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TOPIC: NYC Council hearing on the "Sustainability of Biofuels"

NYC Council hearing on the "Sustainability of Biofuels"

250 Broadway
NY, NY 10007

Wednesday, February 25th @ 10am

More details on the hearing can be found on the New york City council wesbite:

To find out more about biofuels in the New York City context download the HabitatMap fact sheet, Heating New York With Biodiesel, A Bad Idea:
The .pdf mentioned above is full of inaccuracies. I'm sorry to see that, these are still being posted on the web more than a year after this false testimony was delivered at the city council meeting.

Below are some accurate facts. I apologize for such a long post.

A twenty percent biodiesel blend in heating oil can reduce nitrogen oxide emissions by 20 percent and reduce sulfur oxide emissions by 83 percent1. While the switch to Ultra-Low Sulfur Diesel (ULSD) in heating oil can also reduce sulfur emissions, biodiesel provides greater reductions in nitrogen oxide emissions as well as reductions in particulate matter and polyaromatic hydrocarbons. A combination of biodiesel and ULSD would provide the optimum air quality improvements with direct health benefits to the citizens of New York City.
The National Biodiesel Board supports improvements in environmental and economic performance as evidenced by our sustainability principles (see: ). We also believe that biodiesel is currently the most advanced renewable motor fuel available and holds the most promise to put new advancements into real-world application.

The development of new feedstocks is the industry’s greatest opportunity for advancement. The existence of 176 biodiesel production facilities with over 2 billion gallons of capacity for processing new feedstocks is stimulating advancement in the commercialization of algae, waste grease recovery, and lipid recovery from municipal wastewater2. These advanced feedstocks need a healthy, thriving biodiesel industry to convert those oils into a fuel than can displace petroleum in buses, trucks, tractors, other heavy equipment and fuel efficient light-duty diesel vehicles and hybrids.

Biodiesel is made in the US from a variety of locally-grown feedstocks. Those feedstocks include: soybean oil; canola oil; cotton seed oil; recycled cooking oil; reclaimed waste grease; oil from algae; and animal fats from beef, pork, and poultry processing. The biodiesel industry has built over 176 production facilities all across the US that can use domestically produced feeedstocks to displace foreign petroleum used in this country. The US biodiesel industry has set a goal to displace 5% of on-road petroleum diesel by 20153. The 700 million gallons produced in 2008 puts us on a path to reach that goal.

The link between the growth in biodiesel and the rise in food prices is a misperception perpetrated in large part by the Grocery Manufactures Association’s (GMA) multi-million dollar media campaign to blame biofuels for the dramatic rise in grocery prices and distract consumers from their own record profits. You can read more at . The circumstantial link between volumes of biofuel and rising food commodity prices has proven unfounded in recent months as commodity prices have dropped sharply while biodiesel production continues to rise. 2007 biodiesel production in the US was approximately 500 million gallons. 2008 production was nearly 700 million gallons. The drop in food commodity prices as a result of the drop in oil prices exposed the GMA’s faulty reasoning.

Biodiesel uses the most diverse raw material supply of any commercially available fuel and is based on local and regional resources including vegetable oils, animal fats, recycled oils and waste greases. Biodiesel from soybean oil is ultimately a net positive for the food supply for many reasons. First, soybeans are grown for their 80% protein-rich meal which is used for food and feed. The 20% oil portion is used for salad dressing, frying oil, and processed foods like the gooey filling in convenient store desert cakes. While using soybean oil can slightly impact the cost of those products, it causes the protein meal to be priced lower than it ordinarily would. This makes healthy protein for food and feed cheaper and more abundant. There is a good explanation of how soy biodiesel makes soy protein meal less expensive at . Soy protein is a valuable tool in fighting hunger through school feeding programs around the world. The availability of school meals not only helps children learn, but it gives an incentive for families to send children, particularly girls to school. The approximately 400 million gallons of biodiesel made from soybeans in the United States in 2007 alone, co-produced enough soybean meal to equate to 115 billion rations of protein for school feeding projects like the one our World Soy Foundation supported with the Adventist Development and Relief Agency in Ghana.

