At first, I sympathized with YBD's plight, a sort of common reaction of
sympathy for the "little guy". But on further reflection, I have to agree
with Dana's assessment.
It is clear that in highly industrialized countries, regulations exist for
everything, and these are often the result of legitimate efforts of trade
associations who wish to ensure the long term viability of their industry,
not just a matter of simple greed or efforts to monoplize an industry.
They seek a level playing field between competitors and protection of their
customers against fly-by-night operators producing inferior products at
lower cost.
Setting standards and promoting membership to the more or less
self-regulating trade organization is the rule. It gives regulators the
confidence to not over-regulate, and it gives consumers confidence in the
product. If members cheat and put out a bad product, they can be turfed and
the consumer and government regulators informed of non-compliance,
detrimental cost-cutting, etc.
Example - I used to be on a member of couple of farm building associations.
These were not onerous to join, they protected the interests of any member
builder in good standing, anyone was welcome to join and benefit from
membership and the standards that were developed. These included technical
and business/customer service and satisfaction standards, mediation,
technical sessions, lobbying to regualtors on various issues, etc. This is
what the NBB should be, and if it is not taking care of the potential for
inclusion of small producers, then THAT is the root of the problem here.
Small producers can do a good job, and the NBB should know that and be
helpful and economical for small producers. To exclude the small producer is
contrary to the ideas of sustainability, and biofuels production has a great
deal to do with sustainability - or at least it should have.
Personally, I've found the NBB to be helpful. They are interested in the
long term viability of the industry. When I contacted them for brochures and
videotapes on biodiesel, they sent very good materials, even though I told
them we were very small producers, were not members, and in fact were not
even in their country. Their reports database is a good resource, and anyone
can access it for free.
If they've gotten out of line and forgotten the potential of a larger number
of local and regioanl producers, tell them so. Maybe they'll listen to a
good argument as to why inclusion of the small producer would be a good
thing. (If we want to be cynical, at least the larger producers would end up
with a handy database of potential buyout targets and knowlegable
managers-for-hire (former owners) in a few years.)
The small biodiesel producer will have no choice, in these countries, but to
convincingly demonstrate that their product consistently tests in conformity
to the generally accepted standards. In the US, that is ASTM PS-121.
They will not be allowed to free ride on the test data and standards that
have been established for the industry.
Join the established association, implement a QC program, show your product
meets the standard on consistent basis, or just get out of it and do
buy-and-sell (eg. bulk break and do local supply of the product of major
maufacturers that are willing to play by the rules).
Making backyard biodiesel for one's own use is fine, IMO. I don't think that
any great harm will come of it and I imagine a lot of people will be doing
it for a long time. If they make junk, their engine will suffer more than
the environment. Even if (and I am not condoning this!!) they dump glycerine
in the landfill in a garbage bag or spray wash water on their back yards or
fields, or pour it down the drain, realistically, those would be very low on
the list of polluting activities in our world.
However, selling that biodiesel is another story.
Economy of scale will drive small producers out of the game before long
anyway, I think, and the EPA won't have too much enforcing to do.
Small scale commercial biodiesel production, without QC testing, meeting a
standard, and joining an association, etc. will be quite possible and maybe
even desirable in many less regulated countries of the world (where
availability and cost concerns override other concerns, perhaps), but in
most highly industrialized countries it is a no-win game to think such
compliance can be avoided, and the NBB and EPA are both acting within their
mandate and the the bounds of reason on this issue.
YBD should have seen it coming, and if they did not, now is the time to take
the warning to heart and comply, or get out of the production end of
things, at least for now.
Lobbying for low cost test procedures, membership fees to NBB based on
annual sales or capacity - other "small producer"things like that would
make sense, don't you think? Keep small producers in the fold, help them to
grow and be trusted suppliers in their local areas, and let consumers decide
if they want to buy local (even if the cost is a little higher for the small
producer who is in compliance, compared to that offered by Mr. Big Guy
Biodiesel Ltd., 1000 miles away? Sell on service and known quality, and
local origin, not just on price?)
In the meantime, suspend production. Buying from the majors would keep
one's hand in and the doors open until those efforts at making a place for
small producers within the NBB hopefully pay off.
Edward Beggs
www.biofuels.ca
> From: Dana Linscott <[EMAIL PROTECTED]>
> Reply-To: biofuel@yahoogroups.com
> Date: Fri, 15 Feb 2002 09:32:31 -0800 (PST)
> To: biofuel@yahoogroups.com
> Subject: Re: [biofuel] Re: EPA?/consider the alternative
>
>
> --- Keith Addison <[EMAIL PROTECTED]> wrote:
>> Reference? You keep talking about the scourge of
>> sloppily made
>> biodiesel and the damage it does, you imply you know
>> of blown-up
>> engines which people keep quiet about, and now you
>> claim that the
>> emissions are worse than dino-diesel's. I think
>> either provide some
>> supporting evidence for these claims or stop making
>> them.
