Todd- I have considered your points of contention since last night and also did some research today.
As to your first point, let me stress that this production is by the municipality strictly for use by the municipality within the limits of the municipality. No sale of product would ever transpire. I talked with people from USDOT, Alabama DOT and Alabama DOR. All said that they knew of no reason why we could not do this. I was unable to reach the regional person with the EPA. I don't quite understand your second point (thick headed) but this is what I think may apply. I believe that the intent of that language is to tax vehicles which could normally be expected to make regular use of state and federal roads. I certainly could be wrong about that, but again, none of the agencies I spoke with seemed to think it was a problem. The bit of reading I did on the regulations focused on the sale and distribution of fuel with no mention of production for in house use. Your third point is well made, however, I know something about these kinds of laws. They are in place to prevent government agencies from competeing with private businesses in the marketplace. There is no law that I am aware of that prohibits these agencies from producing any type of goods or services for their own consumption. I don't pretend that local businesses who have enjoyed the business that they receive from the city will be glad. But, the goverment should do what is best for the public interest. Finally, the only thing I can say to the commercial biodiesel producer is that there is no profit involved. Taxes paid by the government to the government is trading paper and thus inefficient. Also those taxes will come out of the public coffers. I am pretty sure that at least the public will support this idea. Much easier to get public support in a small community. I understand your frustration with lawyers and bureaucrats getting their 2 cents in (or out), but I can't let that deter me in this attempt. Maybe someone in the right place will do the right thing. Bill C. ----- Original Message ----- From: "Appal Energy" <[EMAIL PROTECTED]> To: <biofuel@yahoogroups.com> Sent: Monday, June 10, 2002 11:27 PM Subject: Re: [biofuel] First stage foolproof method > Bill, > > While you have hit upon what might appear to be a reasonableo > loophole in the matter, there remain several points of > contention. > > For a moment consider that I might be a very bitter commercial > biodiesel manufacturer, extremely angry at the manner in which > the NBB/soy councils are attempting to get their checkoff dollars > back after they've already spent them once. Surely you don't > believe that someone such as this would let a manufacturing > scenario such as you present go unchallenged, simply because the > state or municipality is road tax exempt? > > Consider the EPA's definition of "in commerce" as being on-road > use. Not brief use of agriculturally exempt dyed fuel, such as > hauling a tractor to a harvest site, but non-dyed commercial > grade fuel. It's the exact same fuel whether it's taxed or not > and whether it's in a state DOT truck, a privately owned tractor > trailer or a Volkswagen Golf. > > Also consider for a moment from where these tax exempt entities > have been previously accessing their fuel - outside vendors. > There are arenas full of ordinances and statutes governing the > acquisition of supplies and competing with commercial interests. > > Now try and explain to the miffed commercial biodiesel producer > why the state or municipality should be exempt from the same > Health Affects data requirements that he or she must adhere > to....Same roads. Same air. Same quality of emissions. Which > brings a soul directly to the off-road exemption, which will at > some point cease to exist due to the very same arguement. > > Too many lawyers, too many bureaucrats and too many people > serving self-interests inevitably screw up anything worthwhile. > > Todd Swearingen > > ----- Original Message ----- > From: William Clark <[EMAIL PROTECTED]> > To: <biofuel@yahoogroups.com> > Sent: Monday, June 10, 2002 11:45 PM > Subject: Re: [biofuel] First stage foolproof method > > > > Todd- Early on in my ivestigation of biodiesel (relative to the > total time I > > have spent) I checked with the municipality here and found that > they are > > exempt from state and federal fuel taxes. Same for schools. My > question here > > is if a municipality would be required to register thier fuel > if they > > produce it themselves and use it to operate their own > equipment? I make the > > assumption that apart from the chemical inputs, there will be > no hazardous > > by-products. If chemicals which may be obtained on the open > market are > > properly handled, what other concern does the EPA have in this > matter? > > > > Bill C. > > ----- Original Message ----- > > From: "Appal Energy" <[EMAIL PROTECTED]> > > To: <biofuel@yahoogroups.com> > > Sent: Monday, June 10, 2002 10:04 PM > > Subject: Re: [biofuel] First stage foolproof method > > > > > > > Bill, > > > > > > There is nothing to stop anyone from producing their own fuel > for > > > their own off-road use, save for local ordinances that may > apply. > > > And there may not be anything stopping anyone from producing > > > their own fuel for their own personal on road use, save for > the > > > IRS and state taxation departments relative to collection of > road > > > taxes and the EPA relative to registration of the fuel - > > > presuming they made the effort to be intentional pains in the > > > arse on the matter. > > > > > > But the moment a commercial manufacturer produces the first > drop > > > for use in commerce (road legal fuel), they have to buy > access to > > > Health Affects data, either by paying NBB fees, conducting > their > > > own studies or partnering with an entity that already has > legal > > > access to the data. > > > > > > That's pretty much the end of the story at the moment. And > pretty > > > much what scotches it for many people who would ordinarily > move > > > into higher volumes of manufacture within their own > communities. > > > > > > Todd Swearingen > > > > > > ----- Original Message ----- > > > From: William Clark <[EMAIL PROTECTED]> > > > To: <biofuel@yahoogroups.com> > > > Sent: Monday, June 10, 2002 10:50 PM > > > Subject: Re: [biofuel] First stage foolproof method > > > > > > > > > > Todd- I don't know exactly what EPA and soybean councils > have > > > put on paper. > > > > I would be interested in seeing what legislation or rules > > > apply. Would > > > > appreciate directions to access that info (if available). > One > > > loophole I > > > > hope to exploit may be that I am proposing that entities > refine > > > their own > > > > fuel, not produce commercially. > > > > > > > > Bill C. > > > > > > > > .