EPA comment period closed on corn fiber as ag residue, biobutanol

By Holly Jessen | July 18, 2013

In all, the U.S. EPA received 117 comments on a proposed rule on renewable fuel standard (RFS) pathways, including corn kernel fiber-to-cellulosic ethanol and issues relating to biobutanol. The comment period ended July 15.

The Renewable Fuels Association submitted 28 pages of comments on the proposed rule. In it, the group supported EPA’s efforts to add corn kernel fiber to the list of qualifying cellulosic biofuel feedstocks as well as what it called a simplified approach to cellulosic RIN generation. “We applaud EPA for confirming that corn kernel fiber is ‘crop residue,’ and believe the agency has proposed a sensible and straightforward approach to RIN generation for renewable fuels derived from cellulosic biomass feedstocks,” wrote RFA President and CEO Bob Dinneen. “Several technologies to convert corn kernel fiber into cellulosic ethanol have been developed in recent years, and a number of existing ethanol plants have already adopted these technologies or are poised to integrate them in the near future. The volumes of cellulosic ethanol produced from corn kernel fiber can meaningfully contribute to RFS2 cellulosic biofuel requirements in the near term.”

Growth Energy’s comments advocated for additional pathways to meet the goals of the RFS, including the pathway of corn fiber-to-cellulosic ethanol and other crop residues. “We believe that any renewable biomass meeting the 60 percent greenhouse gas threshold should be able to generate cellulosic RINs,” the comments said.

The National Corn Growers Association also submitted comments. The group said it felt all biomass feedstocks should be categorized as renewable and that corn fiber should be defined as crop residue as well as qualify as a feedstock for cellulosic ethanol, generating D3 RINs.  “100 percent of the volume of renewable fuel from specific cellulosic feedstock sources should be allowed to generate D3 or D7 RINS as appropriate,” said NCGA President Pam Johnson.

Two other commenters included Quad County Corn Processors Co-op, an ethanol plant in Galva, Iowa, and Illinois River Energy LLC, an ethanol plant in Rochelle, Ill. Quad County has developed a patent-pending process for converting corn kernel fiber into cellulosic ethanol. It’s a post-processing technology that ferments the starch first and then the fiber, rather than a concurrent process that would ferment both at the same time. Delayne Johnson, general manager of the ethanol plant, outlined why the business agreed with EPA, that corn kernel fiber should qualify as a crop residue. He also pointed to current regulations, which allow incidental contaminants to be disregarded when they are impractical to remove, adding that the quantify of starch, protein and oil remaining attached to the corn kernel fiber should be viewed as deminimus quantities and not excluded from the definition of crop residue.

Neal Jakel, general manager of Illinois River Energy, commented that additional feedstocks for cellulosic ethanol are needed. “Corn kernel fiber provides a near-term opportunity, requiring no additional supply chain, very limited capital costs, and allows our plant to leverage current assets,” he said. “We support this rulemaking to the extent that it would remove a regulatory barrier to introduction of corn kernel fiber-based ethanol into the marketplace with D-code 3 RINs.”

Another part of the proposed rule dealt with biobutanol, with the EPA proposing that the RVP standard would be applied to circumstances where biobutanol and ethanol are blended. Butamax Advanced Biofuels LLC, a joint venture of BP and DuPont, commented saying it supported that approach. “Butamax believes that the proposals in this rule will greatly facilitate implementation of the renewable fuel standard in a manner which works well for all of the stakeholders,” wrote Paul Beckwith, CEO of the company.

The RFA also chimed in on this issue, saying it supported the approach but added that it felt it should be limited to situations where “blending an approved gasoline additive with E10 results in no net increase in RVP.” The NCGA added that, “the existing RVP standards should be applied such that commingled blends would be considered in compliance as long as the separate components of the commingled products were in compliance with the RVP standards prior to the mixing,” Johnson wrote. “As such, this then assumes the one pound waiver would be applicable to blends between nine and ten psi, just as is currently allowed for E10.”

To read more comments, see www.regulations.gov