National Biodiesel Board National Biodiesel Board 1331 Pennsylvania Avenue 605 Clark Avenue Washington, DC 20004 Jefferson City, MO 65110 B1O@0@@@!1® (202) 737-8801 phone (800) 841-5849 phone America's Advanced Biofuel
August 28, 2020
Comments submitted to the
New York State Department of Public Service (DPS)
and
New York State Energy Research and Development Authority (NYSERDA)
Relating to Case 15 – E – 0302
White Paper on Clean Energy Standard Procurements to Implement New York’s Climate Leadership and Community Protection Act
The National Biodiesel Board (NBB) represents the biodiesel, renewable diesel, and renewable jet fuel industries. NBB members play an important role in displacing petroleum, improving public health, and protecting the environment. Our members vary in size from large companies to small, family-owned businesses. Many NBB members are members of environmental organizations and are supportive of state and local initiatives to achieve a sustainable energy future. Many of our members are located, or do business, in New York State.
New York State has recently passed and implemented a B5 standard for Bioheat in the downstate region. New York City has also implemented a comprehensive Bioheat standard that will progressively lead to a B20 level citywide by the year 2034. The National Biodiesel Board is also participating in further legislative discussions with the legislature relating to the implementation of even higher blend levels statewide by the year 2030.
We would offer that biodiesel can be a significant contributor to the accomplishment of climate protection goals established by the Climate Leadership and Community Protection Act. The heating oil industry in New York is proactively working toward further reducing the carbon intensity of its products. The heating oil industry’s goal, as set forth in its “Providence Resolution,”1 adopted in 2019, is to adopt B50 by 2030.
1 https://nefi.com/news-publications/recent-news/heating-oil-industry-commits-net-zero- emissions-2050/
NBB commends DPS and NYSERDA for allowing stakeholders to participate in its consideration of the Clean Energy Standard and other low carbon programs. We believe that stakeholder involvement will enable New York to successfully chart a path forward to a sustainable energy future.
NBB is supportive of the CLCPA initiative and wishes to offer comments and suggestions relating to the white paper that was recently published and policies that could be implemented under the new program.
As an introduction to our comments and suggestions, we would offer the following principles for your consideration:
1. Biodiesel is commercially available now in significant quantities.
2. Given the urgency of climate change mitigation, carbon savings achieved today are far more valuable than what might be accomplished 20 or 30 years from now. Biodiesel is a drop-in fuel that can be implemented with only limited or no equipment modifications.
3. An enormous scope of work would be required to transition residential and commercial buildings to heat pumps for space heating and domestic hot water purposes AND to provide the renewable electricity that would be necessary.
4. We fully support the statement that we need to require rising renewable content in all energy resources used for heating.
5. Taxpayers in the renewable fuel and agricultural industries should be allowed to participate in low carbon programs in New York State.
Summary Comments
1) Eligibility of biomass under the Climate Leadership and Community Protection Act.
The recently enacted Climate Leadership and Community Protection Act of 2019 did not include biomass and biogas as eligible technologies under the definition of renewable energy systems. We believe that the exclusion of biomass and biogas is a major shortcoming of the new law and we will be seeking corrective legislation so that taxpayers employed in the renewable fuel and agricultural industries can fully participate in the achievement of our sustainable energy goals. We would ask for your consideration as we seek legislative amendments to make climate protection programs open to all New Yorkers.
2) Need for realistic forecasting of NYISO grid load impact from building electrification.
The white paper forecast of New York grid loads needs to use more realistic assumptions of expected impacts from building electrification. Estimated reductions in grid loads due to energy
efficiency are overly optimistic. Likewise, projected increases in grid loads due to heat pumps fall far short of what we would consider as reasonable figures. The white paper concludes that overall New York electricity consumption will remain constant in the range of approximately 150 million MWh/yr from present through the year 2050. We would offer that such projection artificially and substantially reduces the calculated level of offshore wind power installations that would be necessary to serve NYISO grid loads during the winter.
We would encourage DPS and NYSERDA to instead use data published in the NYISO 2020 Load and Capacity Data (Gold Book) published just a few months ago. The NYISO Gold Book data are in alignment with NBB estimates and show the peak grid load impact of building electrification in New York as amounting to approximately 40,000 MW or higher by the year 2050. The Gold Book forecast translates into the need for approximately 90,000 MW of nameplate wind power capacity just for heat pumps, using a 45% winter capacity factor. The Gold Book CLCPA forecasting scenario also indicates a total New York peak winter grid load of about 75,000 MW, approximately triple the current peak winter load. This points to the challenge that New York State goals for offshore wind, including the benchmark of 9,000 MW of nameplate wind capacity by 2035, would fill only a small fraction of the power generation gap that would result from the widespread use of heat pumps for space heating and domestic hot water in the residential and commercial sectors. If NYSERDA focuses exclusively on heat pumps, rather than including biomass-based energy resources, the concept of 100% renewable electricity by 2040 will remain unfulfilled and just a distant vision.
