Comments on Implementation of Title IX, Energy Authorities of the Food, Conservation, and Energy Act of 2008
First and foremost I urge whichever Administration takes office in January to honor the intent of Title IX legislation, to assure that the mandatory funding levels defined in Title IX are not held up in Congress, and any additional funds that require appropriation (Section 9012) are quickly provided. The overall goal of Title IX should be to develop an American Advanced Biofuels industry that is sustainable both environmentally and economically. This is, I believe, the intent of the legislation. To that end, biorefinery and biomass crop assistance programs should both be focused exclusively on only advanced biofuel projects and should not be used to support earlier generations of biofuel production. Furthermore, project selection criteria should focus on sustainability over immediate availability of technology. USDA should realize that most, if not all, sustainable advanced biofuel technologies are not commercially available today (2008). There are many very good, innovative technologies, conversion systems, and crops, at the lab level. Properly implemented Title IX programs, especially in these times of virtually non-existent early-stage credit, would go a long way to getting these technologies to market and would provide the start to an American Advanced Biofuels industry that could provide both long-term energy security and long-term rural economic growth. Section 9003 Biorefinery Assistance With the limited funds available, this program should only be used for Advanced or 3rd generation biofuels which is the legislative intent of this section By way of definition: 1st generation biofuels are corn-to-ethanol and soybean biodiesel. Both of these are in wide-spread commercial production. 2nd generation biofuel is cellulosic ethanol. DOE has provided funding for a number of commercial-scale demonstration plants. In addition, General Motors has provided funding for two cellulosic ethanol companies, Coskata and Mascoma. 3rd generation (or True Advanced Biofuel) technologies include: advanced hemicelluloses/lignin conversion processes, either to intermediates (sugar cocktails) or final fuels, and aqueous reforming “green gasoline” processes. 3rd generation biofuels include; bio-jetfuels, advanced biosynthetic diesel fuels, biogasoline, and fuel cell liquid electron carriers. Selection Criteria Criteria used to select candidate projects should be focused on encouraging innovation within the limited funding provided. They should include the following. Questions in Farm Bill Wording of Section 2003 What is a Demonstration-Scale project? Where does that fit in the engineering continuum of Pilot/Prototype/Commercial? What is a Large Scale market? In transportation fuels, all markets tend to be large. Section 9005 Bioenergy Program for Advanced Biofuels Selection Criteria Section 9011 Biomass Crop Assistance Program In keeping with the overall goal of developing an environmentally as well as economically sustainable Advanced Biofuel industry, Section 9011 should provide funding for only sustainable energy or dual use crops. Therefore, before this program is initiated, USDA/ARS should conduct a study of available and near-term future crops to determine eligibility. While this may slightly delay the implementation of this section, it is crucially important that high nutrient input or ecologically unfit crops are not included for funding. This study could be done under the language in this section that outlines selection criteria. Specific crop criteria to be developed should include: Developing these criteria within the ARS system would solve the chicken-and egg issue between crops and biorefineries that is created by some of the language in this section such as letters of commitment, etc. More important, such a study would produce objective, science-based criteria for crop-selection which would help assure the long-term health of rural biofuel economies. Section 9012 Forest Biomass for Energy Selection Criteria Many of the selection criteria recommended for Section 9003 apply for Section 9012 as well. These include: In addition, program emphasis should be given to reactivating mothballed pulp-and-paper plants. In every region of the country, there are pulp-and paper plants closed because of the move to importing most of our paper from China and other countries. These plants present a significant opportunity for creating a forest based advanced biofuels industry at relatively low cost. Not only are they located near underutilized forest resources, they already have the infrastructure needed to build a biofuels biorefinery and in most cases these plants have been updated to meet EPA air and water regulations. Furthermore, they are located in rural communities needing economic revitalization because of their closure. Focusing Section 9012 prototype projects in these facilities could not only develop a forest based advanced biofuels industry very quickly and at lower than expected costs, but it would also provide a way to provide long-term economic growth for many rural communities that are now suffering through high unemployment and the outward migration of much of their younger people.
by Robert Kozak, President, Atlantic Biomass Conversions, Inc.; Board Member, Advanced Biofuels USA
Title IX Implementation: Overall Goals
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