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Regulatory Renovation Clean Power Plan Rule Crafting Page 16 www.biomassmagazine.com July 2015 Plus: State Renewable Portfolio Standard Trends Page 26 And: Q3 Biomass Construction Update Page 10

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Emissions, Permitting & Regulatory Compliance Issue. PLUS: 2nd Quarter 2015 Biomass Construction Update

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Page 1: July 2015 Biomass Magazine

Regulatory Renovation

Clean Power Plan Rule Crafting

Page 16

www.biomassmagazine.com

July 2015

Plus:State Renewable Portfolio Standard TrendsPage 26

And:Q3 Biomass Construction Update

Page 10

Page 2: July 2015 Biomass Magazine

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Publications Biomass Mag, Ethanol Prod

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NEW HOLLANDIS YOUR

SMART BIOMASSEQUIPMENT PROVIDER.

© 2015 CNH Industrial America LLC. All rights reserved. New Holland Agriculture is a trademark registered in the United States and many other countries, owned by or licensed to CNH Industrial N.V., its subsidiaries or af­ liates. New Holland Construction is a trademark in the United States and many other countries, owned by or licensed to CNH Industrial N.V., its subsidiaries or af­ liates.

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Page 3: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 3

INSIDE¦

JULY 2015 | VOLUME 9 | ISSUE 7

Subscriptions Biomass Magazine is free of charge to everyone with the exception of a shipping and handling charge of $49.95 for anyone outside the United States. To subscribe, visit www.BiomassMagazine.com or you can send your mailing address and payment (checks made out to BBI International) to Biomass Magazine Subscriptions, 308 Second Ave. N., Suite 304, Grand Forks, ND 58203. You can also fax a subscription form to 701-746-5367. Back Issues & Reprints Select back issues are available for $3.95 each, plus shipping. Article reprints are also available for a fee. For more information, contact us at 701-746-8385 or [email protected]. Advertising Biomass Magazine provides a specifi c topic delivered to a highly targeted audience. We are committed to editorial excellence and high-quality print production. To fi nd out more about Biomass Magazine advertising opportunities, please contact us at 701-746-8385 or [email protected]. Letters to the Editor We welcome letters to the editor. Send to Biomass Magazine Letters to the Managing Editor, 308 2nd Ave. N., Suite 304, Grand Forks, ND 58203 or email to [email protected]. Please include your name, address and phone number. Letters may be edited for clarity and/or space.

14 NEWS

15 COLUMNCalifornia Biomass Support Sets Good ExampleBy Bob Cleaves

16 DEPARTMENT Readying for a Regulatory LandingThe Clean Power Plan will require coal plants to cut emissions, but biomass’s role in that mission is unclear.By Katie Fletcher

POWER

06 EDITOR’S NOTEThe Inevitable BattleBy Tim Portz

08 BUSINESS BRIEFS

10 BIOMASS CONSTRUCTION UPDATE

46 MARKETPLACE

16

WORK IN PROGRESS: The U.S. Capitol Dome was constructed of cast iron more than 150 years ago, and has not undergone a complete restoration since 1960. Due to age and weather, it has experienced more than 1,000 cracks and defi ciencies. The Architect of the Capitol recently began a multi-year project to repair them.PHOTO: ARCHITECT OF THE

CAPITOL

PELLETS 20 NEWS

21 COLUMNOmission of Wood Heat Goes Too FarBy John Ackerly

22 CONTRIBUTION Regulation of Europe-Bound US Wood PelletsTo capitalize on surging European demand, American wood pellet suppliers need to ensure compliance with regulations.By Virginia E. Worthy and Mark Aspinall

Page 4: July 2015 Biomass Magazine

A S T E C

FINAL PELLET MILL MAG BKCOV.indd 1 4/25/14 11:40 AM

Page 5: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 5

BIOGAS

28 NEWS

30 FEATUREUdder Confusion: Dairy Digester Development in CaliforniaThe state leading the U.S. in diary production and carbon reduction efforts sends mixed messages in developing projects that capitalize on both.By Ron Kotrba

JULY 2015 | VOLUME 9 | ISSUE 7

THERMAL

24 NEWS

25 COLUMNThermal Incentives Heat UpBy Ben Bell-Walker and Joseph Seymour

26 DEPARTMENT Thermal ReinforcementIntegrating or evaluating the potential of renewable heat within renewable portfolio standards is trending in the U.S. By Anna Simet

ADVANCED BIOFUELS & CHEMICALS

34 NEWS

35 COLUMNA Look at EPA’s RVO ProposalBy Michael McAdams

36 DEPARTMENTCrunching the NumbersFirst- and second-generating ethanol producers rallied at the International Fuel Ethanol Workshop & Expo in Minneapolis.By Anna Simet

INSIDE¦ADVERTISER INDEX¦

2015 National Advanced Biofuels Conference & Expo 40

Airofl ex Equipment 14

Andritz Feed & Biofuel A/S 24

ASGCO 9

Astec, Inc. 4

BBI Project Development 29

BRUKS Rockwood 23

CPM Roskamp Champion 28

CPM Wolverine Proctor, LLC 34

DI PIÙ 18

IEP Technologies 32-33

IHI Power Services Corp. 37

KEITH Manufacturing Company 12

MonitorTech Corporation 19

New Holland Agriculture 2

Pellet Fuels Institute 39

ProcessBarron 8

Retsch, Inc. 13

WASTECON 2015 7

West Salem Machinery Co. 20

30

Biomass Magazine: (USPS No. 5336) July 2015, Vol. 9, Issue 7. Biomass Magazine is published monthly by BBI International. Principal Offi ce: 308 Second Ave. N., Suite 304, Grand Forks, ND 58203. Periodicals Postage Paid at Grand Forks, North Dakota and additional mailing offi ces. POSTMASTER: Send address changes to Biomass Magazine/Subscriptions, 308 Second Ave. N., Suite 304, Grand Forks, North Dakota 58203.

TM

Please recycle this magazine and remove inserts or samples before recycling

COPYRIGHT © 2015 by BBI International

Page 6: July 2015 Biomass Magazine

6 BIOMASS MAGAZINE | JULY 2015

The Inevitable Battle

The renewable fuel standard (RFS) is the greatest piece of renewable energy policy the world has ever seen, according to Brooke Coleman, executive director of the Advanced Ethanol Council. Coleman would likely agree that, consequently, the RFS has also gener-ated the largest policy backlash and opposi-tion the world will ever see. The RFS, origi-nally passed as part of the Energy Policy Act of 2005, was expanded and extended in the Energy Independence and Security Act of

2007. It gave rise to a corn ethanol industry with annual production values of over 14 billion gallons, or right around 10 percent of the annual U.S. gasoline consumption. As successful as the RFS has been, those who have dedicated their livelihoods to fulfilling the mandate are now fighting to defend it. This is illustrated in Managing Editor Anna Simet's page-36 department, "Crunching the Numbers," a summary of Coleman's and other biofuel stakeholders' com-ments at the 2015 International Fuel Ethanol Workshop & Expo. While this may seem counterintuitive to the general public, renewable energy advocates are likely to react with a knowing and affirmative shrug of the shoulders.

Ours is an industry looking to take market share, often in declining mar-kets, from well-entrenched incumbents who can only be expected to rabid-ly defend their enviable market position. In nearly every category, industry groups are drafting, working to generate support for, expanding or defending existing renewable energy policies that are so vital to the greater biomass in-dustry. This issue of Biomass Magazine examines the ridiculously complex, overwhelming, challenging and mind-numbingly bureaucratic battleground that we are all combatants upon, whether we like it or not.

Coleman’s assertion is supported throughout the issue. In Simet’s page-26 department, “Thermal Reinforcement,” her sources succinctly establish that the kind of federal mandate enjoyed by the biofuels sector is hardly even worth talking about, and likely makes more sense to tackle at the state level, owing to the different ways thermal energy needs are met across the country. In fact, Charlie Niebling, one of the preeminent thermal biomass advocates in the country, suggests a comprehensive, federal renewable energy standard is a “utopian notion.” Recognizing that, Niebling and others have set their sights on state-level policy victories and are making real progress in the Northeast.

I’ll warn you now that the stories in this issue of Biomass Magazine will likely cause frustration. Policy is vital to our industry’s growth, but it is not a guarantee, and just as soon as our industry enjoys a policy victory that starts to bear real fruit, the hard work of defending our position begins.

TIM PORTZVICE PRESIDENT OF CONTENT & EXECUTIVE [email protected]

¦EDITOR’S NOTE

EDITORIAL

PRESIDENT & EDITOR IN CHIEFTom Bryan [email protected]

VICE PRESIDENT OF CONTENT & EXECUTIVE EDITOR

Tim Portz [email protected]

MANAGING EDITOR Anna Simet [email protected]

SENIOR EDITOR Ron Kotrba [email protected]

NEWS EDITORErin Voegele [email protected]

ASSOCIATE EDITORKatie Fletcher [email protected]

COPY EDITOR Jan Tellmann [email protected]

ARTART DIRECTOR

Jaci Satterlund [email protected]

GRAPHIC DESIGNERRaquel Boushee [email protected]

PUBLISHING & SALESCHAIRMAN

Mike Bryan [email protected]

CEOJoe Bryan [email protected]

VICE PRESIDENT OF OPERATIONSMatthew Spoor [email protected]

SALES & MARKETING DIRECTORJohn Nelson [email protected]

BUSINESS DEVELOPMENT DIRECTOR Howard Brockhouse [email protected]

SENIOR ACCOUNT MANAGERChip Shereck [email protected]

ACCOUNT MANAGERJeff Hogan [email protected]

ACCOUNT MANAGERTami Pearson [email protected]

CIRCULATION MANAGER Jessica Beaudry [email protected]

TRAFFIC & MARKETING COORDINATORMarla DeFoe [email protected]

EDITORIAL BOARD MEMBERS

Chris Sharron, West Oregon Wood Products

Amanda Bilek, Great Plains Institute

Stacy Cook, Koda Energy

Ben Anderson, University of Iowa

Justin Price, Evergreen Engineering

Page 7: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 7

INDUSTRY EVENTS¦

National Advanced Biofuels Conference & ExpoOCTOBER 26-28, 2015Hilton OmahaOmaha, NebraskaProduced by BBI International, this national event will feature the world of advanced biofuels and biobased chemicals—technology scale-up, proj-ect finance, policy, national markets and more—with a core focus on the industrial, petroleum and agribusiness alliances defining the national advanced biofuels industry. With a vertically in-tegrated program and audience, the National Advanced Biofuels Conference & Expo is tailored for industry professionals engaged in producing, developing and deploying advanced biofuels, bio-based platform chemicals, polymers and other re-newable molecules that have the potential to meet or exceed the performance of petroleum-derived products.866-746-8385 | www.advancedbiofuelsconference.com

International Biomass Conference & ExpoAPRIL 11-14, 2016Charlotte, North CarolinaOrganized by BBI International and produced by Biomass Magazine, this event brings current and future producers of bioenergy and biobased prod-ucts together with waste generators, energy crop growers, municipal leaders, utility executives, technology providers, equipment manufacturers, project developers, investors and policy mak-ers. It’s a true one-stop shop—the world’s pre-mier educational and networking junction for all biomass industries.866-746-8385 | www.biomassconference.com

International Fuel Ethanol Workshop & ExpoJUNE 20-22, 2016Wisconsin CenterMilwaukee, WisconsinThe FEW provides the global ethanol industry with cutting-edge content and unparalleled networking opportunities in a dynamic business-to-business environment. The FEW is the largest, longest run-ning ethanol conference in the world—and the only event powered by Ethanol Producer Magazine.866-746-8385 | www.fuelethanolworkshop.com

Page 8: July 2015 Biomass Magazine

PEOPLE, PRODUCTS & PARTNERSHIPSBusiness Briefs

Algae.Tec announces collaboration

Algae.Tec Ltd. has announced the execution of a collaboration agreement for the commercialization of its algae produc-tion technology with Dominic Republic-based Larimar Energy SRL. The companies are collaborating on the development of algae production projects in the Dominican Republic and Caribbean region.

Latvia pellet plant plannedSia Broceni Pellets, a subsidiary of AS

Graanul Invest, has acquired 16 hectares of land in Latvia to construct a 150,000-ton-per-year pellet plant. The facility is expected to begin operations early next year. It will be the eighth pellet plant developed by Graanul Invest.