The question of winter grid load impact from building electrification has been the subject of increasing attention recently. The recent NYSERDA report entitled, “Pathways to Deep Decarbonization in New York State”, published in late June, provides a capable overview of the balanced, multi-technology approach that would be necessary for achieving our climate protection goals. The NYSERDA report recognizes that the direct use of biomass-derived fuels would enable the building sector to become carbon neutral while reducing the challenge of NYISO grid operations during periods of high-carbon intensity. So again, we would ask for your consideration as we seek to address the energy resource shortcomings of the CLCPA through legislation.
3) Funding for renewable heating technologies
NBB is supportive of incentive programs for efficiency and renewable energy measures that can be implemented within the building sector. Energy efficiency should be the foundation for all other types of energy programs in New York State. While this comment goes beyond the scope of the white paper, we would suggest that carbon program funds currently directed to heat pump installations also be allowed to support other heating system technologies that can efficiently utilize renewable fuels. NBB would suggest the use of financial incentives to encourage the purchase of B100-ready burners, fuel storage systems, and ancillary hardware by residential and commercial Bioheat customers.
We would also suggest that incentives be provided for infrastructure improvements that would foster the accelerated distribution and market availability of renewable fuels. Such improvements could include new biodiesel bulk storage and blending equipment that will be necessary for ramping up biodiesel supply in New York State.
4) Biodiesel for Power Generation.
Laboratory and field testing have shown that biodiesel can also help to reduce NOx emissions in steam-cycle power generation. The natural, 10-12 percent oxygen content of the biodiesel molecular structure can reduce fuel-rich pockets and peak temperatures, which are the primary culprits for NOx formation within the flame.
A significant percentage of existing, gas-fired, combined-cycle power plants in the Northeast United States have the ability to also operate with liquid fuels including biodiesel. Major manufacturers of gas turbine systems, such as GE Power Systems, offer full technical and warranty support for the use of B100 and biodiesel blends in their equipment. The use of biodiesel in combined-cycle power generation offers a huge opportunity for replacing natural gas and thereby reducing greenhouse gas emissions in the power sector.
The use of biodiesel as a low carbon fuel in combustion turbine power systems could also enable the continued operation of such systems in a carbon-constrained economy. This would resolve the potential problem of stranded capital assets if such power systems were to otherwise be forced into retirement due to curtailed use of fossil fuels such as natural gas.
The ability of existing natural gas-fired power plants to “stay alive”, through conversion to the use of biodiesel, in a carbon-constrained economy, would provide enormous practical and economic benefits to the NYISO Forward Capacity Market (FCM) auction process by offsetting much of the growth in capacity that would otherwise be necessary for other types of renewable power facilities that have intensive, upfront capital costs.
The use of biodiesel in existing oil and gas-fired power plants, and capture of electric REC values, would likewise offer economic benefits to the NYISO Day-Ahead and Real-time auction processes by reducing the operating cost of power plants that bid at or near the market clearing price for any given period. Such power plants will be able to reduce their bids, which in turn will directly reduce the market clearing price.
Since all power generators in the Day-Ahead auction process receive the market clearing price, rather than their individual bid amounts, for generating power, the cost savings of a reduced market clearing price would apply across the entire range of wind, solar PV, combined-cycle and steam-cycle bidders. This would create a substantial multiplier effect in terms of the entirety of cost savings across the capacity portfolio as compared to the specific savings of power plants that operate near the market clearing price.
Supplemental Comments
Use of Biodiesel in Thermal Applications at Blend Levels Above B20
Biodiesel blends up to at least B50 can and are currently being used successfully in residential and commercial heating applications. The field experience of retail home heating companies using biodiesel blends up to B50 has resulted in no operability issues or need for appliance adjustments, cleaner burning appliances with less need for maintenance, and this is all achieved at no additional cost to the consumer. It is simply the delivery of up to a 50% biodiesel blended fuel versus ultra-low sulfur diesel fuel.
In November 2018, Brookhaven National Laboratory (Sustainable Energy Technologies Department / Energy Conversion Group) reported “field experience with biodiesel blends has shown no clear technical issue compared to that of conventional No. 2 oil. Overall, the results of this work have not identified a clear technical barrier which would limit the use of biodiesel in home heating systems. It should be emphasized that these results are only applicable to biodiesel which has been properly processed from its parent oil/fat into biodiesel and that meets the stringent ASTM D6751 specification for B100 prior to blending.”2
Cost Savings to Electric Ratepayers
When cold weather comes to the Northeast, and as grid power loads climb, the cost and carbon intensity of power generation at the margin, produced to meet thermal loads, increase as older generation facilities come on line and less environmentally-friendly fuels, such as no. 6 residual oil, are used.
