Graham, Keith, Tom, et. al.

Graham,

First, I sincerely hope that you do not bow out of
this discussion, as your participation does provide a
perspective that otherwise has been absent (in my
limited experience with this listserve).

I also want to thank Keith for his wonderful post a
while back on the issue of soybean subsidies.

Second, I think that there are some points to consider
in Graham's argument that all BDers should think
about.  It's true that we haven't seen any particulars
wrt actual failings of the product of small biodiesel
producers, and that it is certainly unfair of the NBB
to summarily dismiss small producers on the basis of
their product quality.  If the NBB were in fact really
interested in promoting small-scale production, it
would be suggesting ways to work with backyarders
rathe than simply suggesting that they bow out.

I can give only a single anecdote from my own
extremely limited experience, that may or may not
count as it is coming second/third hand.  The owner of
Fuelwerks, the place where I buy (World Energy)
biodiesel in Seattle, told me that he had a bad
experience with poor quality biodiesel from Portland,
and that is why he is sticking with World Energy.  He
also claimed that Seattle Metro (bus service) had a
bad experience as well and consequently was now set
against biodiesel.

Now I understand that the specifics in these stories
are missing, and so they don't weigh in as evidence
either for or against small producers.  That is the
point that has been made over and over.

A more significant point has been missed, however,
namely that regardless of the truth of a basis for
concern about the quality of backyard production, the
perception is equally important.

What we are trying to do is to (re)introduce a (old)
new technology.  The average driver, who knows nothing
of mechanics, fuel technology, and so on, is going to
be wary of sticking an unfamiliar substance in their
tank.  Doubly and triply so for the commercial or
government fleet manager.  We're talking about both
actual risk and the perception thereof.  We all know
that bad news travels further and faster than good
news, and so just one actual or perceived bad
experience by someone putting biodiesel in their tank
(regardless of whether the biodiesel was actually at
fault or was simply blamed for something else that
went wrong) can set back our mutual agenda.

We need a couple of things.  First, better public
information and more outreach, such as the Clean
Cities Coalition did with their biodiesel symposium in
Seattle in Sept 2001.  Second, more help / technical
assistance for small scale producers, in understanding
the regulations and tax implications.  What we get
instead are generally warnings and threats.  That
makes people, including me, just want to dig in our
heels and raise a middle finger.

Here are some specific actions.
1)  The NBB should make its Tier 1 testing results
available to any small producers who want them,
without having to submit to its fee structure that
discriminates against small producers OR it should
revise that fee structure to be fair to small
producers.  NBB has, unfortunately, decided it easier
simply to wave away all backyard biodiesel, a strategy
for which Graham is now receiving a lot of flak.
[As a side note, I don't think the NBB has a leg to
stand on anyway, as these results were paid for with
public money--soybean checkoff funds--and therefore
cannot be appropriated for private benefit.  But the
NBB evidently wants to make someone work to establish
that.  There are FOIA requirements at play here.]

2)  EPA and the IRS should publish specific, clear,
unambiguous guidelines with regard to taxation and
certification requirements for biodiesel, in plain
English and not lawyer-speak.  Having spent hours
wading through CFR and federal register announcements
about EPA regs for biodiesel and fuel testing, as well
as a lot of time on the phone with EPA, I have found
these rules abstruse and contradictory.  Even Joe
Sopata at EPA told me that their own regs didn't jibe
with the law.  Perhaps things have been clarified
recently, to the better.

3)  The fuel tax is fair and good, IMO.  It is a user
fee (and therefore relatively progressive as a tax),
and goes to pay for roads and transportation projects.
   But it is a lot of paperwork (at least in Washington
State) to go through:  you have to register as a fuel
dealer, submit a whole bunch of forms, and so on, even
if you are just producing for your own use and not for
sale.  I would like to see this process streamlined
and made more accessible.  At present, it seems to
encourage avoidance rather than participation.

4)  We need to agree on some kind of quality
standards.  Perhaps I am flogging a dead horse here,
but I haven't been able to read a consensus on this
forum about the feasibility of ASTM testing for small
producers.  Standards make the world go round, and
without them, car manufacturers and engine
manufacturers won't agree to warranty BD use; then car
owners and fleet managers won't want to use it (that
perception of risk I talked about earlier).

As a final note, although I am all for decentralized
production (especially using WVO), and would buy
locally made BD over World Energy if I had the option,
I have to say I am glad the NBB and World Energy
exist.  Graham, even though I don't think your
business model is ideal (using subsidized,
conventional agriculture virgin oil, and shipping it
all over the country to be processed and sold) I do
appreciate that at this stage in the game you are
providing a consistent supply of product to places
that otherwise may not have it.

I also think we are better off having a relatively
large organization to do lobbying on behalf of BD in
Congress, something I certainly couldn't do (very
effectively) if I were a small producer.  Someone has
to take on the oil companies and do the outreach to
engine manufacturers, and the small producer community
is simply not well-enough organized at this point to
do so.  Even if the NBB is interested principally in
feathering its own nest, at least ADM (an otherwise
thoroughly reprehensible company) et al are lobbying
for, for example, BD tax-exemptions.

For NBB and small producers to work together
effectively, both sides will have to give something,
and both have something to offer.  But each will have
to look beyond its self-interests to do so.  At this
time, the NBB has greater political and economic
power, and is (perhaps?) better organized to act.
Small-scale producers may need to think about
organizing somehow (a national cooperative?) to focus
their voices.

best to all,

thor skov





>


=====
Grants Manager
Stillaguamish Tribe Of Indians
3439 Stoluckquamish Lane
P.O. Box 277
Arlington, WA 98223-0277
(360) 652-7362  Ext 284

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