Solenis opens world headquartersSolenis LLC celebrated the grand

opening of its new world headquarters April 27. Located in Wilmington, Delaware,

the headquarters will currently accommo-date approximately 120 employees sup-porting a variety of corporate functions for the specialty chemicals company, which was previously known as Ashland Water Technologies. Space for additional expan-sion has been allocated. The opening of the world headquarters follows the opening of the company’s European headquarters in Schaffhausen, Switzerland, last year.

Cirque Energy appoints CEOCirque Energy Inc. has named Rodger

Silverthorn chairman, president and CEO. Silverthorn, who previously served as the company’s executive vice president for busi-ness businesses development and secretary, replaces former CEO, President and Chair-man Joseph DuRant, who died. Silverthorn will continue to serve as director of the

company, and the remainder of Cirque Energy’s leadership team will continue with their present responsibilities. Cirque Energy also recently appointed Patrick Rogers to its board of directors. He currently serves as CEO of the Laguna Group Inc.

Vecoplan adds team member

Michael Wilhoit has rejoined Veco-plan LLC as a project engineer. Wilhoit’s new position includes coordinating the design and development of turnkey shredding systems for the recycling sector. In order to ensure continuous quality control, he will also oversee the manufacture and implemen-tation of his projects once the engineering phase has been completed. Prior to rejoining Vecoplan, Wilhoit was managing partner at AREco Industrial Services.

FUEL | AIR | GAS | ASH processbarron.com/biomass

205-663-5330

BIOMASS to ENERGYProcessBarron is there every step of the way.

Biomass diagram july 15.indd 1 6/9/2015 10:20:30 AM

Silverthorn DuRant Rogers

Wilhoit

Page 9: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 9

Bioplastics organization foundedHolland Bioplastics has been founded in

the Netherlands to share relevant knowledge about bioplastics and connect relevant par-ties. Founding partners of the organization include Corbion, NatureWorks, Bio4Pack and Braskem. Participation is open to those involved directly or indirectly in the produc-tion, manufacture, research, or marketing of bioplastics.

Capstone supplies microturbine to Lithuanian biogas project

Capstone Turbine Corp. has received an order for a C800 microturbine to upgrade a facility operated by a pork producer in Lithuania. The C800 microturbine will be fueled by biogas produced on site. It will be installed in a combined-heat-and-power ap-plication along with an anaerobic digestion, fuel compressor and heat exchanger.

ADBA appoints board members The Anaerobic Digestion and Biore-

source Association has added three new board members. They are Julian O’Neill, chief executive of Biogen; William Heller,

chief executive of Tamar Energy; and David Greenfield, advisor to the Local Authority Waste Network Coordinators and manag-ing director of Social, Environmental and Economic Solutions Ltd.

Terex Materials acquires CBITerex Materials Processing, a business

segment of Terex Corp., and Continental Biomass Industries Inc. have announced the acquisition of the assets of CBI by Terex, marking an expansion of the Terex Environmental Equipment product line. TEE, part of Terex Materials Processing, has been serving the wood, biomass and recycling industries since 2011. The acquisi-tion of CBI’s business, in operation since 1988, significantly advances the product line while adding dimensions to the TEE business that would otherwise have taken years to develop. The acquisition also adds customization and specialty product capa-

bilities that enable TEE to serve even the most demanding requirements of custom-ers worldwide.

Alstom, NG Metalúrgica sign steam turbine agreement

Alstom and NG Metalúrgica have signed a cooperation agreement to jointly approach the Brazilian marketplace for high-performance small and midsized steam turbines. Under the agreement, NG Met-alúrgica will sell Alstom’s geared reaction steam turbines high-speed reaction type steam turbines in Brazil. Alstom will share all necessary technology with its partner while contributing certain engineering services and components to the turbines sold by the Brazilian company.

BUSINESS BRIEFS¦

SHARE YOUR INDUSTRY NEWS: To be included in the Business Briefs, send information (including photos and logos, if available) to Business Briefs, Biomass Magazine, 308 Second Ave. N., Suite 304, Grand Forks, ND 58203. You may also email information to [email protected]. Please include your name and telephone number in all correspondence.

Page 10: July 2015 Biomass Magazine

10 BIOMASS MAGAZINE | JULY 2015

Conifex Power, Mackenzie Generating Station

Location Mackenzie, British ColumbiaEngineer/builder Spectrum Energy, Clean Energy, JV DriverPrimary fuel Hog fuel, shavings, forest residuesBoiler type ABB ICFB BoilerNameplate capacity 36 MWCombined heat and power Yes

Government incentives

IPP or utility IPP contracting to BC HydroGroundbreaking date November 2013Start-up date 2015A 72-hour test run was completed and the plant is now in commercial operation.

Constellation Energy, Albany Green Energy

Location Albany, GeorgiaEngineer/builder DCO Energy LLCPrimary fuel Forest residue, urban waste wood, pecan shells, peanut hullsBoiler type Valmet circulating fluidized bed boilerNameplate capacity 50 MWCombined heat and power Yes

Government incentives $250 million in bonds via the Albany Dougherty Payroll Development Authority

IPP or utility IPP contracting to Proctor & Gamble Co. and Georgia PowerGroundbreaking date 2014Start-up date June 2017The project will supply P&G’s paper manufacturing facility with up to 425,000 pounds per hour of process steam

Merritt Green Energy Project

Location Merritt, British ColumbiaEngineer/builder DalkiaPrimary fuel Forest and sawmill waste, pine beetle killBoiler type Double drum FSE Energy boilerNameplate capacity 40 MWCombined heat and power NoGovernment incentives NoneIPP or utility IPPGroundbreaking date 2014Start-up date 2016The building has been built and progress onsite continues steadily.

Fort St. James Green Energy Project

Location Fort Saint James, British ColumbiaEngineer/builder DalkiaPrimary fuel Forest and sawmill waste, pine beetle killBoiler type Double drum FSE Energy boilerNameplate capacity 40 MWCombined heat and power NoGovernment incentives NoneIPP or utility IPPGroundbreaking date 2013Start-up date 2016 The turbine and gearbox have arrived and are set in place.

Biomass construction activity remains strong as Q2 2015 closes out. The Biomass Construction Update continues to follow progress of selected facilities from groundbreaking to completion, and is pleased to report the following advancements and developments.

New to the BCU is the University of Maine at Farmington’s Biomass Heat Plant, which recently broke ground with an aggressive goal of completion for use during the 2015-2016 heating season. The university was struggling with aging oil-fired equipment that had exceeded its useful life, and made initial plans to move to a natural gas. When plans for the city’s new natural gas pipeline were delayed, the university turned to biomass.

In Georgia, construction is moving forward on Constellation Energy’s 50-MW cogeneration power plant that will supply 42 MW of electricity to Georgia Power. The remaining electricity will be sent directly to Proctor & Gamble’s facility adjacent to the site, and the facility will also supply P&G with 100 percent of its process steam.

Conifex Power completed repairs to the Mackenzie Generating Station and the facility passed the required 72-hour test run. It is now delivering power to BC Hydro.

In Grand Junction, Colorado, a flare-toppling ceremony was held on Earth Day to commemorate completion of the Persigo Waste Water Treatment Plant’s compressed natural gas production and delivery pipeline systems. The project was made possible with the assistance of grant money and the production of RIN credits.

In Denmark, Dong Energy continues its extensive work to convert the Skærbæk Power Station to biomass. It is now putting its

newly reconstructed quay into service in order to receive many large equipment deliveries by ship.

Excitement is building at East Kansas Agri-Energy as it nears concrete work completion on its renewable diesel facility, signaling the beginning of steel erection. Progress can be viewed live at ekaellc.com, via three webcams.

Fair summer weather in the northern hemisphere brings with it a marked increase in construction activity, which BCU is following and will report in the October edition of Biomass Magazine. If you would like your project profiled, email [email protected].

Biomass CONSTRUCTION UPDATESpring Construction in Full Swing by Steve Stucko

ProjectComplete

Skærbæk Power StationPHOTO: DONG ENERGY

Biomass Power Pellets Biogas Thermal Advanced Biofuel

Page 11: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 11

CONSTRUCTION UPDATE¦

Rentech Inc. - Wawa

Location Wawa, OntarioDesign/builder EADExport Port Port of OntarioExport location United Kingdom (Drax)Pellet Grade Industrial premium pelletsCapacity 450,000 metric tonsFeedstock Crown forest woodGroundbreaking date 2014Startup date Q2 2015In mid-May, Rentech reported that commissioning was underway and all 12 pellet mills had been run.

Colombo Energy Inc. - Greenwood

Location Greenville, South CarolinaDesign/builderExport Port Port of WilmingtonExport location EuropePellet Grade Industrial premium pelletsCapacity 460,000 tonsFeedstock Forest woodGroundbreaking date March 2015Startup date 2016 The plant secured sales of 70 percent of its production through 10-year, fixed-price supply contracts.

Allendale White Pellet Plant

Location Allendale, South CarolinaDesign/builder Thunderbolt Biomass Inc.Export Port Port of Savannah and BrunswickExport locationPellet Grade Industrial premium pelletsCapacity 60,000 metric tonsFeedstock Yellow pineGroundbreaking date May 2014Startup date Q4 2015The project is currently focused on mechanical and electrical installation; commissioning is expected to begin this fall.

Chip Energy Inc.

Location Goodfield, IllinoisDesign/builder Chip EnergyExport Port N/AExport location N/APellet Grade Pellets, briquettes and logsCapacity 36,500 metric tonsFeedstock Waste wood, energy crops, agricultural residueGroundbreaking date 2013Startup date TBDAll silos are now in place, the walls are erected, and construction is focused on the roof.

German Pellets Louisiana

Location Urania, LouisianaDesign/builder Designed by Elektro Fischer USA LP Export Port Port ArthurExport location EuropePellet Grade UtilityCapacity 1.1 million tonsFeedstock SoftwoodGroundbreaking date 2014Startup date 2015Commissioning is complete and production is gradually being ramped up.

TANAC S.A. - Rio Grande

Location Rio Grande, BrazilDesign/builderExport port Rio GrandeExport location United KingdomPellet Grade Industrial premium pelletsAnnual Capacity 400,000 metric tonsFeedstock Acacia Mearnsii woodGroundbreaking date 2014Startup date February 2016In May, construction was focused on completion of the concrete storage silos.

Lanzatech Freedom Pines Biorefinery LLC

Location Soperton, GeorgiaDesign/builder LanzatechProcess technology Proprietary thermochemical pathwayBiofuel/biochemical product(s) Ethanol and possibly butadiene, jet fuelFeedstock Woody biomassProduction capacity 2 MMgyType of RINs D3CoproductsGroundbreaking date 2014Start-up date 2015

East Kansas Agri-Energy LLC - Renewable Diesel Facility

Location Garnett, KansasDesign/builder WB ServicesExport Port Capable of both enzymatic and chemical processingExport location Renewable dieselPellet Grade Distillers corn oilCapacity 3 MMgyFeedstock D4Groundbreaking date NaphthaStartup date 2014Concrete work is underway, and the project is on schedule for commissioning during the Q4 2015.

ProjectComplete

ProjectComplete

Page 12: July 2015 Biomass Magazine

12 BIOMASS MAGAZINE | JULY 2015

Biomass Power Pellets Biogas Thermal Advanced Biofuel

DuPont Cellulosic Ethanol LLC - Nevada

Location Nevada, IowaDesign/builder DuPontProcess technology DuPont proprietary process Biofuel/biochemical product(s) EthanolFeedstock Corn stoverProduction capacity 30 MMgyType of RINs D3CoproductsGroundbreaking date November 2012Start-up date 2015In April, CEO Ellean Kullman said, that "The plant is coming up this quarter."

Skærbæk Power Station, Dong Energy

Location Fredericia, DenmarkDesign/builder B&W VollundProcess technology Wood chipsBiofuel/biochemical product(s) B&W Vollund fluidized bedFeedstock 280 MWthProduction capacity District heat and electricityType of RINs N/AGroundbreaking date September 2014Startup Early 2017New flue gas pipes will be lowered into the existing 120-meter chimney in 16 meters sections.

University of Maine at Farmington, Biomass Heat Plant

Location Farmington, MaineEngineer/Builder Trane U.S. Inc.Primary fuel Wood chipsBoiler typeNameplate thermal capacity 35,400 MMBtuHeat end use District heatGovernment incentives/grants N/AGroundbreaking date May 2015Start-up date November 2015The system will serve 24 UMF buildings and is estimated to reduce fossil fuel use by 390,000 gallons a year.

DOE's Savannah River Site Biomass Heating Plant

Location Aiken, South CarolinaEngineer/builder Ameresco Inc.Primary fuel Forest residueBoiler type Fluidized bed

Nameplate thermal capacity

Heat end use District heatGovernment incentives/grants N/AGroundbreaking date May 2015Start-up dateGroundwork has begun on this follow-on project to the 20-MW SRS Biomass Cogeneration Facility, which was completed in 2012.