It is understood that New York is seeking to achieve a fully renewable power grid with no further use of fossil fuels. But until the NYISO grid achieves renewable generation all the way to the margin, which is several decades over the horizon, fuels will need to be used to produce power for electrically-driven heat pumps, which add to the already sharp peak-load characteristics of the grid. The high cost of operation for antiquated generation equipment using non-renewable fuels will translate into continuing higher power costs for all ratepayers.
The direct use of renewable fuels, instead of heat pumps, for thermal applications in residential and commercial buildings, would provide relief to the NYISO grid especially during peak load periods, with significant cost savings to all ratepayers.
While several states in the Northeast have implemented ambitious programs to encourage solar PV and wind power, progress has been painfully slow compared to the magnitude of existing customer loads. Even the most optimistic of state energy planning scenarios indicate that it will take several decades for the power grid to become fully renewable. The smart
2 Brookhaven National Laboratory, Sustainable Energy Technologies Department/Energy Conversion Group, B20-B100 Blends as Heating Fuels, November 2018, pages 55-56
economic choice would be to use available taxpayer funds not just for renewable power, but also for energy efficiency and renewable fuels.
Electrification of Heating in Buildings – Real World Performance Is What Matters
It is known that heat pump efficiencies drop considerably during cold weather. Manufacturer claims of high efficiency during cold weather are often based only on highly controlled laboratory testing. Third-party field testing often shows real COPs dropping well below 2.0 due to defrosting and pan heater losses plus operating control issues. The loss of heat pump efficiency, along with the issue of power grid performance, substantially negate the common claim that heat pumps always achieve greenhouse gas savings compared to fuel-fired systems.
The graph below shows hourly CO2 emission rates for liquid fuels versus a typical, cold-climate heat pump for a single-family home in New England on a moderately cold day during February 2019. The graph uses ISO New England marginal generation data for that day, but based on our analysis, the carbon intensity patterns of ISO New England and the downstate control zones of NYISO are similar in terms of both cold weather-based peaks and also short duration, morning/evening peaks during moderate weather. The graph shows that cold-climate heat pumps can indeed achieve average CO2 savings in the range of 40 to 50% compared to traditional heating oil. But the data in the graph also show that a B50 biodiesel blend would accomplish the same GHG savings as a cold-climate heat pump, and additionally, the use of B100 would achieve double the environmental benefits with 80% CO2 savings.
Additionally, the lowest carbon intensity option entails the use of B100 in an absorption heat pump. Notably, the CO2 emissions rate for the cold-climate heat pump option increases substantially during morning and evening peak periods due to the use of lower efficiency power generation systems such as simple-cycle combustion turbines and fuel-fired steam cycle plants, which suffer heavy environmental penalties of excessive fuel consumption and NOx emissions during start-up.
Hourly CO2 Emission Rates lbs/hr Typical Single Family Home in New England February 4, 2019
6 --ULSD
5 --B20 i: 4 -;;;- --B50 f! 3 N 8 2 --B100
--B100 plus Absorption 0 Heat Pu mp 0 10 20 30 - Co ld Climate Heat Hour Pump
Figure 1. Hourly CO2 Emissions Rates for Single-family Home During Moderately Cold Day
The graph below shows hourly CO2 emission rates for liquid fuels versus a typical, cold-climate heat pump for a single-family home in New England on a severely cold day during the month of February 2019. The graph again incorporates ISO New England marginal generation data for that day, which again should be similar to downstate NYISO data, and which result from gas- fired combined cycle systems providing output to the grid at the margin during overnight hours, then gas-fired, simple cycle turbines providing output at the margin during morning and mid- day hours, then oil-fired, simple cycle turbines providing output at the margin during the evening peak period, then back to gas-fired, simple cycle turbines during the late evening. The graph shows that the combination of increasing carbon intensity of the grid, combined with a dropping cold-climate heat pump COP, results in a net carbon intensity that is greater than traditional heating oil for most hours of that day. Again, the use of B100 would achieve 80% CO2 savings, and the lowest carbon intensity option would entail the use of B100 in an absorption heat pump.
