Hello Thor If you look at this previous message: http://archive.nnytech.net/index.php?view=887&list=BIOFUELS-BIZ
- from Shaine Tyson at NREL, via Tom Leue, it seems biodiesel doesn't qualify for expemtions under baseline or non-baseline because it's not a petroleum fuel. Others also reached this conclusion. So where did this spring from? >AN EXCEPTION IS BIODIESEL, WHICH IS ONE >GROUP, EVEN THOUGH IT CONSISTS OF MIXED ALKYL ESTERS >OF PLANT AND/OR ANIMAL ORIGIN." (My capitalization)` I saw it at the url you gave. >Hi everyone, > >I have been on the phone with various government >officials at various agencies. > >I have a guy at the Agricultural Marketing Service >trying to answer the question of whether checkoff >funds are considered private or public monies. > >Someone on this list asserted that it was with such >funds that the Soybean Board/Council funded the NBB >Tier 1 testing. Is there any documentary proof of >this? Also previous: ><http://www.ott.doe.gov/biofuels/biodiesel/research_progress/244335a4 >.pdf>http://www.ott.doe.gov/biofuels/biodiesel/research_progress/24433 >5a4.pdf >it is rather apparent that the NBB/Soybean Councils laid >considerable inside track years ago. The entire document, circa >March 1997, is predicated upon the authoritative input of "the >biodiesel industry." But that pdf isn't at that url anymore, nor can I find it on my hard disk. It's called "Titled: Fuels and Fuel Additives Registration Regulations" - possibly part of the same document you accessed, but I can't find it there. PDFs - GRRR! Pollution of the Web. Best Keith >I also have a request in to EPA about Tier One testing >requirements. Joe Sapata left me a message saying >that we could not use the NBB test data, but I don't >know the rationale. > >Non-discrimination is an issue that Glenn Ellis >brought up. Where I see the discrimination, beyond >denying public use of NBB testing data bought >(putatively) with public money, is EPA's refusal to >grant the Tier One testing exception to small >biodiesel producers. > >[All the following info can be found at: >http://www.epa.gov/icr/icrs/icrpages/1696ss03.htm] > >Specifically: As part of its Information Collection >Request, (EPA ICR Number 1696.03, OMB Control Number >2060-0297) section 2(a), EPA writes: > >"There are several exceptions to the above, in order >to lessen the burden for small businesses. >Manufacturers of baseline and/or nonbaseline products, >who have an annual sales revenue of less than $50 >million, are exempt from Tier 1 and Tier 2. >Manufacturers of atypical products, who have an annual >sales revenue of less than $10 million, are exempt >from Tier 2." > >From what I can tell, biodiesel is considered a >nonbaseline diesel group. In its description of >Diesel fuels and additives, EPA says (section 2(a) >again),: "Nonbaseline Group - diesel/additive >elements are limited to CHONS (carbon, hydrogen, >oxygen, nitrogen, and sulphur) and fuel oxygen is 1.0 >percent or greater. A group is established for each >oxygenate. AN EXCEPTION IS BIODIESEL, WHICH IS ONE >GROUP, EVEN THOUGH IT CONSISTS OF MIXED ALKYL ESTERS >OF PLANT AND/OR ANIMAL ORIGIN." (My capitalization)` > >Section 6 states, >"Due to the costs, it is likely that only limited >additional Tier 1 research will be done. Future fuels >and additives subject to Tier 1 will almost >exclusively be those that can group with existing Tier >1 data, and likely will come from manufacturers who >have already paid for the Tier 1 data. Thus, it is >estimated that there will be only one new Tier 1 >submission over the next three years. Of course, >manufacturers of baseline and nonbaseline products >with less that $50 million in annual revenue are >exempt from Tier 1, so there will be continuing >registration activity in that area. > >"In the previous ICR, it was concluded that the few >new products for which a new Tier 1 would be required >are likely to be in the atypical and/or nonbaseline >categories, with an estimate Tier 1 cost of about >$500,000 per product. The National Biodiesel Board >has estimated its Tier 1 cost for biodiesel at >$600,000." > >Therefore, according to EPA's own words, it seems to >me that if you have sales of less than $50 mil you're >exempt. Yet Tom Leue said he was threatened by EPA if >he didn't provide Tier 1 test data (and I'm asssuming >he had annual revenues <$50 mil.) > >Also, with regard to accessing the NBB test data, >consider this. > >Regarding confidentiality, 3(f) states, "Some Tier 1 >data, particularly6 those related to composition, >could be claimed as confidentiala dn would be subject >to EPA's FOI provisions at 40 CFR 2." But section >2(b) asserts that " the data may also be used by >non-EPA organizations...to review a product's >potential toxicity,...to determine whether the >submittal of further information would be duplicative, >or to contact producers to use the registration >already granted and share in the cost of previous >compliance. Public interest and environmental >organizations may review the data and preform their >own evaluations." > > >Any thoughts? > >Regards, > >thor skov > > >===== >Grants Manager >Stillaguamish Tribe Of Indians >3439 Stoluckquamish Lane >P.O. Box 277 >Arlington, WA 98223-0277 >(360) 652-7362 Ext 284 > >__________________________________________________ >Do You Yahoo!? >Yahoo! Health - Feel better, live better >http://health.yahoo.com > > >Biofuels at Journey to Forever >http://journeytoforever.org/biofuel.html >Biofuel at WebConX >http://www.webconx.dns2go.com/2000/biofuel/biofuel.htm >List messages are archived at the Info-Archive at NNYTech: >http://archive.nnytech.net/ >To unsubscribe from this group, send an email to: >[EMAIL PROTECTED] > > > >Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/ ------------------------ Yahoo! Groups Sponsor ---------------------~--> Will You Find True Love? Will You Meet the One? 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