Page 13: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 13

CONSTRUCTION UPDATE¦

Noblehurst Green EnergyPHOTO: NOBLEHURST FARMS INC.

Noblehurst Green Energy, Noblehurst Farms Inc.

Location Linwood, New YorkEngineer/Builder EnviTec Biogas

Substrate(s) Dairy manure, fats, oils and greases, grocery waste, dairy effluent

Digester type Complete mix followed by a plug-flow systemGas cleaning technology Yes

Biogas production capacity 36.8 CFM

Biogas end use Electrical generation

Power capacity 0.44 MWGroundbreaking date 2013Start-up date Q1 2015Commisioning and the grid tie are complete. The generator officially went online April 12.

Roeslein Alternative Energy of Missouri LLC, Roeslein Alternative Energy LLC

Location Northern MissouriEngineer/Builder Roeslein Alternative Energy LLCSubstrate(s) Hog manureDigester type Lagoon style, floating impermeable coverCHP? Molecular sieve/PSA

Biogas production capacity 2 million-plus MMBtu/year

Biogas end use CNG and LNGPower capacity N/AGroundbreaking date May 2014Start-up date Phase one: June 201525 of 88 lagoons are now covered and flaring; 16 more will be covered this summer as design work on the nine gas production facilities continues.

Persigo Wastewater Treatment Plant, City of Grand Junction

Location Grand Junction, ColoradoEngineer/Builder BioCNG LLCSubstrate(s) Sewage

Digester type/technology Continuous flow

Gas cleaning technology BioCNG LLC

Biogas production capacity 83.3 CFM

Biogas end use CNG for use in city and county vehicle fleets

Power capacity N/AGroundbreaking date December 2014Start-up date April 2015It is estimated that the facilty will produce the equivalent of 196,000 gallons of gasoline a year from gas that previously was flared.

ProjectComplete

ProjectComplete

Page 14: July 2015 Biomass Magazine

14 BIOMASS MAGAZINE | JULY 2015

PowerNews

In May, Sen. Tom Udall, D-N.M., introduced legislation to establish a na-tional renewable electricity standard (RES). If passed by Congress and signed into law, the bill, S. 1264, would require utilities to generate 30 percent of their electricity from renewable energy sourc-es by 2030.

The measure would create the first national threshold for utilities to provide a certain percentage of their electric-ity from renewable resources, including wind, solar, biomass, landfill gas, ocean, tidal, geothermal, incremental hydro-power or hydrokinetic. The RES require-ment would phase in, starting at 7.5 per-cent in 2015 and gradually increase to 30 percent in 2030 and thereafter, through 2039.

“Investing in homegrown clean en-ergy jobs just makes sense, and that’s why I’m continuing my fight for a national RES,” Udall said. “More than half the states—including New Mexico—have widely successful RES policies, and it’s time to go all in. I’ve long pushed for a ‘do it all, do it right’ energy policy, and a RES will help us get there.”

In the U.K., Scotland’s Rural College has teamed up with sustainability software and data company Ecometrica to de-risk investments in the biomass energy industry by combining a powerful computer model with state-of-the-art mapping software. The re-sulting Biomass Market Assessment Service (B-MAS) was launched in May. It provides power companies and potential investors in bioenergy supply with infor-mation on the future take-up and supply of bioenergy crops under different pricing and policy scenarios.

“The behavioral aspects of farmers’ decision making are fundamentally important to how new markets like that for bioenergy crops develop,” said Peter Alexander, the SRUC research who developed B-MAS. “Often it is assumed that it will just happen if it is economically viable, but the reality is more complex. For the first time, we have brought the be-havioral aspects of farmers’ decisions into a detailed model of this market, for example, with farmers be-ing influenced by the action of their neighbors. This combined with a spatial resolution of 1 kilometer, al-lows a much more realistic assessment of the future uptake of bioenergy in the U.K. than has previously been possible, which we believe will [be] of significant value to the bioenergy sector.”

Udall bill seeks to establish national RES program B-MAS launches in UK

RES requirements2015 7.5%2016 8.0%2017 8.5%2018 9.5%2019 10.5%2020 12.0%2021 13.5%2022 15.0%2023 16.5%2024 18.0%2025 20.0%2026 22.0%2027 24.0%2028 26.0%2029 28.0%2030 and thereafter through 2039

30.0%

SOURCE: S. 1264

Page 15: July 2015 Biomass Magazine

JULY 2015 | BIOMASS MAGAZINE 15

Depending on market conditions, biomass power can sometimes be a tough proposition. Government support is crucial in many areas, and also warranted, when considering the environmental and economic benefits from biomass alongside the often high cost of fuel.

In California, the biomass industry is facing some severe challenges. In recent years, many facilities have shut down as Public Utility Regulatory Policies Act of 1978 contracts expired and natural gas became a cheaper and available option.

Several newspaper articles from around the state have documented the decline of biomass and the markets that would be affected if local facilities were to shut down. A good portion of the 565 MW of biomass power are in jeopardy, and with them, many farmers who rely on their local facilities to purchase residues from orchards and other agricultural waste.

A recent article in the Hanford Sentinel, “Decline of Valley biomass plants a threat to ag,” covered the biomass crisis. It reads in part:

“Growers are asking: If you can’t burn orchard trees that have been removed, and you’ve got no bio-mass plant to send them to, where does it all go? ‘They just pile up,’ said Dino Giacomazzi, Kings County Farm Bureau president. ‘Currently, biomass plants are about the only way we have to dispose of orchard removal.’”

The dilemma was further explored in another sto-ry in California’s Woodland Daily Democrat, “Biomass power plants running out of steam.” It reads in part:

“Tulare County farmer Chris Lange has about 80 acres of uprooted citrus and olive trees that he needs to have cleared and chipped. Lange said he is waiting on a chipping company, which has not yet received approval from biomass plants to bring the orchard waste in to be processed into electricity.

‘We have been waiting for the chipper to come and it is just not happening,’ Lange said. ‘I understand that the contracts for the chippers by the cogeneration plants are not being renewed. We (in the San Joaquin Valley) have more permanent crops being pushed out than ever, and this leaves everybody hanging.’”

The Woodland Daily Democrat went on to quote Steve Brink, California Forestry Association vice president of public resources, who said that electricity produced from natural gas costs 2 to 6 cents per kilo-

watt, whereas biomass power costs about 10 cents per kilowatt. “With no direction from state government to pay the known environmental benefit, what would you expect the utility to do?,” the Democrat quoted Brink. “The state has not provided any direction of where this (biomass) needs to go. There’s 1 million, bone-dry tons just in the Northern California forests on both public and private lands that is piled up and burned, now that there’s no place to take it.”

With orchard growers pulling out and replacing older trees with young trees in an effort to conserve wa-ter during the drought, and with fewer biomass plants operating, “the problem is now amplified,” Brink said.

Luckily, there is some good news. The California state legislature is considering a bill that would help shore up the industry by recognizing its environmental benefits. Led by the California Biomass Energy Alli-ance, the bill will direct $50 million to a Biomass State Cost Share Account within the Greenhouse Gas Reduc-tion Fund. The Assembly overwhelmingly voiced its support for the biomass industry by passing Assembly Bill 590,” said Julee Malinowski-Ball, executive direc-tor of the California Biomass Energy Alliance, in the association’s press release. “This bill will provide needed funding for biomass plants by allocating Greenhouse Gas Reduction Funds to the facilities for its environ-mental benefits.”

Malinowki-Ball continued, “For more than a quar-ter century, biomass plants have been providing reliable, renewable, utility-scale power in California. Despite our numerous benefits, biomass is often overlooked. This funding will ensure that biomass plants will be compen-sated for its environmental benefits.”

The bill unanimously passed assembly floor and will now head to the California Senate.

This is good news, and not just for the California biomass plants facing closure. As the U.S. EPA’s final Clean Power Plan is released later this summer, Cali-fornia’s support for biomass sets a precedent for other states designing their own carbon reduction plans.

Author: Bob CleavesPresident and CEO, Biomass Power Association

www.biomasspowerassociation.com [email protected]

California Biomass Support Sets Good Example

POWER¦

BY BOB CLEAVES

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Climate change has evoked carbon emission reduction strate-gies worldwide. In the U.S., seven of the top 10 warmest years on record have occurred since 1998, with carbon pol-lution deemed its biggest driver. Recognizing that, President

Obama’s Climate Action Plan directed the EPA to work closely with states, industry and other stakeholders to establish carbon pollution standards for both new and existing power plants, which currently ac-count for roughly one-third of all domestic greenhouse gas emissions (GHG). On June 2, 2014, the U.S. EPA proposed the Clean Power Plan to help reduce carbon emissions by 30 percent from 2005 emission lev-els by 2030. The federal initiative began making headway in 2010, and although biomass could serve as one of numerous methods to help achieve this aim—and its landing in the mandate looks favorable—nothing is certain until touchdown.

The current status of the mandate is best understood by step-ping through the preceding chain of events. In 2010, the EPA issued its GHG Tailoring Rule, which aimed to tailor default emissions levels contained in the Clean Air Act to make them applicable to GHG emis-sions. However, the rule did not distinguish biogenic emissions from fossil fuels, and did not exclude biogenic carbon dioxide (CO2) from applicability under prevention of significant deterioration (PSD) and Title V permitting thresholds. “That created great concern for the for-est products industry—land owners, biomass power, all of the people

in the larger value chain,” says Paul Noe, vice president of public policy with American Forest and Paper Association. “We went to the EPA and voiced those concerns and they agreed to step back and do a more detailed science review of this issue.”

The agency responded by issuing a three-year deferral of biogenic CO2 regulations in July 2011. A few months later, the EPA drafted the Accounting Framework for Biogenic CO2 Emissions from Stationary Sources, which was reviewed by the EPA’s Science Advisory Board, a panel of scientists and experts representing several areas of forestry and agriculture. The SAB panel was tasked with reviewing the EPA’s overall approach and accounting practices, as well as suggesting improvements to the original framework accounting model.

Last November, EPA issued a revised framework, informed by the SAB’s report and public comments, for a second round of targeted peer review with the SAB. This round of analysis is ongoing and could be for a while. Current review is focusing on charge questions pertain-ing to specific areas of the framework that were not addressed in the prior revised report, and where the EPA would like further guidance. Specifically, the EPA requests the panel examine and offer recommen-dations on future anticipated baseline specification issues in assessing the extent to which the production, processing and use of forest and agriculture-derived biogenic material at stationary sources for energy production results in a net atmospheric contribution of biogenic CO2

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Readying for a Regulatory LandingBiomass’s role in the federal Clean Power Plan is up in the air, but the industry hopes for a smooth touchdown. BY KATIE FLETCHER

emissions. This framework presents an equation called the biogenic assessment factor (BAF) equation, which includes terms representing different aspects of the biological carbon-cycle dynamics associated with bio-genic feedstock growth, harvest, processing and use at stationary sources.

The second draft of the framework was also ac-companied by a memorandum issued by Janet Mc-Cabe, acting assistant administrator for the Office of

Air and Radiation, to the EPA’s Regional Air Division directors describ-ing the agency’s current thinking regarding biogenic CO2 emissions in the context of the CPP and the PSD Program. It is these two docu-ments the biomass industry has looked to as a means of gauging what role biomass will play in upcoming policy.

Overall Optimism Bob Cleaves, CEO of the Biomass Power Association, believes the

revised framework and accompanying memo support a clear, science-based approach that provides regulatory certainty while deferring im-portant policy implementation to the states. “It’s hugely positive what the EPA did in November, because it essentially gave the industry a kind of carbon stamp of approval,” Cleaves says. “We’re starting to put a price on carbon, recognizing the environmental benefits of the industry and providing the industry with the same kind of benefits that solar, wind and other renewable technologies receive.”

Noe says the AF&PA also finds the documents favorable. “We’re pleased that while it has been a long path, EPA has recognized the car-bon neutrality of biomass derived from certain forest products manu-facturing residuals, and we think that it’s clear when you look at the McCabe memorandum and the revised framework.”

All in all, players in the biomass industry are taking the news from the EPA as a good sign. Even so, the industry seeks certainty in regu-latory text. The memorandum clarifies what biomass energy qualifies

as carbon neutral in some respects, but doesn’t definitively answer the question across the board. In the documents, EPA makes a prelimi-nary finding that the use of certain forest-derived industrial byproducts and waste-derived feedstocks for energy are carbon neutral, and shows specific analysis that use of spent pulping liquor for energy is carbon neutral. The agency intends to apply these findings in future Clean Air Act regulations. However, AF&PA hopes for certainty on the carbon neutrality of energy derived from certain forest products manufacturing residuals, and how EPA will determine whether trees that may be used for energy are sustainably derived.