>
> If you are telling me to shut up because you don't
> agree with my point of veiw I am very surprised since
> you nearly always encourage a free discussion of any
> biofuel related subject on this list. This particular
> subject is a timely and important one and even though
> I knew my point of veiw would be unpopular I chose to
> share it because I felt many might benefit.
>
> Normally you would encourage this...but it seems now
> you are, at least temporarily, the most fanatical of
> posters regarding this subject. I included the
> previous("unregulated biodiesel is a danger")link
> because it had value in its simple point...not because
> it was definative. If standards are not set and
> enforced for commercial biodiesel producers(including
> small ones) it won't take long for the "fast buck"
> operators to ruin the opportunity that is beginning to
> develop. Although the initial small scale producers
> may be ethical and upright many that follow are likely
> to not be if turning out an inferior product produces
> a higher profit. Any commercial operation that
> produces and sells(even unitentionally) an inferior
> biodiesel product will prejudice the public against
> biodiesel in general and especially biodiesel from
> small scale producers. Without regulations (and
> enforcment)which preclude this it won't take long to
> happen. Even one or two inadvertant bad batches from a
> small producer would give the large producers a an
> example I am sure they would be quick to exploit to
> thier advantage. Any small scale commercial producer
> that does not want to submit his product to continuous
> rigorous independent quality testing is dangerously
> close to providing this "example".
>
> Similarly any producer that is unwilling to submit his
> product to rigorous independent testing that confirms
> their products' low pollutant emmission qualitys is
> dangerously close to providing the petroleum giants
> with an example of how "alternative fuels" like
> biodiesel should be regulated even more heavily than
> they currently are.
>
> One more perspective to look at it from is from that
> of consumer protection. Even if I were a virtual
> Wizard at transesterifcation and felt very self
> assured that I would never turn out a bad batch
> because I had a great process and a "fool proof"
> method that made mistakes virtually impossible I would
> still feel that out of respect for my customers(and to
> limit liability)I would have to implement a quality
> assurance testing program from day one of operation.
> To not do so would not only be economically unwise and
> extremely arrogant it would nearly assure that some
> customers at some time in the future would receive
> inferior fuel and suffer the consequences ...even if
> they did not immediatly notice it. Rigorous,ongoing,
> independent testing of ones product is a part of any
> ethical business plan.
>
>> Facts and
>> figures concerning the prevalence of and damage
>> caused by sloppily
>> made biodiesel please. Er, not the iffy German
>> commercial stuff,
>> backyarder and unregulated small operator
>> perpetrators would be
>> better.
>
> Keith,
> If you will carfully read my response I made no claim
> that well made biodiesel "emissions are worse than
> dino-diesels'". I was responding to the comment which
> stated that the most sloppily made biodiesel is better
> than the best petrodiesel. I don't believe there is
> currently a "scourge" of badly made commercial
> biodiesel. Nor do I think that much "home brew" is
> sloppily made and then run through engines. People
> tend to be pretty careful about what they put in their
> own vehicles since they have to bear the burden of not
> doing so. It does happen occasionally and that is all
> it takes to give biodiesel a bad reputation if allowed
> to happen in a commercial operation. Surely you are
> not implying that badly made biodiesel will not harm
> an engine or pollute the air or that it is impossible
> to make a bad batch of biodiesel.
>
> The current method of methoxide based
> transesterification can produce a highly variable
> product depending on the skill and experience of the
> producer as is evidenced by many of the archived
> discussions on this list. I have no evidence nor do I
> believe that YellowBiodiesel is anything but the
> finest quality biodiesel available commercially. I do
> not believe think its' producer is a "cowboy" (I'm
> sure you did not mean to 'dis real cowboys) but I do
> not agree that small COMMERCIAL biodiesel producers
> should be exempt from pollution control laws. I don't
> believe that ANY commercial venture should be exempt
> from pollution control regulations since to do so
> would provide an incentive to create pollution to any
> individual that is primarily concerned with profit.
>>
>> <snip>
>>
>>> You may have good intentions but look at some of
>> the
>>> statements you have made...and how fanatical they
>> must
>>> seem to the average reader. I don't think that this
>>> battle is lost yet but it seems from the feedback
>> by
>>> the time most realize they have been suckered into
>>> "tilting at windmills" the strategic battle will
>> have
>>> been lost because everyone was busy somewhere else.
>>
>> I'll agree that this particular branch of the
>> discussion has become a
>> distraction into tilting at windmills. But I'd say
>> the focus
>> nonetheless remains on the problem itself and
>> dealing with it rather
>> than on whether or not to blame the victim.
>
> So far I have seen no evidence that the "problem" is
> harrassment by the EPA and have seen evidence that the
> "problem" is primarily based on the producers
> unwillingness to thoroughly test his product insisting
> rather that the EPA accept that it is identical to the
> biodiesel that was tested by the NBB based solely on
> his "word of honor". While he may be a totally honest
> and upright person the EPA is simply not allowed to do
> that by thier mandate. They must have data generated
> from the actual product being manufactured in order to
> permit the product to be sold.