Domestic economic growth as a direct result of the biodiesel industry generates more tax revenue that is costs. The biodiesel industry has contributed significantly to the domestic economy. The 51,893 jobs that are currently supported by the U.S. biodiesel industry reflect the beginning of the industry’s potential to create jobs and economic growth in the U.S. economy. Biodiesel has added $4.287 billion to the Gross Domestic Product. Biodiesel has the potential to support more than 78,000 jobs by 2012. The NBB estimates that for every 100 million gallons of biodiesel that is produced from algae, 16,455 jobs will be created and $1.461 billion will be added to the GDP.

A lifecycle inventory conducted by the USDA and DOE determined that biodiesel reduces greenhouse gas emission by 78% compared to petroleum diesel1. This reduction is obtained because the carbon emitted as biodiesel is burned was originally pulled from the atmosphere by a soybean plant. In effect, the carbon is being naturally recycled with no net addition of CO2 to the atmosphere. This is in stark contrast to petroleum which pulls carbon, in the form of crude oil from deep within the Earth’s crust and spews that carbon into the air as it is refined or burned. It is this process of unlocking millions of years of sequestered carbon from buried fossil fuels that is responsible for 80% of human-induced greenhouse gas emissions and is the leading cause of global warming that threatens our earth and our way of life3. This analysis of soy biodiesel conducted by USDA and DOE considered every bit of energy and associated greenhouse gas (GHG) emissions emitted in the production of soy biodiesel. This included everything required to plant, grow, harvest, transport, and crush soybeans, as well as the energy required to convert surplus soybean oil to biodiesel and transport it to a retail fuel station. In 2008, US biodiesel production was nearly 700 million gallons. By displacing 700 million gallons of petroleum, we reduced GHG emissions equivalent to removing 980,000 vehicle form the roadway. No other fuel can claim real-world reduction in GHG emissions of the same magnitude. The USDA/DOE study conducted in 1998 also showed that the energy balance for biodiesel was 3.2 units of energy output per unit of fossil energy input. That analysis was recently updated by the University of Idaho which found the energy balance is now 4.56 to 1 and predicted to reach 5.44 to 1 by 2015. This improvement is due to increased crop yield, improvements in farming and processing efficiency. Since carbon emissions and energy go hand in hand, it would stand to reason that biodiesel’s GHG emissions are also getting better with time.

Biodiesel is a diesel replacement fuel that is made from agricultural oils, fats and waste greases that meets a specific commercial fuel definition and specification. The fuel is produced by reacting renewable feedstock with an alcohol to remove the glycerin and result in an alkyl-ester that meets the D6751 fuel specifications set forth by ASTM International. Alkyl-esters have physical properties similar to diesel fuel which makes them compatible with heating oil and diesel fuel injection equipment. However, the alkyl-ester chemical compound is different than a diesel fuel molecule. These chemical differences result in biodiesel’s nontoxic and biodegradable characteristics as well as reductions in harmful emissions. Biodiesel is one of the best-tested alternative fuels in the country and the only alternative fuel to meet all of the testing requirements of the 1990 amendments to the Clean Air Act. Methanol is the most commonly used alcohol in the transesterification process and constitutes approximately 10 percent of the material used to make biodiesel. Renewable ethanol and renewable methanol can be used for a 100% renewable fuel. The USDA/DOE study conducted in 1998 also showed that the energy balance for biodiesel (using methanol) was 3.2 units of energy output per unit of fossil energy input. More on that inventory can be found at these sites:
• 2 page fact sheet:
• 60 page summary:
• 300 page report:
This positive energy balance takes into account the energy used to plant, grow, harvest, transport, and process soybean oil into biodiesel and transport it to the point of use. That analysis was recently updated by the University of Idaho which found the energy balance is now 4.56 to 1 and predicted to reach 5.44 to 1 by 2015. This improvement is due to increased crop yield, improvements in farming and processing efficiency.

Biodiesel is an advanced biofuel as defined by the Energy Independence and Security Act. It is the first, and currently the only, advanced biofuel to have achieved market commercialization. While biodiesel has been in development for many years, the roots of its US commercialization can be traced back to January 2005, when the biodiesel tax credit (There are no tariffs on biodiesel in the US.) took effect. The biodiesel tax credit has been the most effective alternative energy incentive program in US government history. In the last 4 years, the biodiesel industry has built more than 100 renewable refineries, added over 50,000 green jobs to the economy, over $4.2B to GDP, and has generated federal, state, and local tax revenue that far exceeds the cost of the program.