One of BPA’s requests is for the EPA to broaden its definition of waste-derived materials by including nonforestry cellulosic materials—like urban wood, wood-derived construction and demolition debris and railroad ties—since these are organic materials that do not cause land use changes and do not deplete carbon stocks. The association also encourages the EPA to state that biomass power plants that use the feedstocks covered by the McCabe Memorandum be exempt from regulation under the CPP.

In the testimony BPA submitted to the SAB panel, it argues that the use of fuel is a function of price, rather than carbon accounting. In the words of the association, if the EPA were to conclude that all biomass is carbon neutral, the fear that biomass electricity would under-take major harvests and compete with the value of pulp and sawlogs is fantasy. “It’s virtually inconceivable that power prices would reach the point where it would make economic sense to harvest natural forests,” Cleaves says.

In order for the industry to use merchantable fiber, Cleaves es-timates power prices would have to reach somewhere between 15 to 20 cents a kilowatt hour (kWh). “The idea that by the EPA somehow giving us the green light to harvest natural forests is going to—with a wave of a magic regulatory wand—allow us to go out and use any type of biomass is just patently absurd on the economics.”

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Chance to CofireBesides fear of overharvesting, some

may question whether U.S. coal plants will rapidly convert to biomass with supportive policy. William Strauss, founder and president of FutureMetrics, recently published white papers making the case that the CPP is not a war on coal, and that a gradual transition to cofiring at coal plants can be made without the assumed negative impacts. Strauss states in his paper, “If the coal industry and the power stations that use coal follow a strategy that is proven successful in Europe and South Korea, coal plants will not close and coal pro-ducers may see their margins improve.”

Strauss says the generation company that cofires wood pellets with coal to achieve a 10 percent reduction in CO2 will increase its cost of production by less than one penny per kWh, significantly less than the current cost of wind or solar power for achieving the same reduction. He uses the example of a 325-MW power plant cofiring at 89 percent coal and 11 percent pellets for a 10 percent CO2 reduction. Strauss refers to this as a ra-tional and pragmatic off-ramp to a decarbon-ized future, or a gradual transition to a less carbon-intensive power generation sector. “It’s a low-cost, decarbonizaiton pathway, but it’s still about a penny per kWh more than just plain old coal, so unless the utility is going to get either approval from the ratepayer or get support from policy, they are just going to burn coal,” Strauss says. “They’ll take the cheapest generation path forward if there is no incentive for them to change from busi-ness as usual.”

Strauss affirms there will still be the need for other carbon mitigation solutions. “You couldn’t cofire in all plants, there are not enough sustainable feedstocks to pro-duce that quantity of pellets,” he says. “Right now the market is overseas. There are unde-rutilized wood baskets further inland that are either underutilized because they’ve lost their traditional customers in the pulp and paper business or they never had those customers to begin with.”

Strauss adds that coal producers can benefit from the Clean Power Plan if they en-gage with pellet manufacturers. “It is a strate-gy that unites the states with the power plants, the coal producers and the pellet producers.”

Slow and DeliberateBecause price defines biomass feed-

stock options, the BPA submitted comments advising the SAB and EPA to focus on the low-value feedstock currently in use when fi-nalizing the current framework. Greg Morris of the Green Power Institute testified at the latest SAB meeting, calling for clarity on how the fuels the existing industry uses—residues and byproducts—are going to be treated in respect to carbon accounting. A section of Morris’s prepared comments reads, “In the opinion of the GPI, the SAB has a real op-portunity to provide a valuable service to the biomass industry and the renewable energy industries in general by expeditiously memo-rializing its consensus that biomass fuels de-rived from residue and byproduct forms of biomass should be assigned a BAF value of zero.”

The latest SAB teleconference was held May 29, where four other registered public speakers joined Morris, followed by a discus-sion of general conclusions about the frame-work and ending with a debate on the specific charge questions. Three more teleconferences have been slated to discuss the charge ques-tions this summer. Still, there is no timeline set for when SAB’s conclusive advice on the charge questions must be offered to the EPA. Holly Stallworth, designated federal officer with the SAB, says, “We’re going slower and in a more deliberate fashion.”

She commented that the revised frame-work is more of an academic exercise and that it has been declared by the EPA as policy neutral. “They are saying that they do not plan to channel it into policy and not into the CPP at this time,” Stallworth says.

The framework released in Novem-ber maintains the policy agnostic approach from the first version and does not provide a detailed discussion of specific policy and implementation options. The language in the framework reads, “EPA has not yet deter-mined how the framework might be applied in any particular regulatory or policy contexts or taken the steps needed for such implemen-tation.”

The framework does explain particular elements of the framework equation where policy-relevant choices would need to be made for application to a specific policy or program, but ultimately it’s a technical docu-

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ment that does not set regulatory policy. SAB members are split on the issue. Some on the panel agree the accounting framework should be policy neutral, while others believe it can only be useful or contextual if it is specifi-cally designed to address the policy issues for which its use is intended to provide reliable input. Madhu Khanna, chair of the biogenic carbon emissions panel, noted during a March 25 meeting that the panel’s responses to the charge questions could be better answered if policy context that affects scale, targets and mix of feedstocks were provided, because an-swers would differ depending on the policy.

During the May meeting, Khanna stated that the framework doesn’t explicitly state a policy context. However, “You could im-plicitly get from this that the policy context is regulation of CO2 emissions from station-ary sources under the Clean Air Act,” she says. “We really need to focus on this narrow question of whether more details about the policy context, other than this implied one of the Clean Air Act, are needed in order to de-termine the BAF that is defined in this frame-work.”

Cleaves’ stance is that “by keeping the process completely separate from policy con-siderations, the panel may be keeping biomass power in a policy limbo at a time we can’t af-ford uncertainty,” he says. “We need a clear understanding of how biomass will count under the CPP.”

Besides policy context and implemen-tation, the more comprehensive discussion and analysis the SAB is conducting as it pre-pares its report for the EPA includes detailed technical appendices on the following topics: baseline approaches, spatial- and temporal-scale decisions and implications, inclusion of alternative fate analysis for certain feedstocks and methane, leakage and illustrative regional feedstock-specific calculations using existing data sources and models, and resulting re-gional biogenic assessment factor values.

During its last meeting, the SAB panel was only able to begin discussing the first charge question regarding temporal scale, es-sentially considering over what time horizon the impact of using biogenic sources should be measured. The meeting concluded with plans to begin discussion there at the next meeting in July.

It is clear, deliberation over the frame-work is a difficult and timely process. If the EPA does not make a definitive decision on biomass in its CPP and defers to the SAB’s judgement, which could be years down the road, Cleaves and others believe it could have an adverse impact on the biomass industry. If not included at all, which most deem unlikely, Cleaves believes the effects could be negative or even catastrophic. “The negative effects would be that states aren’t encouraged to in-clude biomass and that would not be helpful in terms of continuing to recognize biomass in state renewable portfolio standard programs. The catastrophic effect would be, if we aren’t included, then almost by definition we’re part of the problem, and we would be regulated like a coal plant, required to purchase offsets or install pollution control technology.”

If regulated like a coal plant, Cleaves says, biomass plants would have no way to pass on those costs to ratepayers, as they are independent power producers. “We would close down, material would get landfilled, for-est fires would proliferate, methane emissions would increase—the climate would be worse off.”

Noe says that it’s also important that whatever policy comes about in this context and others that it doesn’t cause market dis-tortions. “If you think about how the forest products industry uses manufacturing residu-als for energy, every bit of the tree that can be used for higher value products like pulp paper packaging and wood products are used for that purpose,” he says. “It’s just these residuals that don’t have a higher value use and would otherwise go to waste if not used for energy that wind up being used. We think the market is the best way to ensure that biomass is being used for its best and highest use.”

The biomass industry calls for certainty this summer with the release of EPA’s CPP. “We have a good story,” Cleaves says. “It’s backed by science and I think we are kind of creeping towards a resolution that is going to be favorable to the industry, as it should be. I think what we see this summer in the CPP is going to be really important.”

Author: Katie FletcherAssociate Editor, Biomass Magazine

701-738-4920 [email protected]

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PelletNews

In late April, Enviva Partners LP launched trading of its common units on the New York Stock Exchange under the ticker symbol EVA. The initial public offer-ing (IPO) of 10 million common units rep-resenting limited partner interests was priced at $20 per common unit. Enviva first filed a registration statement with the U.S. Securi-ties and Exchange Commission for a pro-posed IPO in October 2014.

An updated prospectus filed with the SEC on April 20 explains Enviva Partners currently owns and operates five pellet pro-duction plants in the U.S with a combined production capacity of approximately 1.74 million metric tons per year, along with a dry-bulk, deep-water marine terminal at the Port of Chesapeake. The pellet plants

owned by Enviva Partners include facilities in Amory, Mississippi; Wiggins, Mississippi; Ahoskie, North Carolina; Northampton, North Carolina; and Cottondale, Florida.

A separate pellet plant located in South-ampton, Virginia, owned by the joint venture Enviva Wilmington Holdings LLC, is not covered by the IPO. The joint venture has also commenced construction of a pellet plant in Sampson County, North Carolina, and a terminal at the Port of Wilmington, North Carolina. Two additional pellet plants are planned for the region, along with a pel-let plant and port proposed for development in Mississippi. The publically traded Enviva Partners will be granted right of first offer to acquire these facilities.

Wood Resources International LLC has reported exportation of wood pellets from North America to Europe and Asia reached an all-time high in 2014, increasing 22 percent when compared to 2013. Shipments from the U.S. were up 40 percent, while Canada export-ed 6 percent less.

According to Wood Resources Interna-tional, U.S. exports to Europe increased for the 12th consecutive quarter, reaching a new high of more than 1.1 million tons during the fourth quarter of last year. Volumes of pel-lets to Asia shipped by container from the U.S.

West Coast, however, dropped as manufac-turers concentrated on seasonal local demand.

During the fourth quarter, 73 percent of U.S. pellet exports were destined for the U.K., up from 55 percent in 2013 and 31 percent in 2012.

In British Columbia, fourth-quarter ex-ports fell by 15 percent when compared to the third quarter. Exports to Europe increased, while shipments to Asia were down.

Wood Resources International also stressed there is strong potential for pellet ex-ports to Japan and South Korea to increase.

Enviva begins trading on NYSE

US pellet exports reach new high

Amory, MSWiggins, MSAhoskie, NCNorthampton, NCCottondale, FL

FL

AL GA

SC

NC

MSLATX

OKAR

TN

KYMONE

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In 2011, we noticed a glaring omission in an annual U.S. government publication. The annual Winter Fuel Report failed to mention wood and pellets, one of the most com-mon heating fuels in America. Members of Congress were also appalled. The next year, the report began covering wood and pellet heat, not just fossil fuel heat.

Now we find the same parent agency, the U.S. DOE, omitting any mention of wood and pellet heating in a major, consumer-oriented publication and inserting the word solar where wood and pellets should be. The publication, Energy Saver: Tips on Saving Money & Energy at Home, is one of the DOE’s main consumer-oriented energy efficiency publications. The glossy, 41-page booklet is distributed free of charge and contains scores of excellent suggestions on how to save on your utility bills.

The section on renewable energy tells consumers they have many options for using renewable energy at home, in-cluding solar and small wind turbines. The booklet also dis-cusses geothermal and solar thermal. It states: “Solar panels are the most popular form of renewable energy today.”

There are not even half a million homes with solar pan-els and about 10 million homes with wood or pellet stoves. On an annual basis, wood and pellet stoves still outsell solar panels. By 2020, there still be less than one million homes with solar. Even if the high estimates are correct, the number of homes using solar is still less than half the number of those with installed stoves. So why does the DOE say solar panels are the most popular form of residential energy, and why does it not even mention wood or pellet stoves in the renewable energy section?

It’s understandable that wood stoves aren’t being en-dorsed as an energy pathway that should rapidly expand (particularly in western states where inversions often trap particulates). But pellet stoves and boilers provide an ex-cellent option for homeowners in most of the country to reduce fossil fuels and affordably heat their homes without producing excessive emissions.

About 10 states offer rebates or tax incentives to install pellet stoves or boilers. There are liberal leading states that are trying to expand residential renewable energy deploy-ment, such as Maryland, Massachusetts, New York, Oregon and Vermont. Then there are more conservative states, like Idaho, Maine, Montana and New Hampshire, which also see the benefits of helping households use a local renewable re-source to affordably heat their homes. Why is the DOE so out of touch with what is happening around the country?