----- Original Message ----- > > > > From: "Appal Energy" <[EMAIL PROTECTED]> > > > > To: <biofuel@yahoogroups.com> > > > > Sent: Monday, June 10, 2002 9:24 PM > > > > Subject: Re: [biofuel] First stage foolproof method > > > > > > > > > > > > > That's rather a hopeful thought...that an Audobon/NBB > board > > > > > member could persuade the EPA and the soybean councils to > > > make a > > > > > loophole in the matrimonial papers they formulated in > order > > > to > > > > > accomodate micro-regional manufacture. > > > > > > > > > > Don't get me wrong. It would be wonderful if they would. > But > > > that > > > > > certainly hasn't been the stance of either up to this > point. > > > And > > > > > it's rather difficult to imagine that they could even if > they > > > > > wanted to, as the general rule in this country is "equal > > > > > protection under the law." > > > > > > > > > > Which also means equal enforcement, prosecution and > > > > > persecution.... meaning that the rules are to be applied > > > equally > > > > > to everyone and that exceptions are perceived as the > > > proverbial > > > > > pox - no matter how beneficial they prove. > > > > > > > > > > One can always hope. But if I were you, I would be > > > formulating a > > > > > backup plan well before I put all my eggs in that basket. > > > > > > > > > > Todd Swearingen > > > > > > > > > > ----- Original Message ----- > > > > > From: William Clark <[EMAIL PROTECTED]> > > > > > To: <biofuel@yahoogroups.com> > > > > > Sent: Monday, June 10, 2002 9:09 PM > > > > > Subject: Re: [biofuel] First stage foolproof method > > > > > > > > > > > > > > > > Ken & others- First I would like to thank all of you > for > > > your > > > > > help & your > > > > > > prompt replies. I thought it might be useful for me to > > > describe > > > > > what I have > > > > > > in mind. > > > > > > > > > > > > One of the missions we would like to undertake is to > > > > > demonstrate the > > > > > > effectiveness of biodiesel as a fuel to the local > community > > > and > > > > > government. > > > > > > The quality of my fuel is important. While energy > > > (electricity) > > > > > is cheap > > > > > > here, cost is very important, hence my desire to use > solar > > > as a > > > > > heat source > > > > > > when practical. I believe that WVO can be preheated in > a > > > pcv > > > > > pipe grid using > > > > > > the sun. When painted black it is less suseptible to > UV. > > > Not > > > > > along term > > > > > > solution but will do for now. > > > > > > > > > > > > After we are comfortable with our process, we intend to > > > > > convince the City of > > > > > > Eufaula to have the Recycling Dept. collect all WVO > > > produced > > > > > locally (not > > > > > > currently doing this) and produce their own clean fuel. > I > > > know > > > > > other cities > > > > > > in USA are producing biodiesel but none as small as us > > > > > (15,000). Most > > > > > > biodiesel info I have seen is geared either to large > > > capacity > > > > > production or > > > > > > individual and farm production. Once we have coverted > our > > > own > > > > > city, we will > > > > > > try to convince other small communties in Alabama and > > > > > eventually the South > > > > > > East to do the same. > > > > > > > > > > > > Somebody recently made referrence to the EPA and their > > > > > discouragement of > > > > > > small biodiesel prodution in an e-mail on this list. I > am > > > > > unfamiliar with > > > > > > this but don't doubt it. Ron Dodson (neat guy and a > very > > > > > creative thinker) > > > > > > is the head of Audubon International. That is the group > we > > > are > > > > > doing this > > > > > > with. Ron also sits on the National Biodiesel Board. We > can > > > > > probably get > > > > > > some support for this idea through him. > > > > > > > > > > > > Bill C. > > > > > > > > > > > > ----- Original Message ----- > > > > > > From: "Ken Provost" <[EMAIL PROTECTED]> > > > > > > To: <biofuel@yahoogroups.com> > > > > > > Sent: Monday, June 10, 2002 6:43 PM > > > > > > Subject: Re: [biofuel] First stage foolproof method > > > > > > > > > > > > > > > > > > > >Next question. What problems might I encounter using > > > > > > > >anhydrous ethanol as opposed to methanol as a > reactant > > > > > > > >in this process? > > > > > > > > > > > > > > I believe the first step involves mostly > esterification > > > but > > > > > also > > > > > > > some transesterification. I don't know how much > you're > > > > > > > relying on the glycerine to fall out of the reaction, > but > > > it > > > > > > > won't leave the solution as readily or as completely > when > > > > > > > ethanol is used. Also, you have to use more ethanol, > > > > > > > of course, since the molecular weight is greater than > for > > > > > > > methanol (ratio 46 to 32). If you want to continue > with > > > > > > > ethanol in the 2nd step, which is PURELY > > > transesterification, > > > > > > > the problem with the glycerine failing to separate > from > > > > > > > the biodiesel can become quite bothersome, > particularly > > > > > > > with any water in there, or free fatty acids above > 1%. > > > > > > > > > > > > > > > > > > > > > Biofuel at Journey to Forever: > > > > > > > http://journeytoforever.org/biofuel.html > > > > > > > > > > > > > > Biofuels list archives: > > > > > > > http://archive.nnytech.net/ > > > > > > > > > > > > > > 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/ > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > Biofuel at Journey to Forever: > > > > > > http://journeytoforever.org/biofuel.html > > > > > > > > > > > > Biofuels list archives: > > > > > > http://archive.nnytech.net/ > > > > > > > > > > > > Please do NOT send "unsubscribe" messages to > the > > > list > > > > > address. > > > > > > To unsubscribe, send an email to: > > > > > > [EMAIL PROTECTED] > > > > > > > > > > > > Your use of Yahoo! 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