As the first, and currently, the only advanced biofuel to be commercialized, biodiesel is driving research and innovation in plant science technology. Nonexistent or yet-to-be-commercialized fuels do not drive markets and innovation. Biodiesel can be made from any natural vegetable oil, animal fat, or oil from algae. The current US biodiesel industry is very diverse in the types of feedstock in use. Many production facilities use multiple feedstocks. Animal fats and recycled greases constitute a greater proportion of production in recent volume growth. While the amount of biodiesel produced each year has grown, the amount of virgin vegetable oil used has remained steady. The existing 176 biodiesel plants are stimulating development of new feedstocks such as waste greases and algae. These new feedstocks can readily be used in existing biodiesel production facilities. The National Biodiesel Board has a feedstock development program and welcomes collaboration to advance the commercialization of oil from algae and other sources. A summary of the leading alternative feedstocks is available at .

As described above, the USDA/DOE lifecycle inventory took into account all fuel, energy, fertilizer, and chemicals used in the process of making soy biodiesel and concluded that biodiesel use reduces greenhouse gas emission by 78% compared to petroleum. That study also concluded that biodiesel reduces wastewater production by 79% and reduces hazardous waste production by 96% compared to petroleum. There have been numerous studies by other agencies and academic institutions that prove the reduction in harmful diesel exhaust emissions when biodiesel is used. The USEPA has surveyed the large body of biodiesel emissions studies and concluded that biodiesel reduces total unburned hydrocarbons by 67%, reduces carbon monoxide by 48%, reduces particulate matter by 47%, reduces sulfates by 100%, reduces polyaromatic haydrocarbons (PAHs) by 80%, reduces nitrated PAHs by 90%, and reduces ozone forming potential of speciated hydrocarbons by 50%. These results are published at . As pointed out above, biodiesel in heating oil application also reduced oxides of nitrogen (NOx), which can sometimes be raised in diesel engines using biodiesel. The different type of combustion from a diesel engine to a boiler or furnace results in reduced NOx emission in heating oil applications.

While it is true that nitrous oxides have a more potent greenhouse gas effect than CO2, it should be pointed out that the 78% greenhouse gas reduction of biodiesel is measured in CO2 equivalents, which factors in the potency of other gases such as nitrous oxides. This statement by Habitat Map should not mislead readers into thinking that all greenhouse gases are not accounted.

US farmers have a long tradition of employing technological improvements to produce a growing bounty of food commodities. These technologies allow farmers to produce higher crop yields on less acres with less inputs. This results in decreased energy use (less passes over the field with a tractor), less soil erosion, and more land available for natural habitat. Very recent improvements in plant science have been paired with advancement in herbicide development. Glyphosate is one of these new advancements. Glyphosate is much more environmentally friendly than the pesticides it replaces, representing a net benefit for the environment and a trend of continual improvement10. Pesticide handling and use is one of the most highly regulated industries in the world. Scientists and public officials have seen fit to regulate that aspect of food production to ensure public safety is protected. Biodiesel uses a co-product of food production. No new acres or unsustainable practices are put into production for the purpose of producing more vegetable oil. In fact, traditional plant breeding had reduced the oil content of soybeans, because the protein meal represented a higher commercial value. By providing an economic benefit from the co-product soybean oil, biodiesel makes farming more economically sustainable and drives innovation for further environmental improvements. One of the potential feedstocks for biodiesel is mustard seed. If biodiesel development drives the cultivation of mustard to be more commercially viable, a valuable co-product of the mustard oil is residual cake which has strong potential market value as an organic pesticide11.

In terms of U.S. soybean farmers, GHG-friendly no till practices increased from 6 to 22% from 1990 to 2004. According to the U.S. Environmental Protection Agency, herbicides used today are 10 times less toxic than those used before the 1990s. From 1990 to 2002 yields increased from 34.1 to 42.7 bushels per acre and are expected to increase as much as 10 percent in the next two years due to new seed varieties. And, finally, it is important to remember that soybeans do not require nitrogen fertilizer – unlike corn, they make their own nitrogen.