As the Obama administration and much of the country is increasingly focused on reducing fossil fuel use, the main federal agency in charge does not even see fit to mention a powerful HVAC device that drastically reduces or eliminates fossil heating fuels in more than 10 million U.S. homes.

A $2,000 or $3,000 dollar pellet stove can easily pro-vide 40 to 100 percent of most homes’ space heating needs. A typical 5-kW array of solar panels can provide about the same amount of energy in a year as a pellet stove can provide in four to five months.

The DOE should initiate more programmatic work on wood heat. Short of that, it should at least acknowledge the existence of wood and pellets in booklets like this and help educate homeowners about how they can best use them. For instance, this booklet could urge homeowners to up-grade from an old, uncertified wood stove to a cleaner, more efficient pellet stove. It could also explain how modern, au-tomated pellet boilers, like the ones that are so popular now in Europe, can provide both space and water heating and are a great complement to solar panels.

Accuracy and honesty are above all important, and ignoring the efforts of more than 10 million homes does not advance our common efforts to reduce fossil fuel use. The DOE should be striving to reach diverse constituencies, not just the urban, affluent people who can afford more ex-pensive energy upgrades like solar panels or wind turbines. The booklet even suggests small wind turbines are good to charge a sailboat battery. A sailboat battery? What audience is DOE trying to reach?

The demographic who could install small wind turbines is relatively small, and those who would use them to charge a sailboat battery is miniscule, but the demographic that could benefit from pellet stoves is huge.

It would help if there were an Energy Star label for wood and pellet stoves, so that federal and state agencies could better guide the deployment of these technologies as they do for all other major HVAC appliances. However, the development of such a label may be years away. For now, simply acknowledging the existence of wood and pellet stoves as a popular renewable energy option and educating the public about how and where to best use them is a good start.

Author: John AckerlyPresident, Alliance For Green Heat

[email protected]

Omission of Wood Heat Goes Too Far

PELLET¦

BY JOHN ACKERLY

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Regulation of Europe-Bound US Wood PelletsBY MARK ASPINALL AND VIRGINIA E. WORTHY

Across Europe, sustainable energy policies have been driving massive demand for a new energy commodity. Europe has found this new commod-

ity in the manufacture and production of wood pellets. Wood pellets are created from those portions of trees that have been traditionally discarded as waste. In the manufacturing pro-cess, chips, bark, branches, and stems are com-pacted into small pellets, anywhere from one-fourth to one-third inch in diameter and one to one and a half inches in length. Generally, these pellets will then be burned as fuel for massive municipal boilers across Europe and the Unit-ed Kingdom thereby replacing coal and similar fossil fuels as a primary means of electricity.

Over 75 percent of wood pellet produc-tion capacity is located in the southeastern U.S. with Georgia, Florida, Alabama and Virginia producing the vast majority of American pel-lets. Approximately 98 percent of wood pellet exports ship from southeastern U.S. ports. In 2014, the U.S. exported 73 percent of its wood pellets to the U.K., according to U.S. EIA data, which indicates that, after the U.K., the three largest importers of American wood pellets in 2013 were Belgium (12 percent) and the Neth-erlands (7 percent).

Given that the U.S. is exporting a vast majority of wood pellets manufactured in the country, concerns arise as to whether the pro-duction and manufacturing process meets the statutory or regulatory requirements of those foreign markets.

Concerns for Exporting to EUWood pellets are a popular form of sus-

tainable energy within the European Union because they are regarded as having a smaller carbon footprint than traditional fossil fuels and coal. With the introduction of the EU’s Renewable Energy Directive in 2009, demand for wood pellets has increased exponentially. With RED, the EU created 20/20/20 targets for the year 2020 which has objectives to: re-duce greenhouse gas emissions by 20 percent compared to emission levels in the year 1990, increase renewable energy use to 20 percent, and improve energy efficiency by 20 percent.

Each EU country will have its own individual-ized target.

While many countries have their own cer-tification schemes, the EU has been developing a multinational certification standard for wood pellets known as ENplus. The ENplus system creates three categories of pellets: EN-B pel-lets for industrial buyers and ENplus-A1 and ENplus-A2 for residential buyers. A break-down of important requirements for each type of pellet can be seen in Table 1.

The certification process involves close inspection of all elements of the wood pellets’ production chain. According to the European Pellet Council Handbook for the Certification of Wood Pellets for Heating Purposes, for the certification of wood pellets, EN-B pellets can only come from forest, plantation, and other virgin wood and cannot be chemically treated. The relevant inspectors will also analyze the production plant and that plant’s internal qual-ity testing methods. In addition to production inspections, there is a certification scheme for pellet traders that confirms that all entities be-

tween the supplier and the consumer blends and stores wood pellets in accordance with dis-closed standards. The handbook demonstrates how carefully each step of the production pro-cess is scrutinized before wood pellets obtain ENplus certification.

In addition to developing ENplus in or-der to regulate the quality of wood pellets, the EU and major European utility companies are developing certification schemes to ensure the sustainability of wood pellets. In 2013, the EU promulgated the EU Timber Regulation to prohibit illegal timber from entering the EU markets. That same year, many of the major European utility companies formed the Sus-tainable Biomass Partnership to harmonize na-tional sustainability standards and develop one universal standard. In furtherance of that goal, SBP has released six standards, each governing a different element of the supply chain.

Standard 1 harmonizes various EU for-estry and timber production regulations for producers of wood pellets, those that oversee the production of woody feedstock into wood

CONTRIBUTION: The claims and statements made in this article belong exclusively to the author(s) and do not necessarily reflect the views of Biomass Magazine or its advertisers. All questions pertaining to this article should be directed to the author(s).

Behavior

SOURCE: EUROPEAN PELLET COUNCIL

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PELLET¦

pellets. Standard 2 similarly provides producers with additional requirements for ensuring the sustainability of feedstock. Standard 3 offers guidance to certification bodies, third parties that investigate wood pellets and verify their sustainability, and provides a consistent cer-tification procedure. Standard 4 explains that chain-of-custody requirements so that entities throughout the supply chain, including traders and processors, can ensure the sustainability of wood pellets as they move down the supply chain. Standard 5 details the requirements for collecting the data that accompanies the sus-tainable wood pellets as they move through the supply chain. Standard 6 provides the genera-tor with the requirements for calculating energy and carbon balances.

UK Exporting ConcernsThe largest concern for American wood

pellet producers exporting to the U.K. is the U.K.’s certification requirements. Regulations require business receiving government in-centives under the Renewables Obligation, Contract for Difference, or Renewable Heat Incentive scheme (which includes consumers of American exports), to obtain at least 70 per-cent of their wood pellets from suppliers that comply with the UK. definition of “legal and sustainable.”

Suppliers can demonstrate legal and sus-tainable status with two types of evidence: category A certification or category B bespoke certification. Whereas category A evidence demonstrates that wood pellets have been cer-tified as complying with relevant at every point of the production chain by an approved third party, the category B checklist shows what claims or materials suppliers must produce to demonstrate that there is a low risk that their wood pellets do not comply with the relevant laws.

With category B bespoke evidence, the supplier verifies the sustainability of its wood pellets by following The Risk-Based Regional Assessment: A Checklist Approach.The check-list presents many of the U.K.’s major timber laws and provides examples of evidence that can satisfy those specific requirements. The checklist is organized into three parts, each of which examines a different aspect of the pro-duction process. For example, the checklist an-alyzes the systems and practices put in place by forest management to minimize harmful con-sequences to the source forest. The checklist also inquires as to the labor practices employed at each level of production.

Companies seeking to enter the U.K. mar-ket for wood pellets will need to be well-versed in both the Woodfuel Advice Note and the Risk Based Regional Assessment: A Checklist Approach, both published by the U.K. DECC and available online.

Opportunity AheadEurope’s demand for wood pellets keeps

increasing. According to U.K. DECC data, in 2013, the EU imported nearly 3.2 million met-ric tons of wood pellets, and in 2014, the U.S. exported 4.4 million metric tons to Europe ac-counting for nearly $500 million. These figures demonstrate that suppliers can expect contin-ued and exponential growth in demand for

American wood pellets in the years to come. To capitalize on this demand, American wood pellet suppliers need to ensure compliance with the import country’s wood pellet certification guidelines, which may include consulting those parties with experience in analyzing and adher-ing to such guidelines.

Authors: Mark AspinallPartner, Sutherland Asbill & Brennan LLP

[email protected]+44 (0)20 7553 8000

Virgina E. WorthyAssociate, Sutherland Asbill & Brennan LLP

[email protected](404) 853-8011

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ThermalNews

U.K.-based Rural Energy has launched the AIRMatic biomass space heater, a new compact solution that is ideal for warehous-es and large industrial units. According to Rural Energy, the standalone, modular bio-mass unit has been developed specifically to heat large-volume spaces.

It is powered by a boiler from Austrian manufacturer Herz and has minimal instal-lation requirements. The AIRMatic can be mounted in nearly any location with a single-phase 230 V electrical supply, space for flue penetration, a water supply and a level floor. In addition, the system is fully compliant with the Renewable Heat Incentive.

“The AIRMatic addresses a real gap in the current biomass market and provides warehouse owners and managers with an easy, off-the-shelf solution that will pay divi-dends,” said Paul Clark, managing director of Rural Energy. “We are well aware that in

warehousing space is at a premium, but with the AIRMatic only a couple of spare square meters are needed to make the switch to bio-mass.”

Ameresco Inc., recently celebrated the groundbreaking of a biomass heating plant that will increase critical steam security and provide additional power at the U.S. De-partment of Energy’s Savannah River Site near Aiken, South Carolina. According to Ameresco, the plant represents a subse-quent modification to the DOE’s original Energy Savings Performance Contract executed in 2009 for construction of the 20-MW biomass cogeneration facility cur-rently operated and maintained by Ameres-co at SRS.

The new plant will be located in the southeast corner of the existing 35-acre

Ameresco site. The heating plant will in-clude a new biomass-fueled boiler and re-location of the existing package boiler to a new enclosed building. Ameresco also will install a new truck tipper and fuel handing system to facilitate the biomass deliveries. The steam produced from the new plant will be supplied throughout SRS’s exist-ing distribution system. Providing steam from this new plant will allow for the exist-ing biomass cogeneration facility to direct more steam to the turbine generator result-ing in approximately 3 to 4 MW of addi-tional power for SRS.

Rural Energy launches AIRMatic

DOE heating plant in development in South Carolina

HEATING UP INNOVATION: Rural Energy’s AIRMatic biomass space heater is a compact solution designed to heat large industrial spaces. PHOTO: RURAL ENERGY

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JULY 2015 | BIOMASS MAGAZINE 25

THERMAL¦

Summer is a difficult time to discuss thermal policy. Homeowners are thinking about summer vacations and spreading mulch, while businesses are executing midyear performance reviews. The inevitable return of the heating season is low on most people’s priority list, but naturally, it’s at the top of the Biomass Thermal Energy Council's agenda, and we’re making it a priority for Congress, too. There are three legislative options before the Senate and House of Representatives that could break open the market for bio-mass thermal technologies and fuels. All three vehicles would use the Business Investment Tax Credit to incentivize ther-mal projects, but achieve market growth using substantially different strategies and constituencies.

The first bill would have the strongest direct economic effect on the biomass heating industry. The Biomass Ther-mal Utilization Act or BTU Act packages a 30 percent resi-dential renewable energy tax credit with a 30 percent business ITC for commercial and industrial high-efficiency biomass thermal technologies. It would avoid 1.3 million tons of car-bon dioxide production, create approximately 35,000 jobs, and increase renewable energy by nearly a gigawatt hour by 2017. More importantly, the BTU act is revenue-positive for the U.S. Treasury (creating more economic activity from the credit than it costs), and its cost pales in comparison to that of other energy ITCs and residential credits.

Interest in combined-heat-and-power (CHP) industrial energy efficiency currently commands a larger, though com-plex, base of political and industry support. CHP currently enjoys a 10 percent ITC for commercial and industrial ap-plications through 2016. ICF International has estimated that 698 biomass-fueled CHP sites comprise 3,837 MW of elec-trical generation capacity (4.6 percent of total U.S. capacity), with another 630 MW under development. The POWER Act, S.1516 and H.R.2657, would boost the existing CHP ITC from 10 to 30 percent of installed costs and extend the credit through 2018. On its face, this bill would appear to support broader deployment of biomass thermal systems that also generate electricity. However, the new CHP bill maintains a subrequirement that qualifying systems must also have a minimum electrical efficiency of 20 percent. Athough biomass thermal-led CHP systems can surpass the 60 per-cent minimum overall efficiency requirement for this ITC, even the best-designed thermal-led systems find it difficult to meet the 20 percent electrical efficiency target when us-ing backpressure steam turbines and organic Rankine cycles (among other technologies). BTEC's position, which may appear counterintuitive, is that reducing the minor electrical efficiency criterion to 5 or 10 percent would yield a greater number of more efficient projects.