Hourly CO2 Emission Rates lbs/hr Typical Single Family Home in New England January 21, 2019 14 ~ ULSD
12 - ~ B20 I ~ ~ 10 --- .c y -;;, 8 ,...,- -a-B50 ,e N 6 0 . ""*-B100 u 4 2 ~ B100 plus Absorption 0 Heat Pump 0 5 10 15 20 25 ~ Cold Climate Heat Hour Pump
Figure 2. Hourly CO2 Emissions Rates for Typical Single Family Home During Severely Cold Day
It is apparent from recent ISO New England and NYISO discussions about reducing the carbon intensity of power generation that a solid understanding of grid operations is necessary for establishing successful policies and programs for renewable heating of buildings.
Some important points to consider include the following:
1) As grid loads increase during cold weather due to temperature-dependent heating loads, or during customary morning and evening peak periods, the additional power plants that come online at the margin are typically steam-cycle stations or peaker combustion turbines, not combined-cycle plants or renewable resources, which would normally already be in operation to handle base loads.
2) As grid loads increase, the efficiency of power generation, procured to meet thermal loads, will decrease. The fuel-to-electric operating efficiency (start + production) of many power plants at the margin can drop to well below 30 percent. This negates the common claim that heat pumps always achieve greenhouse gas savings compared to fuel-fired systems.
3) Locational-based Marginal Prices (LBMPs) are based on the market clearing price set by the power plant at the margin which, by definition, will have the highest bid price.
4) The LBMP is then paid to all operating generators within a control zone. This means that the total cost of power to customers is set by the most expensive generator to clear the auction, not the average of the costs bid by the aggregate of generators. Increasing grid loads mean higher $/kWh costs for everybody.
5) The slope of the curve of LBMP vs. grid load can be fairly steep at the margin during cold weather, or during morning and evening peaks, due to the rapid decline in power generation efficiency vs. load, and also due to the additional strain on the natural gas pipeline system. The cost surcharge to ratepayers due to added thermal load will be the delta LBMP times the entire number of MWh sold within a control zone, not just the MWh sold for heat pumps. So the economic penalty of adding load to the grid during already high demand periods can be a substantial economic burden to ratepayers.
The above fundamental principles need to be recognized and addressed during DPS and NYSERDA planning activities relating to heat pumps and other electrification measures.
NYISO Grid Load Growth Due to Heat Pumps
If heat pumps were to replace nearly all liquid fuel and natural gas use for thermal applications by residential buildings in New York, about 30,000 MW of additional load would be added to the existing NYISO winter peak grid load of about 25,000 MW, thus more than doubling the capacity required.
The conversion to heat pumps in the commercial/industrial/institutional sector as well would yield an additional winter peak load of about 15,000 MW on top of the residential increase. The resulting NYISO winter peak load, after the forecasted electrification of heating, would be about 60,000 MW and thus several times greater than even the most optimistic forecasts of renewable power and battery storage for the region. These figures are supported by the NYISO Gold Book of 2020. Further, since offshore wind power systems operate with a capacity factor of about 45% during the winter, a total nameplate capacity of nearly 100,000 MW would be required. The availability of large quantities of battery storage could reduce the required capacity by up to one-third, but with substantially increased capital cost. Since the gap between required generation capacity and availability of renewable power would have to be filled by fuel-fired power plants, the electrification of heating would result in a major increase, not decrease, in the use of fossil fuels for power generation.
Any creditable forecast of renewable power growth in New York would result in the need to limit the use of heat pumps to just mild and moderate weather conditions, and outside of typical morning/evening peak periods. The notion, that existing fuel-fired heating systems could be preserved for use during just extreme cold weather, has no technical or economic credence.
Numerous field studies of residential heat pumps have also shown repeated patterns of use that are limited by homeowners who sense the economic problems of cold-weather heat pump performance and intuitively limit usage to just mild weather.
The common perception that heat pumps will enable “zero emissions” heating is simply not true. The sufficient availability of solar PV and wind power plus battery storage on the New York grid, sufficient to meet thermal load-driven peak loads, is far over the horizon. Increased power loads due to heat pumps will ironically increase, not decrease, the need for old, polluting, peaking turbines.
The challenge of providing for the heating needs of millions of residential and CII buildings in New York, and eliminating the use of fossil fuels, cannot be more than just partially addressed through the use of heat pumps. Energy policymakers need to recognize that renewable fuels are a key part of the “all hands on deck” approach that will be necessary to achieve a sustainable energy future.
We would encourage DPS and NYSERDA to therefore break new ground in how state energy planning is conducted, by charting a reasonable forecast of renewable power growth in New York, and then to develop thermal programs that could heat pump installations within the electricity budget afforded by reasonable, renewable power growth rates, but which would then fill the remaining gap through the environmentally responsible use of renewable fuels.