US biodiesel production in 2009 is likely to be considerably less than that. Currently, there are 176 active biodiesel production facilities in the US with a capacity to produce 2.6 billion gallons. However, 2008 saw the largest volume of biodiesel ever produced in the US at just under 700 million gallons. This was up from 500 million gallons in 2007. In 2007, approximately 400 million gallons of biodiesel was made from virgin soybean oil. The rest was made for animal fats, recycled greases and other feedstocks. In 2008, the amount of biodiesel made from virgin soybean remained constant at 400 million gallons. The growth in biodiesel production was made primarily of other feedstocks. Absent a change in current market forces or federal energy policy, the biodiesel industry could see a significant drop in sales for the first time since the fuel's introduction, to as low as 300m gallons.

The US biodiesel industry has set a goal to displace 5% of on-road petroleum diesel by 2015. This volume is equivalent to the amount of diesel used in America refined from Iraqi and equivalent to one quarter of the diesel refined from Persian Gulf crude. Freeing the US from reliance on politically unstable parts of the world such as the Middle East is the most critical thing we can do for energy independence.

The estimates for CO2 released during land conversion vary widely. For certain land types, more carbon can be sequestered during farming operations than in the land’s previous state. However, the more important thing to note is that no new land needs to be cleared to meet the US goal of displacing 5% of petroleum diesel. The Energy Independence and Security Act of 2007 requires that biodiesel meeting the requirement of advance biofuel cannot be made from feedstock from land that was cleared after enactment of the law. Additionally, The US biodiesel industry has adopted a sustainability principle that states “Biodiesel shall contribute to climate change mitigation by significantly reducing lifecycle greenhouse gas emissions as compared to fossil fuels. Producers shall strive to continuously improve that reduction.”

Biodiesel used approximately 12 percent of US soybean oil production in recent years. This far from exhausts the annual surplus of soybean oil in the US the results from the production of soy protein meal, nor does it stop the export of whole beans for use in other countries.

Biodiesel requires no change in land use. Biodiesel requires no additional acres of soybeans. Eighty percent of each soybean is protein meal with a high food value. Approximately twenty percent of each soybean is oil. This oil can be used for food uses such as deep-frying foods and manufactured items such as candy bars. When the market for vegetable oil for these products is low, such as when triggered by New York City’s ban on trans fats, the surplus oil can be used for biodiesel with no change in land use. Biodiesel helps ensure the availability and reduces cost for food commodities as described above.

Food prices are impacted much more by the rising price of fuel (petroleum). By adding capacity to the fuel production sector, biofuels helped reduce fuel prices by 10-15% in the period described. As described previously, biodiesel lowers the feed inputs for dairy and poultry.

Malaysia is implementing a program to fell 700,000 hectares of palm plantations to control palm oil prices. Palm oil prices are so low, due to excess supply, the local government is implementing these measures to maintain the economic sustainability of the industry for all the products it produces, primarily food.

The handful of public policies that support biodiesel production and use are the result of our democratic process that deem the benefit of these programs to be in the public interest. Many of those benefits have already been described in this document. In addition to those, biodiesel offers ecological benefits. Biodiesel has strong attributes that make it more environmentally friendly than petroleum diesel, and no other fuel rivals it as a replacement in today’s diesel fleet or diesel engines of tomorrow. Biodiesel is nontoxic and biodegradable. More info can be found at . Biodiesel reduces wastewater production by 79% and reduces hazardous waste production by 96% compared to petroleum diesel. These reductions were quantified in a comprehensive life cycle inventory conducted by the USDA and DOE. A summary can be found at .

The biodiesel tax credit program generates twice as much revenue for the federal government than the cost of the program. In this regard, the biodiesel industry is working for every American and paying dividend in environmental protection and energy security.

Don Scott, PE
Director of Sustainability
National Biodiesel Board

1. Massachusetts Oilheat Council & National Oilheat Research Alliance, Combustion Testing of a Biodiesel Fuel Oil Blend in Residential Oil Burning Equipment, 2003.