Waste heat to power (WHP) is the newest entry in the congressional energy tax policy, and it benefits from broad general support among industrial efficiency champions. S.913 would provide a 30 percent ITC for WHP equipment. WHP technologies capture exhaust heat, gas pressure drops, rejected system heat, and mechanical heat, and converts them to electricity. ICF International estimates U.S. potential for WHP installations to be 14.6 GW, with approximately 7 percent from the forest products and pulp and paper in-dustries. Wasted heat appears to be a significant opportunity to avoid greenhouse gas emissions and encourage more ef-ficient commercial and industrial operations, however, we often encounter misunderstandings about the differences between WHP, CHP and biomass thermal systems amongst think tank experts, congressional staffers and others. Ac-cording to the U.S. DOE, a WHP system is also considered a CHP system when energy is recovered from an industrial process (a CHP bottoming cycle). In fact, we have seen this in operation at Integrated Biomass Resources in Wallowa, Oregon, where excess biomass heat from a lumber kiln gen-erates power through twin ElectraTherm Organic Rankine Cycles. From our perspective, the WHP bill improves upon the CHP ITC by removing the arbitrary minimum electrical efficiency level, while recognizing the importance of thermal energy from a broad range of fuels. Certainly, S.913 is no panacea for biomass thermal systems, but it may prove ben-eficial to thermal-led CHP systems.

With these three irons in the fire during the waning legislative days of 2015, what are biomass advocates to do? First, we must continue supporting the most beneficial bill to our industry, the BTU Act. We still feel the adverse ef-fects of our industry's past lack of coordination when ther-mal technologies like geothermal and solar entered the tax code in 2008 and biomass did not. We should also be aware of our technology and fuels' eligibility in other energy tax proposals, like the new CHP and WHP tax credits, and of-fer our support—or at least lack of opposition—when key votes come. Thermal energy is at last receiving recognition in tax policy, and we ought to link arms with other industries to propel these legislative efforts across the finish line. We can't do much about summer temperatures, but together we can change the conversation this congressional season.

Authors: Joseph SeymourExecutive Director, Biomass Thermal Energy Council

Ben Bell-Walker, Technical Affairs Manager, [email protected]

Thermal Incentives Heat UpBY JOE SEYMOUR AND BEN BELL-WALKER

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¦THERMAL

Thermal ReinforcementWhile some states are juggling attempts to freeze, lower or dismantle state renewable portfolio standards, others are strengthening and fine-tuning them.BY ANNA SIMET

In May, the number of states in the U.S. with mandatory renewable portfolio standards (RPSs) jumped to 30, plus Washington, D.C., finally surpassing the stagnant 29 that had gone unchanged for years. It didn’t last long, however, as the signing of a new bill in Kansas in late May

switched its program from law to voluntary. Perhaps more this year than any other, state legislation has proposed

to kill, weaken or freeze state RPS programs. Though most bills haven’t and likely won’t make much progress, arguments from RPS supporters and adversaries are in stark contrast, often leaving the general public confused about the mission and effect of their state’s RPS––in particular, the costs passed on to ratepayers.

The truth is that the real impact of an RPS is difficult to determine, according to Warren Leon, executive director of the Clean Energy States Alliance. “It’s not so easy to identify the costs and benefits of an RPS be-cause of its indirect effect on the electricity system and electricity prices,” he says. “It’s hard to track all of the economic impacts, and unless you do a thorough study, you don’t know for sure.”

The best studies that have been done suggest that, in most places, the cost of RPSs have been quite modest, Leon says. “There are some places where the RPS has led to lower electricity costs; most have led to slightly higher. But the question is whether some of the other benefits that have come with that—such as local jobs, building and maintaining renewable en-ergy facilities—counter the balance of slightly higher electricity costs, which have actually been quite small.”

While some states are juggling legislation that would negatively impact their RPSs, others have realized positive implications and are going in the

opposite direction by increasing goals and broadening qualifying technolo-gies.

Renewable thermal, in particular. “Beyond trends of strengthening or weakening [RPSs], adding thermal does seem to be real. It’s happened in New Hampshire and Massachusetts, and other states such as Maryland are considering it,” Leon says.

Leon references a paper released by CESA in late April, which reports that a handful of states have granted credit to various renewable thermal technologies under their RPS programs. Seven provide at least partial credit to all kinds or specific renewable heat technologies, but only New Hamp-shire and Massachusetts offer full credit, and New Hampshire is the only state that requires a portion of its RPS to be derived from thermal energy.

New Hampshire Model“New Hampshire was the first to do it, and do it properly,” says Adam

Sherman, executive director of the Biomass Energy Resource Center. Mas-sachusetts followed by passing a thermal inclusion bill in the 2014 legislative session, he adds, and Vermont—where BERC is located—just retooled an energy bill titled RESET that creates a three-tied RPS with a thermal com-ponent, and includes biomass heat technologies.

“It [adding thermal] is interesting because, on one hand, it’s a great way to take an unregulated portion of the energy market and create incentives and market mechanisms that catalyze market adoption of these technolo-gies,” Sherman says. “But, on the other hand, it’s oftentimes taking electric generation revenue or policy mechanisms, or applying regulations in the electric sector, to try to incentivize the thermal sector.”

While 29 states and Washington, D.C., have mandatory renewable portfolio standards, only two provide full credit to renewable thermal. However, more states are evaluating adding heat to their qualifying technologies and at least providing partial credit.

Mandatory RPS

Voluntary RPS

Mandatory RPS with full thermal credit

DEPARTMENT

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JULY 2015 | BIOMASS MAGAZINE 27

THERMAL¦Sherman notes that many people support inclusion of thermal in the

RPS, but there are some who see it as a “robbing Peter to pay Paul ap-proach. In theory, the way to do prothermal policy would be to apply it somehow to heating fuels, but there is not a lot of political support for taxing fossil fuels— especially heating fuels—because they see it as a regres-sive tax, and no one wants to make it even harder for Mrs. Smith, who is struggling to stay warm in the winter, by driving up the cost of heating fuels to fund weatherization, thermal efficiency and renewables.”

Sherman points out that in some cases, the generation of a thermal renewable energy credit (REC) can be done at a lower cost per credit than an electrical-derived one. “Thermal energy is 300 percent more efficient than burning wood to produce a megawatt-hour of electric energy,” he says. “Because of that efficiency factor, it could generate a REC to be pur-chased by a utility for a lower price per MWh. That’s really what got the New Hampshire utilities behind the initiative [to add thermal to the RPS], because it gave them flexibility and more options to cost-effectively acquire those RECs needed to meet RPS requirements.”

Adding thermal smartly is no simple task. After New Hampshire passed its bill in 2012, it took over two years to write the rules and imple-ment it, according to Charlie Niebling of Innovative Natural Resource So-lutions, who played a significant role in getting heat included. “They began allowing projects to qualify at the beginning of 2014. There were a few who took advantage of it—it applies to any projects that meet the technical requirements and came online after Jan. 1 2013. We’re really just only now starting to see projects coming forward and being developed with the full intent of utilizing and taking advantage of the incentives.”

Niebling admits that enthusiasm has been tempered somewhat by the dramatic decline in oil and propane pricing. “The business of advanced modern wood heating is really a function of what alternative fossil fuel heating oil prices are doing, and they’ve come down dramatically. The pace of project development has slowed, but it would be much worse without the existence of the thermal incentive.”

That’s soon to change in New Hampshire, he points out, as the U.S. Endowment for Forestry and Communities has committed a chunk of money to the state, which it will use to help finance biomass thermal projects specifically. Dubbed “T-RECs,” Niebling explains that since RPS programs provide a performance incentive, one doesn’t generate a revenue stream until he is operating. “You can’t take the fact that you might get RECs in the future to a bank. It’s all a function of the market, and there is a lot of risk associated with RPS markets and policy.”

Under T-RECs, once a REC purchase price is negotiated, the project is awarded a one-time, upfront lump sum payment—15 to 20 percent of its capital cost. Once the RECs are generated, ownership is transferred to the endowment. “The beauty of this is it takes a performance incentive and turns into a source of capital that can be used by a project to get built,” Nie-bling says, adding that the hope is the program could be launched in other states when thermal provisions are added.

Following New Hampshire’s lead, Massachusetts passed SB 1970 in summer of 2014, and its Department of Energy and Natural Resources immediately went to work drafting the rules.

Massachusetts and More“It [implementing the program] will likely be much quicker than in

New Hampshire,” Niebling says. The estimated value of the incentive, which was added to the states Alternative Compliance Standard, is a re-markable $800 million over the next 15 to 20 years. “It’s a huge play, and it’s getting a lot of attention. The rules are expected to be completed this summer, so we may see a draft out very soon.”

The program in Massachusetts has a few more strings attached than in New Hampshire, Niebling points out, including a sustainable biomass component to it that has to be met by any project that takes advantage of the credits.

And similar to what the endowment has done in New Hampshire, the state will assist smaller projects in getting built. “They will estimate what the heat output for a project will be over 10 years,” says Niebling. “Then, in lieu of selling credits as your system is operating, they will pay you a that sum upfront to use help finance the installation.”

The provision is applicable only for smaller projects under 100 kilo-watts, or 340,000 Btu. “So basically, home homeowners and small com-mercial projects will be able to take advantage of this very novel approach,” Niebling says. “It’s unique in terms of the way RPS programs are imple-mented around the country, and it’s worthy of some note. The administra-tive costs of enrolling, complying in these programs—and the paperwork and recordkeeping, it’s too heavy a lift for a little guy. For a bigger guy with in-house expertise, like a big school system installation or hospital, they have the capacity, and revenue generation is sufficient to justify the cost to participate—and there are costs.”

The major cost is a meter, which runs anywhere from $4,000 to $7,000 for a typical hot water installation, and more for steam.

Besides New Hampshire, Vermont and Massachusetts, several other states, including Maine, New York, and Maryland, have dabbled in adding renewable thermal technologies to their state energy plans. Regardless of the route a state chooses, Leon notes that an important point is that every RPS is different, and there is no one-size-fits-all. “RECs vary widely from one state to another, as do the ways utilities meet the mandate, the array of technologies, and the [program] priorities, so you just have to adapt this concept to each state individually,” he says. “You can’t just put out a model legislation and expect every state to run with it, it doesn’t work that way.”

And while it may be difficult to determine the overall impact of an RPS, spending a little more each year on renewable energy could prove to be a wise investment. “Ratepayers have faced an increasingly volatile econ-omy,” Sherman says. “Paying a little bit more now is probably a wise hedge against 20 years down the line.”

While the number of states with an RPS is very likely to sit at or very near 29 for the long term, legislation for a federal RPS has recently been introduced, but it certainly isn’t the first time. The idea of a nationwide mandate may sound good, but could be extremely difficult to implement. “I think it’s unrealistic,” Niebling says. “Setting aside the politics of who runs Congress, the energy markets and electric energy policy in this country vary so widely from one part of the country to another, a comprehensive RES seems like a utopian notion.”

Leon agrees. “Theoretically, it would be desirable to have both a fed-eral RPS and state RPS—the federal [standard] could create some national standards and keep the whole country moving toward renewables,” he says. “But the virtue of the state RPSs, is that different states have different needs and interests. Some technologies make sense in one state but don’t make sense in another, and one of the virtues of a state RPS is that the state can tailor it to its needs. We see a lot of variety among states, and that’s been a good thing, because it allows them to implement policies that serve their own purposes. You wouldn’t want to replace state policies with a national one, they would have to work hand in hand.”

It all boils down to the state and how the RPS is created, Niebling adds. “I long for the day that our government stops incentivizing or subsidizing any kind of energy, and everything can compete on a level playing field, but the fact is we compete in a marketplace that is heavily influenced and dominated by fossil fuel subsidy. It takes multiple shapes and forms, and that’s a reality that is not going away any time soon. The oil, gas, coal lobby is extremely powerful. We’re right to ask for some equivalent measure of treatment in what we do.”

