExBTL
Case B: If another plantation would occupy the area of the palm oil plantation, the results show a considerable difference between the two alternative plantation land uses investigated in this study: food oil and coconut plantations. For average Malaysian palm oil, energy savings are about 33 GJ for food oil and 16 GJ for coconut plantations.
Greenhouse gas savings are about 2.2 t and 1 t of CO2-Equivalents, respectively.
Besides the different land use alternatives, the results also depend on the technology and infrastructure used for production and processing of palm oil. This especially applies to the results for greenhouse gas emissions. Compared to typical palm oil (world market), average Malaysian palm oil results in about 15% higher greenhouse gas savings for NExBTL. Good practice palm oil even results in about 65% higher savings compared to typical practice palm oil.