1. USDA/DOE 1998, Life Cycle Inventory of Biodiesel and Petroleum Diesel for Use in an Urban Bus.
2. Dev Shrestha , University of Idaho, presentation at the 2009 National Biodiesel Conference and Expo, San Francisco, CA Feb 2, 2009.
3. U.S. Climate Change Science Program 2009, Global Climate Change Impacts in the United States.
4. Massachusetts Oilheat Council & National Oilheat Research Alliance, Combustion Testing of a Biodiesel Fuel Oil Blend in Residential Oil Burning Equipment, 2003.
5. National Renewable Energy Laboratory, Impact of Biodiesel Fuels on air Quality and Human Health, 2003
6. Calculated from lb/person estimate given by National Renewable Energy Laboratory 1998, Urban Waste Grease Resource Assessment.
7. Gavin Newsom press conference San Francisco, CA, Feb 4, 2009.
8. C. Ving, City of San Francisco, presentation at the 2009 Sustainable Biodiesel Summit, San Francisco, CA, Jan. 31, 2009.
9. www.biodiesel
10. USDA/University of Idaho Energy Balance paper
11. Worldwatch Institute, Biofuels for Transport, 2007
Please see slide show for accompanying images and graphs:

Hi, my name is Michael Heimbinder. I'm the Executive Director of HabitatMap.
HabitatMap is a Brooklyn based environmental health justice non-profit.

I want to thank Conor for inviting me to speak today, and I want to thank all the folks who worked behind the scenes to help make the Brooklyn Food Conference happen.

Let me begin by simply stating, there are “good” biofuels and there are “bad” biofuels and the difference between the two is primarily determined by what feedstock is used and how that feedstock is produced.

For instance, by producing biodiesel from recycled restaurant grease collected from New York City restaurants, businesses like Tristate Biodiesel lead the way in the production environmentally friendly biofuels. Tristate takes a product that restaurants often pay to dispose of and transforms it into a valuable commodity that can fuel our vehicles and heat our homes.

Unfortunately however, there just isn’t enough “good” biodiesel to go around. Currently Tristate only produces around one million gallons of biodiesel annually and though they may be capable of scaling up production, their capacity to produce “good” biodiesel is necessarily limited by the availability of local restaurant grease.

Today, soybean oil is the most widely used biodiesel feedstock in the United States. According to U.S. data on plant capacity and feedstock utilization put together by the National Biodiesel Board, soybean oil accounted for at least 40 percent of biodiesel feedstock and since many plants report utilization of multiple feedstocks, the actual soybean oil share is likely much larger. Other vegetable oils made up much smaller shares. Canola accounted for about 5 percent and recycled and waste vegetable oil for less than .005 percent.

So when we evaluate whether were fueling up with good or bad biodiesel in the US, we primarily need to consider where our soybeans our coming from and how those soybeans are being produced. Simply put, what are the environmental and social implications of cultivating soybeans in the United States?

As is illustrated in this slide, most of the soybeans grown in the US come from the Midwest and the Mississippi Corrdior where the average farm operation is hundreds of acres. These are industrialized monoculture mega farms that devour and destroy enormous quantities of non-renewable and irreplaceable resources.

[SLIDE 4 & 5]
Powering the machines that plow, plant, harvest, cast fertilizers, pump irrigation water, spray pesticides, etc. is energy intensive. The fossil fuels consumed by on-farm operations release significant quantities of greenhouse gases and toxic air emissions.

Adding to soybean agriculture’s formidable fossil fuel tally, large amounts of natural gas are needed to produce the nitrogen based fertilizers that promote their growth. These fertilizers break down in fields releasing nitrous oxides, a global warming agent hundreds of times more potent than CO2. When these fertilizers leach from farm fields they poison drinking water and ravage marine ecosystems. Run-off from Midwestern farm fields ends up in the Gulf of Mexico where it contributes to a New Jersey-size “dead zone” almost entirely absent of marine life. The red zones in this slide indicate areas of the Gulf almost devoid of dissolved oxygen.

Making matters worse, 91 percent of the US soybean acreage planted in 2007 was genetically engineered to tolerate herbicides, a development that has boosted glyphosate applications several fold. Glyphosate, a powerful weed killer, is the third most common cause of pesticide illness in farm workers; exposure has been linked to rare cancers, miscarriages, and premature births.