Authors: Anna SimetManaging Editor, Biomass Magazine

[email protected]

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BiogasNews

The International Renewable Energy Agency has released a report announcing 7.7 million people were employed by the re-newable energy industry worldwide in 2014, including, 822,000 in biomass, 381,000 in biogas, and 1.788 million in liquid biofuels. In 2013, IRENA reports 782,000 were em-ployed in biomass, 364,000 in biogas, and 1.45 million in liquid biofuels. When compared to the 6.5 million renewable energy jobs re-ported in 2013, the 2014 total increased by 18 percent.

In the European Union, solid biomass added 37,900 jobs last year. According to IRENA, the European biomass sector now has 342,100 jobs, topping wind, solar pho-tovoltaic, and geothermal heat and power. Europe also has 97,200 jobs in the biofuels sector.

“Renewable energy continues to assert itself as a major global employer, generating

strong economic and social benefits world-wide,” said IRENA Director-General Adnan Z. Amin. “This increase is being driven, in part, by declining renewable energy technol-ogy costs, which creates more jobs in installa-tion, operations and maintenance. We expect this upward trend to continue as the busi-ness case for renewable energy continues to strengthen.”

Envia Energy, a joint venture (JV) between Waste Management Inc., Ven-tech Engineers International LLC, NRG Energy Inc. and Velocys plc, has broken ground on its gas-to-liquids (GTL) plant, located adjacent WM’s East Oak Landfill near Oklahoma City, Oklahoma.

The project will be the first of a se-ries of GTL plants the Envia JV plans to develop to produce renewable diesel fuel, synthetic waxes and naphtha from a com-bination of landfill gas (LFG) and natural gas.

The JV first announced its formation in March 2014. In August, Velocys an-

nounced that the final investment decision (FID) was made to proceed with construc-tion of the commercial plant. Now, Envia Energy has completed all of the permit-ting to enable construction to move ahead, entered into the main contracts for the project, procurement of all major equip-ment has been completed and fabrication of the Fischer-Tropsch reactors and plant modules are underway. The facility is on track for commercial operation by the first half of next year.

IRENA: renewable energy jobs continueupward trend

Envia breaks ground on GTL plant in Oklahoma

Global renewable energy jobs in 2014 (in thousands)Solar PV 2,495Liquid biofuels 1,788Wind power 1,027Biomass 822Solar heating/cooling 764Biogas 381Small hydropower 209Geothermal 154Concentrated solar power 22SOURCE: INTERNATIONAL RENEWABLE ENERGY AGENCY

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The Golden State has borderline personality disorder regarding promotion and discouragement of dairy biogas projects. BY RON KOTRBA

California is by far the No. 1 dairy state in the U.S. with roughly 1.8 million head, concentrated mostly in the Central Valley. Ac-cording to the California Milk Advisory Board, about one in every five U.S. dairy cows resides in California on some 1,500 to

1,600 farms. On average, each dairy cow produces about 27 to 29 tons of manure a year, meaning annual manure generation from California’s dairy industry reaches an astounding 52.2 million tons annually. And with this much cow manure comes voluminous methane emissions, a potent greenhouse gas (GHG). Michael Boccadoro, executive director of the organization Dairy Cares, says 48 percent of California’s methane emis-sions come directly from the dairy industry.

Not only does California lead the nation in dairy production, but it is also a trailblazer in GHG reduction legislation with programs such as

cap-and-trade and the low carbon fuel standard (LCFS), both fostered under the California Global Warming Solutions Act of 2006 (AB 32). The state also has one of the most ambitious renewable portfolio stan-dards (RPS) in the country. With all of these legislative tools in place, and with more than 100 billion pounds of manure a year responsible for half of the state’s methane GHGs, why are there fewer than two dozen dairy digesters established in California?

“That’s the great question,” says Neil Black, president of California Bioenergy LLC (CalBio). “Because of those issues, we established Cal-Bio. We have the largest dairy industry, the most sophisticated renew-able energy environment and leaders on addressing climate change. I’d say that the focus on the renewable energy side has historically been on

Udder Confusion: Dairy Digester Development in California

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BIOGAS¦solar and wind in California.” Black says California is playing a major role in developing world-leading climate change initiatives, “but those programs are just now getting put into place, and that is leading regu-lators to look at how to develop specific programs to develop dairy digesters.”

Black says there are ongoing discussions with California Air Re-sources Board to create a program to take dairy digestion to the much-needed next level. Boccadoro says the dairy industry is pushing ARB to tap into funds from the GHG Reduction Fund—proceeds from the cap-and-trade program—to develop 100 to 200 new dairy digester projects by 2022. “The GHG Reduction Fund sits at about $2.3 billion so far this year alone,” Boccadoro says. “We’ve asked for $100 million a year for five years. That’s the impetus needed to get this industry off the ground. ARB recognizes something needs to be done, and we argue dairy digestion has the most bang for the buck in GHG reduction.”

Boccadoro says development of a robust dairy digester industry in California has little to do with permitting obstacles and boils down to availability of incentive funding and long-term contracts with utilities. He says when federal 1603 Recovery Act funding was available in 2013, procurement contracts were signed and five new projects got built, but in 2014 funding ceased and no contracts got signed and therefore no projects were built. He says there is still $10 million available in this year’s state budget for dairy digesters allocated to the state food and agricul-ture department, and the next budget cycle looks even more promising. “The governor wants $25 million and the legislature has requested $30 to $50 million,” he says.

In June 2013, Boccadoro and several other experts drafted a report for USDA titled “Economic Feasibility of Dairy Digester Clusters in California: A Case Study,” in which the authors lay out the regulatory and permitting environment in California. The report lists several legis-lative tools on the books that can be leveraged, or that were specifically designed, to promote dairy digesters, including the cap-and-trade pro-gram, the RPS, the LCFS, AB 1900, AB 2196 and SB 1122.

The report notes AB 1900 was passed in 2012 to clarify and fa-cilitate requirements for injection of biomethane into California’s vast natural gas pipeline system. State law previously prohibited landfill gas from being injected into the pipelines and utilities imposed strict qual-ity and testing requirements on other sources of biogas, such as dairy biogas, making pipeline injection difficult. AB 1900 requires the Cali-fornia Public Utilities Commission, in consultation with the Office of Environmental Health Hazard Assessment and ARB, to develop stan-dards for constituents in biogas to protect human health and pipeline integrity and safety. AB 1900 was expected to facilitate and streamline biomethane injection and promote in-state production and distribution of renewable natural gas. In May, the CPUC issued a proposed deci-sion on regulatory implementation of AB 1900 that imposed the cost of testing on biomethane producers and announced development of an incentive program to offset interconnection costs. Patrick Serfass, executive director of the American Biogas Council, says the proposed rule is “a nice gesture and very well intentioned, but there are some problems in execution.”

“Bearing the cost of testing the gas species listed in the ‘con-stituents of concern,’ especially to the extremely low levels required, is generally not viewed as fair, especially since nonrenewable natural gas suppliers do not have to pay to test for potentially hazardous trace components present in nonrenewable natural gas, which are not pres-ent in renewable natural gas (RNG),” says Sean Wezei, principal with

Dekany Consulting Inc. and co-chair of ABC’s RNG working group. “The ABC also appreciates the CPUC’s proposal to offset some of these [interconnection] costs, but the limit of $1.5 million per connec-tion, and the uncertainty of this offset being available when the pipeline connection is constructed, has our membership generally expecting this offset program to be insufficient to change the fact that zero RNG-to-pipeline projects have been installed since AB 1900 was implemented in California.”

Matt Schmitt, business development director for Colony Energy Partners Tulare LLC, says pipeline injection is a better route for his biogas project than electrical generation. Phase one of Colony Energy Partner’s multifeedstock hybrid project entails procuring 500 MMBtu per day of gas from the Tulare wastewater treatment facility and pro-ducing 500 MMBtu of biogas from 200 to 300 tons a day of dairy manure and other agriculture and food processing wastes. The gases will be conditioned on-site and then injected into the pipeline grid. The project received $5 million from the California Energy Commission renewable transportation fuel funds, $3 million from the solid waste authority and $500,000 from the air district. “The key with getting these grants is that your project must support GHG reductions, and you must have your permits before applying,” Schmitt says, adding that permit-ting takes time and money. “It’s been rather simple for us, we haven’t made it complicated by putting a digester on dairy with all of the regula-tions on water discharge—we avoided that nightmare. We’re just going into sewer so there are no issues with regard to the water quality board.” Black says California requires double-lined lagoons, a much higher stan-dard than elsewhere, and that adds to the costs. Schmitt says with all of the grid interconnection regulations in the electricity market, his project would be “bogged down for years.” SoCal gas interconnection, CEQA conditional use, air and solid waste permits were all “straight forward,” Schmitt adds.

For dairy projects intending to produce electricity for the grid, SB 1122 requires California’s three investor-owned utilities (IOUs) to pur-

THE FEW, THE PROUD: CalBio's Old River dairy lagoon digester project, one of only a few dairy digester projects in California to be built in recent years, is part of the state's first burgeoning cluster that will supply biogas to a centralized location where it will be conditioned and used to produce electricity. PHOTO: CALBIO

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¦BIOGAS

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chase 250 MW of bioenergy-based electricity from 3-MW or smaller distributed energy projects, with 90 MW set aside (in category two) for agriculture and dairy biomass and biogas projects. Projects classified as “dairy” must be 100 percent dairy manure, while ag waste biogas proj-ects may have up to 20 percent waste from other categories (i.e., urban or forest wastes). The regulations developed to implement SB 1122 are complicated and imperfect.

The ABC and the Bioenergy Association of California held a joint webinar May 14 titled “California’s New Bioenergy Program Set to Launch This Summer.” Christa Darlington, special counsel with the Placer County Air Pollution Control District, presented and identified key requirements to participate in the program. “There are a few things CPUC asks you to show,” she said. “One is whether interconnection is possible for your facility.” Darlington said projects are required to have a system impact study and be strategically located, and transmission-level upgrade costs must be below $300,000. “If upgrade costs are above that, the project will have to pay it down,” she said. “So it’s not a proj-ect development barrier, it’s just a pay-down requirement.” The project must also show that its team has experience, “a low bar to prove,” Dar-lington said. The project must also demonstrate the facility can comply with requirements, such as having 100 percent site control and an effec-tive capacity of no more than 3-MW electricity production. The facil-ity must be certified as RPS-eligible, qualify under the Federal Energy Regulatory Commission, have commenced operations on or after June 1, 2013, and be online within 30 months of an execution of a power purchase agreement (PPA).

The pricing mechanism is “one of the more complicated pieces of the program,” Darlington said. The first auction is expected this fall, and

every six days there’s a potential for new auction and, at that time, a re-view of what happened at the previous auction will be performed to de-termine a new price. The price starts at $127.72 per megawatt hour and may go up as high as the $197 cap. The price moves at increments of $4, then $8, and then $12 thereafter. The minimum number of bidders in a specific category is initially three, then after the first bidder strikes at a price there must be at least five projects in the queue before the price will start to move again for that category. The price will rise if less than 20 percent of the MW available per category is allocated. Then the price remains static for the next auction, and then the prices will rise at the following auction. Black says the concern is that it’s expensive to get into the queue, and a higher price is needed to attract projects, but the price doesn’t go up until a sufficient number of projects are involved. “That’s an example of the complexity,” Black says, adding that, while this may work well for solar, it may be problematic for biogas. The IOUs had in-put in drafting the regulations for SB 1122, and they intentionally made the process “as cumbersome as possible,” Boccadoro says. “They are using it as an obstacle to getting these projects built.”

Peter Brown, president of FFA Fuels, a company selling biodiesel processors and biogas digesters in cooperation with Polygen, says “Pe-troleum companies and the utilities are very powerful here,” and says that it’s no surprise that SB 1122 regulations are this burdensome, com-plex and discouraging for biogas projects. “I think SB 1122 is about people trying to make believe they’re moving on something that they haven’t budged on in 50 years,” Brown says. “It’s an unholy combina-tion of regulators banking on businesses banking on individuals from keeping this from happening.”

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BIOGAS¦

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The utilities “don’t love this program,” Black says. “It’s a small program for them that takes a lot of time, and these projects take a lot of money.” He says the bioenergy community is waiting to hear how PUC implements these regulations, particularly on important issues such as inflation adjustment. “The way this is structured, it could take a very long time to get to the price that’s needed,” Black says. “That’s why the grant side is so important when they’re taking a price at the low end of SB 1122.”