Local Air Quality Impact and Environmental Justice Concerns from Power Generation for Heat Pumps
The table below shows NOx emission factors (lbs per MMBTU of delivered heat) for Bioheat- fired boilers and for cold-climate heat pumps driven by several common configurations of power generation with and without emissions controls.3,4 The table shows typical values for both steady-state and peaking operation.
3 Alternative Control Techniques Document – NOx Emissions from Stationary Gas Turbines, U.S. Environmental Protection Agency, Office of Air and Radiation, January 1993 4 Startup and Shutdown NOx Emissions from Combined-Cycle Combustion Turbine Units, R. Bivens, EPRI CEM User Group Meeting, May 2002
Biodiesel-fired Boilers and Electric Heat Pumps Typical NOx Emission Factors lbs per MMBTU Delivered Heat
Steady-state 4 hr Peak Load
Combined Cycle 0.02 lb per MMBTU 0.15 lb per MMBTU w/SCR and OC (5 ppm @ 15% O2)
Combustion Turbine 0.03 lb per MMBTU 0.25 lb per MMBTU w/SCR and OC (5 ppm @ 15% O2)
--·- B20 – B100 Boiler 0.10 lb per MMBTU 0.10 lb per MMBTU :·.~· . (<100 ppm @ 3% O2)
Combustion Turbine 0.16 lb per MMBTU 0.25 lb per MMBTU WU . . . . . • • • • • w/DLN or H2O _,.,.• ,.,~ -~' ...... •·" ..•·" ~,,,.~ -·"' ,•.. (30 ppm @ 15% O2)
Steam Cycle Gas/Oil 0.25 lb per MMBTU 0.30 lb per MMBTU (200 ppm @ 3% O2)
Combustion Turbine 0.80 lb per MMBTU 1.00 lb per MMBTU w/o emissions control (150 ppm @ 15% O2)
Figure 3. Typical NOx Emission Factors for Residential and Commercial Boilers and Heat Pumps
Although combined-cycle and simple cycle, combustion turbine systems, with selective catalytic reduction (SCR) and oxidation catalyst (OC) emission controls, can indeed produce lower levels of hourly NOx emissions than direct-fired combustion systems during off-peak, steady-state operation, it must be remembered that most thermal loads occur during either morning/evening peak periods or during cold weather, when peaking operation becomes dominant for power generation at the margin. Under peak load conditions, the direct combustion of B20 to B100 blends show the lowest level of NOx emission factors among the options shown.
Heat pump operation during winter peak periods can thus frequently result in higher total NOx emissions than individual fuel-fired heating systems. One 350 MW combined-cycle unit (e.g., GE Series 7 HA Frame with HRSG) could heat 60,000 homes via cold-climate heat pumps but would emit NOx equal to about 120,000 natural gas/Bioheat-fired home heating systems during a 2 hr start-up period from cold or lukewarm generator status. The low-level, area source of NOx associated with the direct combustion of biodiesel blends would then be concentrated into a major point source that falls under USEPA Title 5 Clean Air Act emissions standards. Possible environmental justice concerns would result due to high local emissions in economically disadvantaged neighborhoods adjacent to power plants.
The negative air quality impact of temporally coincident turbine start-up is going to become even more pronounced as large-scale commercial, solar PV systems become more numerous. The graph below refers to the growing “duck curve” problem in California which results from the sharp decline in renewable power output during the late afternoon just when grid loads begin rising to their customary evening peaks.5
...... Growing need for flexibility starting 2015
Net load '27,000
'25,000
'23 ,000
21 ,000
! 19,000
r 17,000
15,000
0 1 2 l , 5 6 7 I 9 10 II 12 ll i.. 15 16 17 18 19 '20 21 22 23
CalifomiolSO
Figure 4. Graph of “Duck Curve” nature of diurnal solar PV output and grid load trends
We would offer that DPS and NYSERDA should perform a comprehensive analysis of power generation in New York and consider the imposition of requirements for NOx offset projects to mitigate negative air quality impacts in economically disadvantaged neighborhoods, adjacent to power plants, which arise from thermally-driven grid loads.
Challenges to Offshore Wind Power Development
Below, we have noted several links to US Department of Energy (DOE) and National Renewable Energy Laboratory (NREL) reports that review issues associated with wind power in the US and the Northeast Region in particular.
NREL’s report entitled “2016 Offshore Wind Energy Resource Assessment for the United States”6 addresses the technical and economic potential for offshore wind energy based on factors such as distance from shore, depth of water, power density (MW/km2) of wind farms, and interconnection with the power transmission system.
