Dana wrote: >I suspect that we are not privy to the whole story. > >Looking at it from the EPA's point of view they cannot simply accept >that the biodiesel product of this company is in fact conforming to >the standards of the National Biodiesel Board without some >independent verification that it is.
Other way round surely. I don't think the NBB or its "standards" have any legal or statutory standing. >Absent that verification they >would be remiss if they did not require any commercial producer to >prove that their product conforms to the standard they claim it >does. Personally I DON'T want the EPA to simply accept any >commercial fuel producers word that his biodiesel is in compliance >with existing pollution control laws. In my experience the EPA >rarely enforces the pollution control laws as it is and I am always >surprised and pleased when I seem them actually doing what we pay >them to do. But they're not, they're just harrassing a little guy who's making a useful and innocuous product, which his customers rely on as it seems there's nowhere else they can easily get it. Check the current news for the ever-ongoing spate of deliberate pollution and poisonings by industry, the bigger the more. That's what they should be preventing, not this. >I suppose that the National Biodiesel Board might be the source of a >complaint which triggered the "singling out" of this biodiesel >producer but I doubt it.. since I suspect there are very few >commercial producers that "choose not" to belong to the National >Biodiesel Board or at least submit samples for testing by the NBB to >confirm that the product conforms to their standards. Does the NBB do that? I'm sure someone does, or at least I hope so, but is it them? >Compared to the >million dollar cost of other verification processes joining the NBB >might be a viable alternative. I suspect that the "contract >requirements which are unduly burdensome on a small operation" >probably include providing for the regular testing of product to >ensure that it conforms to the standards of the NBB. I'd like to see some confirmation of that. If so, are only the NBB's "official" (the NBB is not "official") tests acceptable? By dint of what? What other testing facilities are available? Would they be acceptable? If not why not? >This is simply a >cost of doing business and even though it is burdensome on small >business' is in place to protect the public. Although we may feel >that any regulation on biodiesel is oppressive no I suspect no one >actually wants unregulated biodiesel producers. Indeed not, though a lot of sins get covered by "protecting the public". But whatever arrangements are in place or should be in place MUST NOT make life impossible for small, independent, local producers. And the great danger is that they will do exactly that. >Before we all fly off the handle let's consider what will happen if >the standards which have been established No standards have been established. >are not conformed to by >commercial producers of biodiesel. And let's not spout "govt. >conspiracy" when in fact it most likely is the EPA actually doing >what we pay it to do. > >A commercial producer of biodiesel has a legal obligation to their >customers to provide assurance that their product conforms to some >recognized and accepted standard that a "home brewer" does not. There is no recognised and accepted standard, and therefore no legal obligation. There's a moral obligation, and a small-scale, local operator is more likely to abide by it than a big, faceless company that can refer complaints to the Customer Satisfaction Department, cc the lawyers in Damage Control. >Similarly a commercial producer of biodiesel should (as an >obligation to the breathing public ) be required to prove that their >product is within the legal pollution production standards. I think you're putting the cart before the horse. For instance, with the new organic farming standards now being applied in the US and elsewhere, what is certified is not the crop itself, crops are not tested, soils are not tested - what counts is the *management system*. If it's *managed* according to the standard, then the produce will be acceptable. (Actually I have some problems with this, in this particular case, but let it stand for the sake of this discussion.) So, Tom and other small producers are using well-established practices, the results and produce of which are well known. That should be all they have to demonstrate, IMO. If, in addition, regular product testing is required, well and good, but then those doing the requiring are beholden to make testing facilities available at an affordable price. But let's get it in perspective - this is biodiesel: less toxic than table salt, more biodegradeable than sugar, right? We're not dealing with nuclear wastes, dioxins, POPs here. So what exactly are these enormous risks that the public has to be protected against at such huge costs? Even if it's badly done, producing poor-quality biodiesel, will anything suffer other than the engine? Human health? The environment? The universe and all the fish? You don't need a B-52 to swat a mosquito. But if local energy production is seen as a threat by Central Control, that might merit a B-52. >I for one >would not feel comfortable with any commercial fuel producer being >allowed to simply promise that their product does either of these >rather than provide independent verification that it in fact does. >The NBB apparently provides an avenue for biodiesel producers to do >so and the producer in question chooses to not take advantage of it >choosing instead to complain that he is "being singled out". I doubt >this is true as I suspect that all other COMMERCIAL biodiesel >producers are held to the very standard that this one does not wish >to be held to. Again, there is no standard. BUT - his process is a standard one with known