Dana,
My messages seem not to get through so will try again.
I do not agree with you that YBD has done anything yet that is
controversial. This company feels that they are being put out of business
because of some overly "burdensome and expensive" regulations and have asked
for some relief through their Congressman who hopefully will direct this
question as an enquiry to the EPA secretary. Nothing controversial about
that. YBD has a perfect right to make such a request, and I do not feel that
either the Congressman or EPA would consider this request controversial.
(True there have been controversaries and some controversial statements on
this webb site, but YBD has not been involved so far as I know. )
Given the status of present conditions, YBD feels that they have gone as far
as they can under the circumstances. They have been given an ultimatum by
EPA, have determined that the cost of compliance is too burdensome and
costly, have tried to negotiate with NBD, not found any relief there, and
are now faced with seeking other alternatives. Nothing confrontational
about this so far.
Some specific answers are needed to help resolve the situation: 1) Can or
will NBD do anything more for NBD than what NBD has so far offered? 2) Can
EPA offer the small BIOdiesel producers some special considerations, as they
have, by precedent, offered the small PETROdiesel producers? 3) Failing
these requests, can EPA offer some relief to small biodiesel producers on
the basis of allowing them to proceed as follows: :
a) approving or modifying their process design,
b) approving process construction,
c) approving and/or modifying their
process procedures, and, finally
d) requiring periodic sampling and analysis,
by EPA approved facilities, of the biodiesel product on a periodic
basis.
Do such analytical facilities exist or can they be readily established? If
option 3 is permissible, YBD might be able to proceed without involving NBD
at all.
You raise objections to item 3 on basis that this would not insure against
contamination of the biodiesel product. On this basis EPA could not approve
water treatment plants, as they do now, requiring similar procedures. For
either water purification or for biodiesel production, the question needs to
be asked whether a process can be specified and designed to INSURE against
either unsafe water or unsafe biodiesel. No, you can't insure against
someone deliberately and maliciously contaminating the product, and the
producer should only be required to take reasonable precautions. (This is
why I put a lock on the tank that is periodically filled with No. 2 fuel oil
to run the furnace that heats my house. Someone might, and I believe has in
the past, poured water in the tank filler spout.)
NBD, even though they required someone to watch YBD's production process 24
hours a day could not absolutely guarantee that YBD biodiesel being put into
a particular vehicle fuel tank was not contaminated.
To say that YBD has been confrontational or at all unreasonable, I believe,
illustrates a bias on your part. To suggest that YBD may perhaps not be able
to compete because of economies of scale is premature and irrelevant. There
are some basic principles involved, and, if judiciously handled, this case
might be a means to establish these principles to assist the small biodiesel
producer. First eliminate or simplify any unnecessary policies, regulations,
or attitudes that would prevent a small biodiesel producer from competing.
Before you can be a fair negotiator, and effective in resolving these issues,
I believe, you should first get rid of your bias.
[Non-text portions of this message have been removed]
------------------------ 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/
