U.S. producers are not the only ethanol producers who have serious concerns about the pending U.S. EPA rule to implement the second stage of the renewable fuels standard (RFS2). The Caribbean Basin Ethanol Producers Group, which consists of Trinidad Bulk Traders Ltd., Gasohol de El Salvador, LAICA of Costa Rica, Petrojam Ltd., Jamaica Ethanol Co., and Jamaica Broilers Group, said in a comment filed with the U.S. EPA Sept. 15 that if the rule is finalized as proposed it “could shut down our industry.”
The group operates dehydration facilities in the Caribbean. George Fitch, executive director of the group, said the facilities use hydrous ethanol from Brazil as their primary feedstock. However the feedstock tracking provision of the proposed RFS2 rule would make the facilities unable to comply with U.S. rules. “It is impossible for us to verify that the hydrous ethanol we purchase from Brazil was made from sugarcane on land currently under cultivation,” he wrote. “For most of us, we have one large tank for incoming hydrous alcohol and one large tank for outgoing anhydrous ethanol.” Fitch continued to explain that feedstock is co-mingled in the tank as new shipments arrive and as new batches of anhydrous ethanol are added to the tank before being shipped to the U.S. “Therefore, it is impossible to trace the anhydrous ethanol back to a particular sugarcane mill in Brazil.”
Article Continues After Advertisement
Some U.S. producers have expressed similar concerns related to the feedstock tracking element of the proposal. (See “RFS2 rule could require biofuel producers to track feedstock.”) They also have stated it would be extremely difficult to track a feedstock's origins in the manner suggested by the EPA.
The solution proposed by Fitch is that the traceability requirements be modified “to reflect the nature of how hydrous ethanol is collected, shipped, discharged, processed and stored.” The Caribbean producers would also like to be grandfathered as producers of advanced biofuels, even though their facilities currently use fossil fuels to operate, and request that modifications be made to the renewable identification number (RINs) system to allow the importer of dehydrated ethanol to generate the RINs.
The EPA is currently reviewing comments submitted on the proposed RFS2 and is scheduled to issue its final rule by Dec. 1. However, many members of the ethanol industry believe the final rule will be delayed until mid-2010 or later.
