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EPA is proposing - Petroleum Equipment Institute

EPA is proposing - Petroleum Equipment Institute

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include a general definition of renewable fuel, but unlike RFS1, we are including aseparate definition of “Renewable Biomass” which identifies the feedstocks from whichrenewable fuels may be made.Another difference in the definitions of renewable fuel <strong>is</strong> that RFS2 contains threesubcategories of renewable fuels: 1) Advanced Biofuel, 2) Cellulosic Biofuel and 3)Biomass-Based Diesel.“Advanced Biofuel” <strong>is</strong> a renewable fuel other than ethanol derived from cornstarch and which must achieve a lifecycle GHG em<strong>is</strong>sion d<strong>is</strong>placement of 50%,compared to the gasoline or diesel fuel it d<strong>is</strong>places.Cellulosic biofuel <strong>is</strong> any renewable fuel, not necessarily ethanol, derived from anycellulose, hemicellulose, or lignin each of which must originate from renewable biomass.It must achieve a lifecycle GHG em<strong>is</strong>sion d<strong>is</strong>placement of 60%, compared to the gasolineor diesel fuel it d<strong>is</strong>places for it to qualify as cellulosic biofuel.The RFS1 definition provided that ethanol made at any facility - regardless ofwhether cellulosic feedstock <strong>is</strong> used or not - may be defined as cellulosic if at suchfacility “animal wastes or other waste materials are digested or otherw<strong>is</strong>e used to d<strong>is</strong>place90% or more of the fossil fuel normally used in the production of ethanol.” Th<strong>is</strong>prov<strong>is</strong>ion was not included in EISA, and therefore does not appear in the definitionspertaining to cellulosic biofuel in today’s proposed rule.The statutory definition of “renewable biomass” in EISA does not include areference to municipal solid waste (MSW) as did the definition of “cellulosic biomassethanol” in <strong>EPA</strong>ct, but instead includes “separated yard waste and food waste. <strong>EPA</strong>’sproposed definition of renewable biomass in today’s proposed rule includes the languagepresent in EISA. As d<strong>is</strong>cussed in Section III.B.1.a, we invite comment on whether th<strong>is</strong>definition should be interpreted as including or excluding MSW containing yard and/orfood waste from the definition of renewable biomass. <strong>EPA</strong> intends to resolve th<strong>is</strong> matterin the final rule, and <strong>EPA</strong> solicits comment on the approach that it should take.Under today’s proposed rule “Biomass-based diesel” includes biodiesel (monoalkylesters), non-ester renewable diesel and any other diesel fuel made from renewablebiomass, as long as they are not “co-processed” with petroleum. EISA requires that suchfuel achieve a lifecycle GHG em<strong>is</strong>sion d<strong>is</strong>placement of 50%, compared to the gasoline ordiesel fuel it d<strong>is</strong>places. As d<strong>is</strong>cussed in Section III.B.1.d, we are <strong>proposing</strong> that coprocessing<strong>is</strong> considered to occur only if both petroleum and biomass feedstock areprocessed in the same unit simultaneously. Thus, if serial batch processing in which100% vegetable oil <strong>is</strong> processed one day/week/month and 100% petroleum the nextday/week/month occurs, the fuel derived from renewable biomass would be assignedRINs with a D code identifying it as biomass-based diesel. The resulting products couldbe blended together, but only the volume produced from renewable biomass would countas biomass-based diesel.22

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