Two key principles described in the report are the recommended wind farm density limit of 3 MW/km2 (about 8 MW per square mile) and the cost multiplier that is triggered by the need for
5 Confronting the Duck Curve: How to Address Over-Generation of Solar Energy, Office of Energy Efficiency and Renewable Energy, US Department of Energy, October 2017 6 https://www.nrel.gov/docs/fy16osti/66599.pdf
floating, rather than fixed, platform construction in water depths of 200 feet or more. Both parameters are of particular importance along the New York coast.
DOE’s “Wind Vision” report7 reflects the constraints described in the NREL report noted above by suggesting economic potential for 86,000 MW of nameplate offshore wind capacity by 2050 for the entire United States. Such level of offshore wind energy growth is notably less than the capacity that would be required to serve heat pumps in New York, and thus raises a planning issue for policymakers, reinforcing NBB’s philosophy that a portfolio of technological solutions will be needed to meet New York’s—or any other state’s—GHG reduction goals.
Biodiesel - Direct Path to a Sustainable Energy Future
Biodiesel is a renewable replacement for diesel BIODIESEL - WHERE DOES IT COME FROM? fuel and natural gas. It is made from used cooking oil, animal fats, brown (sewer) grease, and agricultural byproducts and co-products.
The feedstock used to produce U.S. biodiesel
Soybean and Canola Oil Used Cooking Oil Oilseed Cover Crops has become increasingly diversified, with waste products making up an increasing volume of feedstock used to produce fuel. Biodiesel offers an especially effective outlet for fat-
Brown Grease Animal Fats Algae based waste streams that can cause substantial cost for disposal.
Several different types of plants, including soybeans, canola, and pennycress, can also provide feedstock for biodiesel production. It is important to understand that demand for protein meal used as livestock feed is the primary driver for the planting of soybeans since 80 percent of a soybean is comprised of protein meal. The remaining 20 percent of the soybean is comprised of oil which cannot be digested by animals and must therefore be removed. The biodiesel industry helps to make economical use of this excess oil with the result that the net cost of protein meal is reduced.
Biodiesel achieves greenhouse gas (GHG) emissions of about 80% compared to oil-fired combustion systems and about 70% compared to natural gas-fired systems. Biodiesel thus provides a direct pathway toward achieving the common energy policy goals of 40% GHG savings by the year 2030 and 80% GHG savings by the year 2050. The carbon savings of biodiesel will continue to improve as agricultural practices, such as no-till planting and winter cover cropping, and also feedstock processing become more efficient.
7 https://www.energy.gov/eere/wind/wind-vision
Biodiesel can be blended with heating oil (including no. 2 through no. 6 oils) to improve the operational and environmental performance of oil-fired systems. Biodiesel reduces emissions that are harmful to human health and the environment including particulate matter, sulfur oxides, nitrogen oxides, carbon monoxide, and aromatic hydrocarbons.
Recent testing has shown that B100 neat biodiesel can be used in boiler systems via engineered conversions that incorporate cleaning and usually just limited, hardware upgrades to fuel storage systems and burners. B100 biodiesel can enable buildings to immediately achieve the 80% GHG savings that are necessary for protecting our environment. Biodiesel can also be used as a supplement or replacement for natural gas in buildings that have existing or retrofit, dual- fuel capability in their boiler or furnace systems. Biodiesel provides a technically feasible pathway for gas-fired heating systems to achieve a sustainable energy future while PHOTO A. A8100-fired boiler in a Brookhaven National Laboratorv testina facilitv. maintaining clean emissions performance.
Biodiesel production offers the opportunity for significant job creation in the agricultural and food industry sectors throughout the US. New York is already a significant producer of biodiesel feedstocks, and also has good access to rail and water transportation, and could thus further expand its role in biodiesel production.
New York has addressed food and fuel concerns in its Bioheat® law by allowing only US EPA- approved “Advanced Biofuel” feedstocks, which must meet a 50% lifecycle greenhouse gas threshold. Recent reports and publications from Argonne National Laboratory state that biodiesel from virgin oil feedstock in fact now achieves greenhouse gas (GHG) savings of 66 to 72%, even with consideration of indirect land use change (ILUC), and up to 81% of direct carbon savings. US EPA regulations also preclude palm oil and palm derivatives as feedstocks for biodiesel.
The notion that biodiesel feedstocks are diverted from food supplies is a myth. Most biodiesel manufactured in the Northeast is made from used cooking oil. But importantly, the virgin oils used for biodiesel production in the US are coproducts of protein production. For every gallon of biodiesel produced from soybean oil, 30 pounds of protein and 22 pounds of carbohydrates and dietary fiber enter the food supply.8 The natural symbiosis of stored solar energy in the food supply is a reason to promote biofuels coproduced from food commodities. Sustainable energy systems and a circular economy should embrace the fundamental idea of harnessing more bioenergy from these natural systems that are essential to feeding a growing global population.