Brandon Moffatt, Energy Harvest Power Inc. senior vice president, presented on the ABC-BAC webinar and said a core issue in implemen-tation of SB 1122 is what to do with attributes from fuel diversion. He said the utilities have proposed a definition that could be interpreted in favor of them taking fuel diversion as well as electricity generation credits. “We reject this,” he said. “BAC and others objected that this ap-proach is inconsistent with prior CPUC and legislative intent. The green attributes issue is complex and needs updating from prior commission rulings.” He said a CPUC workshop to clarify this is likely.

Despite a complicated regulatory environment that simultaneous-ly promotes and discourages bioenergy production in California, two dairy digester projects under control of the American Biogas Energy Co., which is part of CalBio, are moving forward and have recently re-ceived grant funding: Lakeview Farms Dairy, Bakersfield and West Star North Dairies, Buttonwillow. Lakeview Farms Dairy received $4 million to install and demonstrate a covered lagoon digester that converts dairy manure into biogas to generate renewable electricity and to prepare a 1-MW generator platform capable of being expanded by using biogas from neighboring dairies. This would be the state’s first genuine dairy cluster, what many believe is a long time coming. Another project in

that cluster is Carlos Echeverria & Sons as well as CalBio’s existing 2 -W Old River project. “What’s unique and important about Lakeview is that we’re planning to build a 1-MW dairy digester, but the platform for that will be designed to add a second or third MW from neighboring dairies if and when we build dairy digesters in those,” Black says. “We’re trying to develop economies of scale both in capital expenses and in ongoing operations and management expenses. We’re delighted to have the large Old River project up and running, and to have received funding for two new projects in this cluster.”

Regulations in California are tougher than in other states because of its unique issues: nonattainment zones from dense human popula-tions and associated vehicle and power plant emissions along the coastal regions, juxtaposed with nonattainment zones from multiple sources, including the dense dairy population in the Central Valley. Black says all-in-all, the regulatory environment is improving for dairy digester de-velopment in California. “I think the regulatory community is filled with very smart, hard-working public servants trying to address two impor-tant issues,” he says. “That’s how to develop projects that protect the environment, and help this industry get created. And those are the right two things to be doing. We are hopeful the CPUC helps adjust SB 1122 since a successful program is a very important next step. Ideally the utilities, which helped on our independent projects, will come onboard, too.”

Author: Ron KotrbaSenior Editor, Biomass Magazine

[email protected]

Page 34: July 2015 Biomass Magazine

34 BIOMASS MAGAZINE | JULY 2015

AdvancedBiofuelNews

Renmatix Inc. has acquired the existing assets of a 56,000-square-foot manufacturing facility in Rome, New York, previously owned by Mascoma Corp. According to Renmatix, the new feedstock processing facility (FPF) is dedicated to the first step in the conversion of biomass to cellulosic sugars using propri-etary Plantrose process conditions. The FPF officially opened in April, becoming the third U.S. location for Renmatix.

With the FPF now in place, Renmatix said the acquisition creates a secure supply for

the company and its development partners at the Integrated Platrose Complex in Ken-nesaw, Georgia, where the second step in pro-duction of Plantro sugars is performed.

The acquisition is the latest in a series of strategic moves for Renmatix since mid-2014, including a series D investment from Total, the acquisition of Sweden-based REAC’s intellectual property portfolio, and an expan-sion of the IPC facility.

Renmatix acquires former Mascoma facility

Fulcrum Bioenergy Inc., has awarded Abengoa a $200 million engineering, pro-curement and construction (EPC) contract for the construction of the Sierra Biofuels Plant, the company’s first waste-to-trans-portation fuel facility. The facility, under development approximately 20 miles east of Reno, Nevada, is currently scheduled to begin operations during the third quarter of 2017.

Abengoa will construct the plant under a fixed-price contract that guarantees the schedule, startup and performance of the plant. “Abengoa is a large, well-respected EPC firm with years of experience in the

energy and biofuels industries and we are very pleased to be partnering with them on our Sierra project,” said Rick Barraza, vice president of administration with Fulcrum.

Once operational, the Sierra Biofuels plant will convert 200,000 tons of mu-nicipals solid waste into renewable syn-crude that will be upgraded to more than 10 million gallons of jet fuel annually. The company currently holds 20-year feedstock agreements with Waste Management and Waste Connections, as well as a 10-year offtake agreement with Cathay Pacific Air-ways.

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CONTRACTING FOR CONSTRUCTION: Abengoa has been awarded a $200 million EPC contract by Fulcrum for its 10 MMgy Sierra Biofuels Plant, depicted in this rendering. PHOTO: FULCRUM BIOENERGY INC.

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JULY 2015 | BIOMASS MAGAZINE 35

On May 29, the U.S. EPA released its long-awaited renewable fuel standard (RFS) renewable volume obli-gation (RVO) proposal for 2014, 2015 and 2016. The newly proposed rule represents a significant improve-ment for the advanced and cellulosic biofuels industry relative to the original 2014 proposed rule. Unfortu-nately, there is still a long road ahead for the EPA to finalize this rule, which could be exacerbated by various legal challenges at the end of the rulemaking process.

Covering three years, the proposal has been per-ceived as a mixed bag by many organizations. Some see it as an improvement over the previously introduced rule, while others see it as a step backward. For the next-generation biofuels industry, this proposed rule represents a solid improvement, especially for those in the advanced and biomass-based diesel pool, as well as those in the cellulosic pool seeking a concrete signal of the path forward for all advanced biofuels. The pro-posal utilizes actual production numbers—a pragmatic solution that the Advanced Biofuels Association has been advocating for the past 18 months—from 2014 and most of 2015 to set targets and proposes an ad-vanced pool of 2.68 billion ethanol equivalent renew-able identification numbers (RINs) for 2014, 2.9 billion for 2015 and 3.4 billion for 2016. These are significant increases over the 2.1 billion in 2014 rule.

Moreover, the proposed RVO numbers send a strong signal of support from the administration for the continued development of the advanced and cel-lulosic fuels that deliver the highest greenhouse gas re-ductions under the statute. Specifically, for cellulosic, it accounts for the 33 million gallons produced in 2014, and proposes 106 billion and 206 billion in 2015 and 2016, respectively. And, the biomass-based diesel pool is afforded 1.63 billion gallons in 2014, 1.7 billion in 2015, 1.8 billion in 2016 and 1.9 billion in 2017.

As for those who seem to be disappointed, the corn ethanol industry saw the EPA propose 13.25 billion gallons for 2014, 13.4 billion for 2015 and 14 billion for 2016. This is 1 billion gallons below the statutory number for corn ethanol as part of the over-all program. Not to be outdone, voices from the oil

industry associations are also unhappy, particularly with the 2016 proposal of 14 billion gallons of corn ethanol, given what they claim is a growing number of unblended gasoline gallons and the lack of demand for E-85 and E-15 in the marketplace. Both parties, either publically or in private, have started calling for lawsuits. In addition, some have doubled down their efforts to repeal or reform the program.

Legislatively, it is still too early to know what the response from Congress will be. However, given a few weeks to review the rule and hear from various stake-holder groups, I expect to have a better view of the congressional path forward by the beginning of July. Already, several key members of Congress have voiced their frustration with the law and its implementation, and have called for overall legislative reform of the RFS. Others continue to strongly advocate for com-plete repeal, which would be a devastating blow for all renewable fuels.

For those of you standing on the sidelines and wishing to weigh in on the topic, now is the time to write your members and draft your comments to re-spond to the proposed rule. EPA will hold a public hearing in Kansas on June 25 and has set the deadline for comments on this rule on July 27. It is important to note that the EPA has requested that comments focus on this new proposed rule only.

Although this proposal is truly an improvement to the original proposed rule for the advanced biofuels community, the position of Advanced Biofuels Asso-ciation remains unchanged. Statutory changes are re-quired if we are ever to recognize what was envisioned by the original authors of the RFS2 in terms of build-ing a next-generation biofuels industry of significance. Stay engaged.

Author: Michael McAdamsPresident, Advanced Biofuels Association

[email protected]

A Look at EPA’s RVO ProposalBY MICHAEL MCADAMS

ADVANCED BIOFUELS AND CHEMICALS¦

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36 BIOMASS MAGAZINE | JULY 2015

¦ADVANCED BIOFUELS AND CHEMICALS

Crunching the NumbersFirst- and second-generation ethanol leaders discussed challenges, priorities and successes at the International Fuel Ethanol Workshop in Minneapolis.BY ANNA SIMET

If Renewable Fuels Association President Bob Dinneen didn’t light a fire under the ethanol industry at the International Fuel Ethanol Workshop in Minneapolis in

early June, then it may be an impossible feat. Dinneen, whose career in the ethanol indus-try has spanned nearly a quarter of a century, delivered a rousing and passionate speech during the general session of the conference, where leaders of both the first- and second-generation sectors offered candid takes on the proposed U.S. EPA renewable volume obligation (RVO) numbers, reported on ex-isting and future production, and provided insight on industry trends, challenges and competition.

Dineen referred to the RVO numbers as being “strangely familiar,” and said that the EPA believes it is attempting to break the blend wall, but characterized it as “scratching it—an incomprehensible step backward.”

He said it appears EPA learned “abso-lutely nothing” from the massive number of comments received during the RVO com-ment period, and that the agency has con-sistently made the wrong decision on any number of issues. He implored audience members to attend the public hearing to be held in Kansas City on June 25.

Brooke Coleman, executive director of the advanced ethanol coalition, brought things in a slightly more positive direction,

declaring the RVO as being far from ideal, but said there is room for optimism, one rea-son being that the numbers are not yet final. “We could find ourselves in a profoundly dif-ferent place…until then…we can’t be disap-pointed.”

Coleman also commented that the D3 renewable identification number (RIN) mar-ketplace is being mismanaged, a point that Dan Cummings, president of Poet-DSM Advanced Biofuels, reiterated. Cummings described the current system as being “One of the more disappointing things for the new cellulosic ethanol producers…the EPA’s al-lowance for obligated parties to buy waiver credits instead of actual physical gallons.

DEPARTMENT

Mike Jerke, CEO, Guardian Energy Management; Jan Koninckx, global business director for advanced biofuels, DuPont Industrial Biosciences; and Chris Standlee, executive vice president, Abengoa Bioenergy, discuss first- and second-generation ethanol production at facilities of their respective companies.SOURCE: GAMUT ONE STUDIOS

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JULY 2015 | BIOMASS MAGAZINE 37

ADVANCED BIOFUELS AND CHEMICALS¦

They’re undermining the D3 system,” he said.

Chris Standlee, executive vice president of Abengoa Bioenergy, discussed how the EPA’s rulemaking delays have hampered advanced biofuels in the U.S. “I can speak from experience that it has impacted invest-ment…” he said, adding that it doesn’t mean that Abengoa has discounted the U.S. as a location for future facilities, as the company is actively pursuing a project using municipal solid waste as feedstock. However, Abengoa is largely focused on locations outside of the country, according to Standlee, includ-ing a second-generation facility in Brazil, colocated with the company’s ethanol plant there, as well as a second-generation facility in France, colocated with Abengoa’s existing starch facility.

Standlee reported that commissioning is ongoing at Abengoa’s cellulosic ethanol facil-ity in Hugoton, Kansas, saying “Starting up

a new technology plant is not for the faint of heart. We are producing, but not at full, annualized rates by any means.”

Cummings added that in the chemical processing industry, it generally takes about 20 years from when a process is isolated, to full-scale commercial production, and that Poet-DSM is currently working through some challenges in the pretreatment step of its process. The company brought online its first commercial-scale facility in Emmets-burg, Iowa, last fall.

When asked if the companies feel pres-sure from the EPA to meet RVO numbers —as the country’s first commercial-scale cellulosic ethanol plants—Cummings and Standlee said that most of the D3 category numbers will be fulfilled by biogas-based fuel over the next couple of years, but that the EPA polls advanced fuel companies to get an idea of what they project production will be.

Standlee added that while there is healthy competition when it comes to sell-

ing licenses for a respective cellulosic etha-nol technology, all producers currently in the game want to see each other succeed.

The session ended with panelists urging audience members to send their comments to the EPA, and to attend the upcoming hearing in Kansas City, in order to achieve the best possible outcome in the final rule, due to be released in late fall. “There will be huge ramifications from what happens in November for the advanced ethanol mar-ket,” Coleman said.

Author: Anna SimetManaging Editor, Biomass Magazine

[email protected]

Brooke Coleman, executive director of the Advanced Ethanol Coalition, said that while the recently released renewable fuel standard re-newable volume obligation numbers are far from perfect, they are not final and could change with the final RVO rulemaking.SOURCE: GAMUT ONE STUDIOS

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38 BIOMASS MAGAZINE | JULY 2015

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