results. >It may be true that small biodiesel production >facilities are not economically viable You mean not viable in terms of all these alleged requirements, to conform to standards which don't exist, and to pay huge amounts of money for health and environment data that is already established and uncontested, just to prove that wheels go round? Because, apart from that, I'm sure Tom's operation IS economically viable. What you're talking about is whether it's viable in terms of a burdensome, random, and apparently preferential bureaucracy, a different matter. >in which case the producer may >have to decide whether to close down or expand to an economically >viable size. A bureaucratically viable size. Pay your dues, wear your suit. >Arguing that he is being discriminated against is as >useless as a backyard distiller complaining that he can't legally >sell moonshine to the public because only large business' that can >afford to prove their similar alcohol product won't make consumers go >blind are legally allowed to by the FDA. That's a bit of a misreading. And it's not the FDA, it's the US Bureau of Alcohol, Tobacco and Firearms. And other civilised countries do just that, if not the US. Legislation on this is currently in process, are you aware of it? >For perspective; >A recent link from the NBB web site on the perils of home brewed >Biodiesel. >http://www.biodiesel.org/perils_of_home-brew.htm Yeah, "The Perils of the Home-Brew", written by Werner Korbitz of the Austrian Biofuels Institute, and we've discussed it here before. Very quick they are, like the NBB and others, to point fingers at backyarders and small operations, but the fact remains that the methods backyarders use are PROVEN to have good results. People have driven many thousands of miles on their "perilous" homebrews and subsequent engine examinations have amazed mechanics because there's been so little wear. People claim they've driven lots of thousand miles on *unwashed* backyard biodiesel with no problems and no ill-effects. These cautions are rubbish, IMO. We make it, we wash it, we settle it, we filter it, we use it, our vehicles are happy, and so are we. If the suits don't like that, stuff 'em. >Does anyone really want the possibility that unregulated, >untested "biodiesel" could be legally sold as "the same stuff the NBB >is promoting"? Isn't that what happened in Indonesia when they >allowed palm oil to be mixed with diesel fuel? No, that was quite different, nothing to do with this. (Thailand, not Indonesia.) Unlike US biodiesel, they actually have an official standard for the mix, backed by government tests and the petroleum institute (and by the King), but many people weren't adhering to it and mixing up any old crap, who's to know? - until it's too late. You can't do that with biodiesel, it's either biodiesel or it isn't, and if you use an accepted process it will do the job. A more apt example might be what worries Camillo Holecek at ENERGEA in Austria, that poor-quality biodiesel being marketed in Germany is endangering the vehicle manufacturers' guarantees - this is biodiesel made by *commercial* producers who've no doubt fulfilled all the German standards, health, safety, environment and administrative requirements, but are still free to cheat. I've asked this here before: bureaucratic controls regardless, who's more likely to cheat, the commercial-scale producers or backyarders making their own fuel and small-scale local operators who're probably on first-name terms with all their customers? >We simply don't need >those kind of setbacks if biodiesel is to be accepted as a safe >alternative to petrodiesel. I don't think that's what's at issue here. Re US standards. There *was* a preliminary US Biodiesel ASTM Standard, which expired in June 2001. It wasn't even a standard, it was called a "Quality Specification", ASTM PS 121. The expired specifications are still available from ASTM from their website, for $30 for the pdf download. http://www.astm.org/cgi-bin/SoftCart.exe/DATABASE.CART/PAGES/PS121.htm ?L+mystore+nfyg5893+991076038 I can't find any news or updates on the current hiatus, so I suppose it's still being used, but I doubt there'd be any legal basis for enforcing it. Why the delay? Why the silence? The European standards (the EU standard is also delayed, I believe, not sure why) favour rapeseed oil and exclude soy. Okay, as Ed explained, rapeseed does have superior lubricity, but it's also a major EU crop, as soy is in the US. These are political matters. ASTM PS 121 has been sponsored by soybean interests. Are they maybe trying to find a way to exclude rapeseed oil? If the standards are going to be just that, standards serving the best interests of engines, humans, health and environment, well and good, but I share Ken Provost's scepticism: >The ASTM "standards" for biodiesel are just set by the maximum cost >and pain that the big boys are willing to expend, and hopefully >(from their point of view) will always be just beyond the reach of >what is reasonable for the homebrewer. No, Dana, I disagree with you. We have to defend our patch or we'll be steam-rollered, for no good reason other than big guys protecting their dubious interests, and everybody will be the loser. As we keep seeing. Best Keith Addison Journey to Forever Handmade Projects Osaka, Japan http://journeytoforever.org/ >Dana ------------------------ Yahoo! Groups Sponsor ---------------------~--> Get your FREE credit report with a FREE CreditCheck Monitoring Service trial http://us.click.yahoo.com/ACHqaB/bQ8CAA/ySSFAA/FGYolB/TM ---------------------------------------------------------------------~-> Biofuel at Journey to Forever: http://journeytoforever.org/biofuel.html Please do NOT send "unsubscribe" messages to the list address. To unsubscribe, send an email to: [EMAIL PROTECTED] Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/