8 One gallon of biodiesel requires 7.5 pounds of vegetable oil. Every pound of soybean oil is coproduced with approximately 4 pounds of protein meal. 7.5 x 4 = 30 pound of protein meal.
Between 2004 and 2011, global land in agricultural production declined by 60 million acres9 and forested area increased by 19 million acres. This was possible because farmers produced more food per acre. They did so by growing less grass for beef and ruminant consumption, and by growing crops that produce more protein, fat, and soluble carbohydrates per area. Biofuels can improve both the economics of food production and the sustainability of energy supplies. The more efficient production of protein from fewer acres results in overproduction of fat beyond what can be consumed as food10. Biodiesel is a key outlet for this excess fat. Biodiesel also enables the transition to more efficient agriculture and a world with more room for forests.
Other new sources of biodiesel feedstock under development include winter annual oilseeds, which can be planted in the fall and harvested in May or June of the following year. As an example, the promise for CoverCress (field pennycress with specific oil and fiber traits) stems from the fact that it fits into an existing traditional corn-soy rotation without materially affecting either of those crops. The crop can reduce runoff and loss of nutrients during the winter, thus improving soil biology and providing an additional revenue stream for farmers.
In conclusion, biodiesel is a clean burning liquid heating fuel that can fit directly into the carbon reduction plans being developed by states looking to reduce greenhouse gas emissions in the space heating sector. While there have been many questions/concerns raised over the years – feedstocks, emissions, supply and infrastructure – they all have been addressed and answered positively. If New York is seeking an alternative to space heating with fossil fuels, at little or no cost to the consumer, biodiesel is the answer, as it is a drop-in heating oil replacement and can be used in current home heating appliances. Biodiesel provides a seamless alternative for low income households as they can keep their current home heating system and not incur the installation costs of a heat pump system. Furthermore, those homes would not add to the electric load needed if they were converted to heat pumps.
Fuel Quality
Biodiesel and BioHeat® are high quality fuels meeting or surpassing ASTM standards. The National Biodiesel Accreditation Program is a cooperative and voluntary program for the accreditation of producers and marketers of biodiesel fuel called BQ-9000®. The program is a unique combination of the ASTM standard for biodiesel, ASTM D6751, and a quality systems program that includes storage, sampling, testing, blending, shipping, distribution, and fuel management practices. Sourcing biodiesel from a BQ9000 producer or marketer provides additional assurance that the product meets and often exceeds ASTM specifications.
9 Taheripour et al. (2017), Taheripour, Zhao, and Tyner. “The Impact of Considering Land Intensification and Updated Data on Biofuels Land Use Change and Emissions Estimates,’ Biotechnology for Biofuels (2017) 10:191; https://biotechnologyforbiofuels.biomedcentral.com/articles/10.1186/s13068-017-0877-y 10 Taheripour et al. (2018). “Technological Progress in US Crop production: Productivity Gains, Abundant Supply of Crop Calories, Evolution in the Livestock Industry and Implications for Biofuel Production, International Conference of Agricultural Economists, August 2018 Vancouver; 10.22004/ag.econ.277291
As previously mentioned, the NBB strongly recommends that all renewable liquid fuels used for residential, commercial and industrial heating purposes as well as transportation fuel meet the specifications of ASTM standards D396, D7467 (B6-B20) and D6751 (B100). This prohibits certain “pseudo-fuels” that are not considered fit-for-purpose by ASTM, such as viscous renewable diesel fuel among others, from entering the marketplace and causing unintended negative consequences in heating and fueling systems until such new fuels have conducted the proper research and secured ASTM standards for such materials.
Increasing Availability in the Marketplace
Biodiesel is a renewable, low-carbon, diesel replacement fuel that is widely accepted in the marketplace. It is the only commercial-scale Advanced Biofuel under the U.S. EPA Renewable Fuels Standard (RFS2) program. Biodiesel is one of the best-tested alternative fuels in the country and the only alternative fuel to meet all of the testing requirements of the 1990 amendments to the Clean Air Act. There are currently more than 150 biodiesel plants in the U.S. with a combined production capacity of over 3 billion gallons.
Biodiesel is primarily marketed as a blending component with conventional diesel fuel and heating oil in concentrations between two (B2) and twenty percent (B20). It is distributed utilizing the existing fuel distribution infrastructure with blending occurring both at fuel terminals and “below the rack” by fuel marketers. Certain fuel distributors have also begun to market B100 biodiesel for thermal applications in the residential, commercial and industrial sectors.