Of the approximately 70 million acres of soybeans grown in the US, less than 0.2 % is certified organic by the USDA. That means that at least 99% of the virgin feedstock used to produce biofuels is coming from conventional agro-industrial farms that are anything but environmentally friendly. This fact raises the fundamental question, "How can biofuels be environmentally friendly when they are primarily produced from crops that were cultivated using environmentally destructive practices?".

And the problem only gets worse as demand for biofuels grows. A demand, it should be noted, that is largely a result of government subsidies and consumption mandates. As is illustrated in the graph, the US produced 700 million gallons of biodiesel last year and if the trend line continues we can expect to be producing billions of gallons in the very near future.

Or can we? As stated earlier, the US produces approximately 70 million acres of soybeans annually. With a yield of approximately 60 gallons of biodiesel per acre of soybeans, we could potentially produce 4 billion gallons of soybean derived biodiesel annually if we dedicated every acre of soybeans to biodiesel production. That four billion gallons represents less than 6% of annual diesel consumption in the US. So where will the US get the vegetable oil we need to meet consumption mandates?

Low-income countries offer cheap land and labor and tropical crops such as palm can yield eight times more oil per acre than soybeans. If we continue to mandate the consumption of biodiesel we will exhaust domestic soybean acreages and the economics of vegetable oil will shift production to the tropics. Grasslands, wetlands, and forests will be cleared to make way for palm plantations destroying wildlife habitat and releasing millions of tons of greenhouse gases. Note that clearing new land for energy crops releases up to 420 times more CO2 than the fossil fuels they displace.

Data on US palm oil imports already indicate that this trend is well underway. For 2008/09, US imports are expected to expand by 22 percent to 1.16 million tons. This devastated forest in Borneo is being terraced to make way for a palm plantation.

[SLIDE 10]
Bringing the biofuels debate back to the New York City setting. The City Council is currently considering legislation that would require heating oil include biodiesel. If passed, the “bioheat” mandate will increase heating oil costs by 15-30 cents a gallon, do little to improve air quality beyond what can be achieved with ultra low sulfur diesel, encourage environmentally destructive farming practices, have no impact on foreign oil consumption, devour millions of dollars in taxpayer subsidies, and increase greenhouse gas emissions. Rather than require biodiesel, City Council should authorize an ultra low sulfur diesel heating oil mandate.

One million households and thousands of businesses in New York City consume approximately 500 million gallons of high sulfur heating oil annually. Because the sulfur content of fuels is directly related to emissions of fine particulate matter, heating oil ranks as the largest source of fine particulate matter in the city. Able to penetrate into the deepest portions of the lungs, fine particulate matter contributes to premature death from heart and lung disease, cardiac arrhythmias, heart attacks, asthma attacks, and bronchitis. By mandating ultra low sulfur diesel we can remove sulfur from our heating oil thereby reducing fine particulate matter emissions by more than two-thirds. In addition, ultra low sulfur diesel improves furnace efficiency, decreasing fuel consumption and reducing maintenance. Onroad vehicles are already required to fill up with ultra low sulfur diesel; why should our homes be an exception?

I urge you to contact your City Council member and Mayor Bloomberg today in support of an ultra low sulfur diesel heating oil mandate that does not include biodiesel. Let them know that by simply switching to ultra low sulfur diesel heating oil we can dramatically improve the quality of the air we breathe daily while reducing oil consumption, and we can do it without raising the cost of home heating or depending on unsustainable and environmentally destructive biodiesel!

[SLIDE 11]
In conclusion I’d like to leave the audience with this question: Now that we know where our biodiesel comes from, do we really want to keep forking over our tax dollars to subsidize biodiesel, to fatten up agribusiness to the tune of 2 billion dollars a year, that’s approximately $2.00 per gallon, when the costs of agro-industrial agriculture to our environment and quality of life is so dear.

I have read your post very carefully. I can tell you are sincere in your concern for social and environmental impacts, and I support that cause. However, some of your points are dangerously flawed if they lead us back to sole reliance on fossil fuels.