>
> As I stated before it appears to me that this "victim"
> is much more a victim of his own failure to adequately
> research his business venture prior to committing
> himself financially than he is of the EPA. If he had
> done so he would not have been surprised by the action
> of the EPA and would have been prepared to comply with
> the regulations he would be subject to. I am not
> "blaming" him I am simply pointing out to others that
> while the commercial production of biodiesel might at
> first glance look like a simple and profitable
> business there are lots of costs that are not
> immediatly obvious that currently make small
> commercial ventures of this sort marginal at best.
> When you compete with megabusiness' like the oil
> giants and corporate farm cooperatives you have to
> expect this type of action or you are being
> unrealistic. Similarly if you think that you can
> quickly change the regulations that will likely be
> applied to your venture when these huge corporations
> have essentially purchased the cooperation of our
> "representatives" and national leaders you are being
> naive.
>
> I have in the past shared a few of the pitfalls I ran
> into when I researched the possibility of setting up a
> small biodiesel plant and got the impression from most
> of the feedback that no one wanted to hear anything
> which might be percieved or interpreted as negative
> about biodiesel...so I stopped sharing that
> information. Why should I accept being abused for
> trying to help? I had a feeling that I would receive
> the same reception if I presented my opinion on this
> subject and "its' deja vu all over again" as I feared.
> I am very surprised however that you are doing it
> Keith as it seems very contrary to your nature.
>
> I think you are reacting to your immediate perception
> of what I am attemting to communicate rather than
> digesting the information in context. I am not
> attempting to slander biodiesel in general or this
> producer in particular. Nor am I attempting to
> "defend" the EPA. I am presenting my opinion of the
> stiuation based on the available information and my
> past experience in the hope that a clear and balanced
> assessment of the situation at hand might be of use to
> others. Without multiple POVs (points of veiw) no
> accurrate assessment of the situation is possible and
> therefore no effective solution can possibley be
> arrived at. If everyone agrees that the EPA is the
> problem and it is not(for the sake of argument)any
> obvious solution employed to solve the erroneously
> perceived problem will be innefective at solving the
> real problem at best and disasterous for the industry
> at worst.
> If you don't wish to have any alternative POVs'
> presented you have the power as moderator to ban my
> POV from this list. If you simply disagree with my POV
> please read my posts more carefully before replying to
> statements I have not in fact posted so that the
> resulting dialog will be a productive one.
>
> I realize that my demeanor might appear abrasive and
> unforgiving of the producer in question. This is
> mainly due to my strong belief in accepting personal
> responsability for ones own situation and in this case
> I believe that the main problem stems from the
> producers failure to do so. All possible solutions to
> his immediate problem involve accepting that no one is
> more responsable for creating the problem he now faces
> and stop pointing at those less reponsable for
> creating it. If you cannot pinpoint what the actual
> problem is or where the problem originated you have
> little hope of finding any solution to it let alone
> the simplest, most easily implemented, and least
> expensive solution.
>>
>>> I wish I were a YBD customer. I would probably be
>>> working to help get it back on track instead of
>> trying
>>> to alienate potential allys. In spite of the fact
>> that
>>> I have nothing to gain personally I am the only
>> poster
>>> that has offered to help
>>
>> You think so? You're sure of that?
>
> If you mean that I have nothing to gain personally,
> yes. I am absolutely certain of it.
>
> If you mean that no one else has offered to help, no.
> I may have missed posts where others offered to do
> so.
>
> If you mean do I wish I were a YBD customer as I would
> probably be working to help get it back on track, I am
> as sure of that as I am of my own name. I routinely
> offer my services free of charge (to those that cannot
> afford them otherwise) and have done so in this case
> even though I have no possible personal gain as a
> result. My own plans in regard to bidiesel in fact
> take into account the possability that some small
> producer will unintentionally cause future small
> commercial biodiesel producers to be burdened with
> even more regulation than they are currently. It would
> of course be better for everone if this does not occur
> so soon in the "game" but it is bound to happen
> eventually.
>
> You may note that I offered to help the producer in
> question if he would only contact me off list in one
> of my early posts on this subject. So far he has not
> done so. I am fairly certain that if he did so I would
> be able offer effective and low cost solutions to his
> immediate problem relatively quickly since this
> situation was one of the scenarios I prepared for when
> researching the possibility of setting up a small
> commercial plant of my own. Several viable solutions
> exist but the plan he is currently implementing is not
> one of them. In fact I believe that his current plan
> of "attack" will make it much more difficult for
> others to set up successful small scale biodiesel
> production plants in the near future.
>
> If I were in his situation I would be exploring any
> offer of help at this point...even from someone that
> does not believe that he is a victim of the EPA and
> would require him to take personal primary
> responsability for the situation he is currently
> experienceing.
>
> My offer still stands.
>
> Dana Linscott
> <snip>
>
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