Biodiesel is Good for the Environment
Biodiesel is environmentally safe and is the most viable renewable fuel for transportation, power generation and thermal applications, based on its low carbon footprint and favorable air quality characteristics. A full life-cycle analysis performed by U.S. EPA for RFS2 shows that biodiesel reduces greenhouse gas emissions by as much as 81 percent compared to traditional heating oil and diesel fuel.
We would stress the importance of performing due diligence evaluation of all renewable resources, with emphasis on economic benefits and least-cost solutions including capital cost factors (e.g., upfront costs for heat pump equipment vs. drop-in application for renewable fuels) that can impact the level of economic burden on consumers and businesses during the transition to a renewable energy future.
The Biodiesel Industry Stimulates Development of New Low Carbon Feedstocks
The feedstock used to produce U.S. biodiesel has become increasingly diversified, with waste products such as animal fat and used restaurant cooking oil (yellow grease) making up a larger portion of feedstock used to produce fuel. The National Renewable Energy Laboratory (NREL) recently conducted an extensive report on the availability of yellow and brown grease. That report concludes that 9.4 pounds of yellow grease and 13 pounds of brown grease are available on an annual, per capita basis throughout the U.S. These figures should be used to more accurately forecast the amount of feedstock available in the Northeast and Mid-Atlantic states. NBB estimates that, nationally, these feedstocks can produce more than 900 million gallons of biodiesel. In addition, a report commissioned by the NBB addresses the use of animal fat, which has also become a major contributor of waste feedstock.
Biodiesel production is currently the most efficient way to convert sustainable biomass into low carbon diesel replacement fuel. As a result, industry demand for economical, low carbon, reliable sources of feedstock oils is stimulating promising public, private, and non-profit sector research on so-called “second generation” feedstocks such as algae. The NBB is participating in this effort by making substantial investments in algae research in collaboration with the Donald Danforth Plant Science Center. It is estimated that for every 100 million gallons of biodiesel produced from algae, 16,455 jobs will be created and $1.461 billion will be added to the national gross domestic product.
Algae’s potential as a source of low carbon fuel has been well documented, and a stable, growing biodiesel end-use industry is necessary if the U.S. is to eventually benefit from the commercial scale production of algal-based biofuels. The NBB estimates that for every 100 million gallons of biodiesel produced from algae, 16,455 jobs will be created and $1.461 billion will be added to the GDP.
While soybean oil is considered a co-product rather than a waste feedstock, further discussion of this raw material is merited since farmers in several Northeast and Mid-Atlantic states produce soybeans. In 2007, approximately 39 million bushels of soybeans were grown in the states of Delaware, Maryland, New Jersey, New York, and Pennsylvania. The oil derived from this crop should be considered a sustainable, regional feedstock.
It is important to understand that demand for protein meal used as livestock feed is the primary driver for the planting of soybeans since 80 percent of a soybean is comprised of protein meal. Only 20 percent of the bean is comprised of oil. Historically, the demand for protein meal has driven soy production, resulting in a supply of soybean oil that exceeds the demand for food uses (primarily deep frying foods and baking products). The biodiesel industry helps to make economical use of this excess oil. By creating a market for this excess oil, the price of the protein meal is reduced on a proportional basis.
Biodiesel Increases Energy Security and Competition
Biodiesel is produced in geographically diverse, local facilities that are often located in close proximity to end-use markets. Production facilities are not concentrated in any particular region and are thus less vulnerable than many other types of energy resources to widespread disruption during weather disasters.
Co-products Have Important Sustainability Benefits
The co-product relationship between soybean oil and soybean meal delivers environmental benefits because no crop land and no inputs, such as water, nutrients, and energy, are used solely for production of renewable fuel. The co-product relationship optimizes the beneficial uses from crops that will be planted anyway to satisfy demand for livestock feed and other uses. Growth in biodiesel volumes will come from more efficient utilization of existing wastes and additional vegetable oil produced as a result of yield increases on existing acres, the growing demand for livestock feed, and decreasing demand for high-trans-fat vegetable oils.
The federal RFS2 program explicitly prohibits land conversion for the purpose of producing renewable fuel. U.S. EPA requirements notwithstanding, basic economics dictate that the production of oilseed crops must correlate to the demand for protein meal, and cannot expand solely in response to demand for vegetable oil. It is impossible for oil demand alone to drive the planting of oilseed crops in North America.
Conclusion
The National Biodiesel Board is pleased to support New York State programs that can ensure a sustainable energy future. Biodiesel can enable New York to achieve environmental sustainability and improved local air quality while realizing the economic benefits that come from new job creation.
Sincerely,
Shelby Neal Director of State Government Affairs