I am not a salesman or a lobbyist. I am an Environmental Engineer. I spent a dozen years in the public sector working for the Missouri Department of Natural Resources, primarily protecting sources of clean drinking water. I joined this not-for-profit organization (the National Biodiesel Board); because, like you, I realize that our society has some very important decisions to make regarding energy if we are to sustain ourselves. Please take a moment to consider the facts I offer. Only the facts will help us find the path to a more sustainable energy mix. These are not opinions, or spin, or rhetoric. Those only serve to confuse and hamper the improvements we desperately need.

The US Biodiesel industry has set a goal to displace 5% of US petroleum diesel demand by 2015. As you point out, we cannot produce enough biodiesel to displace our huge demand for fossil fuels. The fact that we are dependent on petroleum to such a large degree is troubling, and should inspire us to make a difference every way we can. The goal of 5% displacement is based, in part, on the volume of feedstocks that exists today. I believe the biggest flaw in your reasoning is that biodiesel use is going to dramatically increase agricultural production and increase negative environmental impacts. That is simply not the case.

When biodiesel is made from soybeans, only the oil is used (and only a very small portion of soybean oil produced is used for biodiesel). Soybeans are grown primarily for their protein-rich meal. This meal constitutes 80% of every bean. When beans are crushed to produce protein meal for livestock feed, the oil is a coproduct. Traditionally, the oil has been under utilized and undervalued. Biodiesel provides a market to put this underutilized commodity to a higher purpose. That purpose is displacing petroleum and generating a further GHG benefit from land already in agricultural production. The US biodiesel industry does not drive any increase in pesticides, erosion, fuel use, or land use. It simply would not make economic sense to plant more soybeans to satisfly a demand only for soybean oil unless there is also a demadn for protein meal. Biodiesel merely utilizes coproducts, byproducts, and wastes that result from existing activity. Even future, potential, indirect land use change has been included in EPA’s analysis of biodiesel’s GHG emissions, and biodiesel is still 57% better than petroleum diesel.

Current utilization of recycled grease in NY has not yet met its full potential. In addition to recycled restaurant grease, waste greases exist that can be reclaimed from the wastewater stream. Together, these greases can supply nearly 20 million gallons a year. For this to happen, the biodiesel industry needs your support, and it is not necessary to discriminate between “good biodiesel” and “bad biodiesel”. In fact, to do so is damaging to the cause of displacing as much petroleum (one might call it “worse petroleum” as possible.

In 2009, the US produced slightly over 500 million gallons of biodiesel. 46% of that was soy. 6% was yellow grease (recycled). 17% was animal fats (excluding edible tallow). What is more interesting than these statistics from a single year is the trend. The trend is that soy biodiesel is remaining relatively constant in absolute volume (declining in percent of total biodiesel volume), while other feedstocks are growing in diversity and growing in utilization as biodiesel feedstocks.

When you describe plowing (No till is growing beyond 22%, BTW), planting, and harvesting and the energy and emissions associated with those activities, you should keep in mind that all those activities and more are included in the lifecycle analysis of biodiesel. The latest study on energy from the USDA reports that for every unit of energy invested in soy biodiesel production, 4.56 units of usable, stored solar, energy are returned in the liquid fuel. The latest lifecycle analysis from EPA on soy biodiesel concludes that direct GHG emissions are reduced 85% (that number is lowered to 57% when indirect land use change estimates are added) compared to petroleum diesel. This includes nitrous oxide emissions. When you point out that N2O is more potent that CO2, you should not miss the fact that EPA (and all other lifecycle analysis) have already included that factor into the calculations.

When it comes to nitrogen fertilizers, it is also important to understand that soybeans remove nitrogen from the atmosphere and fix nitrogen into the soil where it is a natural and valuable nutrient for plant growth. This is a primary reason why soybeans are planted in rotation with corn-because they leave nitrogen in the soil and reduce the amount of commercial fertilizer that needs to be added to a following season of corn or other crop. Planting soybeans in rotation with corn or other continuous crops also breaks the cycle of pest infestations and is a natural deterrent to invasive plants, insects, and other pests.

The hypoxia you describe in the Gulf of Mexico is not a result of the biodiesel industry, nor will the US biodiesel industry cause an increase in this phenomenon. For context, I suggest you go online to to view a map of the Deepwater horizon oil spill in the Gulf of Mexico. While crude oil is, unfortunately, likely to be part of our energy future for some time, 5% displacement by biodiesel could help reduce the occurrence of petroleum disasters such as this.

