California ARB releases discussion paper on regulation of biodiesel fuels

18 February 2013

The California Air Resources Board (ARB) released a white paper—titled “Discussion of Conceptual Approach to Regulation of Alternative Diesel Fuels”—outlining the intended approach to regulate alternative diesel fuels, with focus on biodiesel fuels. The regulatory concepts presented in the paper will be discussed during a public workshop to be scheduled in the Spring 2013.

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Under the federal Renewable Fuels Standard (RFS) and the California Low Carbon Fuel Standard (LCFS), fuel suppliers must include more renewable and low carbon replacements for conventional gasoline and diesel. The potential alternatives to petroleum diesel include biodiesel (fatty acid methyl esters, FAME), renewable diesel (hydrogenated vegetable oil, HVO), gas-to-liquid diesel (GTL) and other synthetic diesels. The white paper outlines a general regulatory policy for all alternative diesel fuels, and introduces a regulatory concept for biodiesel fuels, including neat biodiesel (B100), as well as high- and medium-level biodiesel blends.

The general requirements applicable to alternative diesel fuels (ADF) would include:

1. Formal governmental recognition: For any new fuel, the fuel proponent should obtain some formal recognition, such as through the US Environmental Protection Agency (EPA) registration under 40 CFR Part 79.
2. Public health and safety information: For any new fuel or blendstock, the fuel proponent must develop information regarding any adverse public health effects from exposure and regarding public safety.
3. Multimedia assessment: For any new ADF or hydrocarbon-based diesel fuel blendstock that requires ARB to establish new specifications, a multimedia assessment would be required. A multimedia evaluation requires the identification and evaluation of any significant adverse impact on public health or the environment, including air, water, or soil, that may result from the production, use, or disposal of the motor vehicle fuel.
4. Development of fuel specifications: For any new ADF or hydrocarbon-based petroleum diesel substitute, specifications must be developed (e.g., ASTM standards) to address vehicle performance, public safety and fuel production issues.
5. Approved ADF use in certified engines: For ADFs and drop-in diesel fuel substitutes, an evaluation must be conducted to address any adverse impacts associated with the use of the new diesel replacement in certified diesel engines in California. It is possible that future diesel fuel replacements may require engine and/or fuel system modifications, especially for retroactive use in the existing fleet. In this regard, fuel proponents would be required to obtain the necessary government approvals to use the replacement diesel fuel in current and new certified engines.
6. Other state and federal regulations: Fuel proponents are to comply with any other applicable state or federal regulations regarding the use of the new fuel.
7. Detection test methods: Test methods for the measurement and detection of fuel properties.
8. Enforcement protocol: Provisions to address blending, labeling, product transfer documentation, test methods, reporting, and recordkeeping.

Biodiesel would be the first alternative diesel fuel to be regulated based on the above principles. Currently, blends of up to 5% biodiesel (B5) are allowed in California. The proposed concepts—applicable to higher blend levels such as B20 and to neat B100 fuels—focus on mitigation of the increased NOx emissions (compared to CARB diesel) resulting from the use of biodiesel fuels. The proposal requires emission neutrality of all motor vehicle biodiesel blends above B5, including B100.

Source: California ARB