Glyphosate is much safer than the pesticides it displaces. Before you criticize that existing EPA regulations for pesticides are not strict enough, realize that all things must be judged relative to the entire system and viable alternatives. Environmentally safe herbicides allow for no-till farming which reduces soil erosion, reduces on-farm fuel use, and reduces the need for additional land by producing higher yields on existing acres. And keep in mind that we can produce enough biodiesel to displace 5% of our petroleum diesel without planting more acres or using more pesticides.

If you want to compare the total environmental impact of soybean production with the production of petroleum, I suggest you view the report at . In this report, you will find mostly positive, and some negative impacts of biodiesel compared to petroleum production. Biodiesel is not perfect, but it is vastly superior to the alternative of fossil fuels. Also keep in mind, that this report only includes production, it does not include the overwhelming benefits of reducing emissions when biodiesel replaces diesel fuel in a diesel engine.

The federal Renewable Fuel Standard (RFS)is the policy most likely to influence the volume of biodiesel used in the US in coming years. The requirement for biomass-based diesel fuel tops out at 1 billion gallons. This is most likely to be fulfilled by a mixture of soy biodiesel, recycled and waste greases, animal fats, and inedible corn oil extracted from corn ethanol byproducts. 1 billion gallons of biodiesel can be produced from existing surpluses of soybean oil and better utilization of waste greases. We need all of these sustainable sources to fulfill the national goal. EPA has not published lifecycle GHG analysis for palm oil or other vegetable oil-based biodiesel. Until they publish such analysis showing that these biodiesel’s also reduce GHG emission by a minimum of 50% compared to petroleum, these fuels are not eligible for the program and not likely to enter the US market in any significant way. In addition, any renewable fuel used to meet obligations of the RFS must certify that it was produced on land that was already in agricultural production prior to December 2007. The photo in your slide show showing a forest devastated for the production of palm oil was most certainly not cleared for the production of biodiesel for the US market. Tropical deforestation is a compelling issue. It must be stopped, but the US biodiesel industry is not to blame for these transgressions. Anything other than addressing the direct causes of deforestation is a distraction, and actually puts us further away from solving the real problem.

The membership of the National Biodiesel Board is very diverse, and yet that entire membership adopted a set of sustainability principles that includes protection for natural ecosystems as an expression of their commitment to improve the state of our energy reliance without negative environmental, social, or economic impacts.

Biodiesel and ultra low sulfur diesel fuel (ULSD) together can improve the emission of New York’s heating oil use. The switch to ULSD alone cannot accomplish the reductions in particulate emission, NOx, carbon monoxide, and polycyclic aromatic hydrocarbons that can be obtained with biodiesel use. The bill currently proposed in the New York City Council includes a mere 2% biodiesel blend. This is a modest amount of biodiesel, but the net reductions in emissions that impact human health are significant. The proposed bill includes no taxpayer subsidy for biodiesel. Your comments blur the issue between the issue currently before the city council and the federal biodiesel tax credit.

The federal biodiesel tax credit expired in December of 2009. I’m curious if that makes you more or less in favor of biodiesel use in New York City? The US biodiesel industry is hopeful that the federal tax credit will be renewed. The industry has fulfilled all the promises that supported the original legislation. We have made real progress building domestic businesses and infrastructure to produce renewable fuels in this country, using our natural resources and our domestic workforce rather than borrowing money from China and Japan to buy crude oil from Venezuela and the Middle East. The tens of thousands of jobs supported by the US biodiesel industry create twice as much tax revenue for the treasury than the biodiesel subsidy costs. So, it is a very wise investment of taxpayer money, indeed.

I know it may be asking a lot to set aside your opinions of production agriculture to consider the facts about biodiesel, but that’s exactly what I’m asking you to do. The citizens of New York are relying on Habitat Map and similar benevolent organizations to guide them towards a more sustainable future. Biodiesel can make our fuel dependence more sustainable today. Using a responsible amount of biodiesel today can buy us some time and stimulate some innovation to find more solutions for a better tomorrow.

Don Scott, PE
Director of Sustainability
National Biodiesel Board
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