Bill,

While you have hit upon what might appear to be a reasonable
loophole in the matter, there remain several points of
contention.

For a moment consider that I might be a very bitter commercial
biodiesel manufacturer, extremely angry at the manner in which
the NBB/soy councils are attempting to get their checkoff dollars
back after they've already spent them once. Surely you don't
believe that someone such as this would let a manufacturing
scenario such as you present go unchallenged, simply because the
state or municipality is road tax exempt?

Consider the EPA's definition of "in commerce" as being on-road
use. Not brief use of agriculturally exempt dyed fuel, such as
hauling a tractor to a harvest site, but non-dyed commercial
grade fuel. It's the exact same fuel whether it's taxed or not
and whether it's in a state DOT truck, a privately owned tractor
trailer or a Volkswagen Golf.

Also consider for a moment from where these tax exempt entities
have been previously accessing their fuel - outside vendors.
There are arenas full of ordinances and statutes governing the
acquisition of supplies and competing with commercial interests.

Now try and explain to the miffed commercial biodiesel producer
why the state or municipality should be exempt from the same
Health Affects data requirements that he or she must adhere
to....Same roads. Same air. Same quality of emissions. Which
brings a soul directly to the off-road exemption, which will at
some point cease to exist due to the very same arguement.

Too many lawyers, too many bureaucrats and too many people
serving self-interests inevitably screw up anything worthwhile.

Todd Swearingen

----- Original Message -----
From: William Clark <[EMAIL PROTECTED]>
To: <biofuel@yahoogroups.com>
Sent: Monday, June 10, 2002 11:45 PM
Subject: Re: [biofuel] First stage foolproof method


> Todd- Early on in my ivestigation of biodiesel (relative to the
total time I
> have spent) I checked with the municipality here and found that
they are
> exempt from state and federal fuel taxes. Same for schools. My
question here
> is if a municipality would be required to register thier fuel
if they
> produce it themselves and use it to operate their own
equipment? I make the
> assumption that apart from the chemical inputs, there will be
no hazardous
> by-products. If chemicals which may be obtained on the open
market are
> properly handled, what other concern does the EPA have in this
matter?
>
> Bill C.
> ----- Original Message -----
> From: "Appal Energy" <[EMAIL PROTECTED]>
> To: <biofuel@yahoogroups.com>
> Sent: Monday, June 10, 2002 10:04 PM
> Subject: Re: [biofuel] First stage foolproof method
>
>
> > Bill,
> >
> > There is nothing to stop anyone from producing their own fuel
for
> > their own off-road use, save for local ordinances that may
apply.
> > And there may not be anything stopping anyone from producing
> > their own fuel for their own personal on road use, save for
the
> > IRS and state taxation departments relative to collection of
road
> > taxes and the EPA relative to registration of the fuel -
> > presuming they made the effort to be intentional pains in the
> > arse on the matter.
> >
> > But the moment a commercial manufacturer produces the first
drop
> > for use in commerce (road legal fuel), they have to buy
access to
> > Health Affects data, either by paying NBB fees, conducting
their
> > own studies or partnering with an entity that already has
legal
> > access to the data.
> >
> > That's pretty much the end of the story at the moment. And
pretty
> > much what scotches it for many people who would ordinarily
move
> > into higher volumes of manufacture within their own
communities.
> >
> > Todd Swearingen
> >
> > ----- Original Message -----
> > From: William Clark <[EMAIL PROTECTED]>
> > To: <biofuel@yahoogroups.com>
> > Sent: Monday, June 10, 2002 10:50 PM
> > Subject: Re: [biofuel] First stage foolproof method
> >
> >
> > > Todd- I don't know exactly what EPA and soybean councils
have
> > put on paper.
> > > I would be interested in seeing what legislation or rules
> > apply. Would
> > > appreciate directions to access that info (if available).
One
> > loophole I
> > > hope to exploit may be that I am proposing that entities
refine
> > their own
> > > fuel, not produce commercially.
> > >
> > > Bill C.
> > >
> > > .----- Original Message -----
> > > From: "Appal Energy" <[EMAIL PROTECTED]>
> > > To: <biofuel@yahoogroups.com>
> > > Sent: Monday, June 10, 2002 9:24 PM
> > > Subject: Re: [biofuel] First stage foolproof method
> > >
> > >
> > > > That's rather a hopeful thought...that an Audobon/NBB
board
> > > > member could persuade the EPA and the soybean councils to
> > make a
> > > > loophole in the matrimonial papers they formulated in
order
> > to
> > > > accomodate micro-regional manufacture.
> > > >
> > > > Don't get me wrong. It would be wonderful if they would.
But
> > that
> > > > certainly hasn't been the stance of either up to this
point.
> > And
> > > > it's rather difficult to imagine that they could even if
they
> > > > wanted to, as the general rule in this country is "equal
> > > > protection under the law."
> > > >
> > > > Which also means equal enforcement, prosecution and
> > > > persecution.... meaning that the rules are to be applied
> > equally
> > > > to everyone and that exceptions are perceived as the
> > proverbial
> > > > pox - no matter how beneficial they prove.
> > > >
> > > > One can always hope. But if I were you, I would be
> > formulating a
> > > > backup plan well before I put all my eggs in that basket.
> > > >
> > > > Todd Swearingen
> > > >
> > > > ----- Original Message -----
> > > > From: William Clark <[EMAIL PROTECTED]>
> > > > To: <biofuel@yahoogroups.com>
> > > > Sent: Monday, June 10, 2002 9:09 PM
> > > > Subject: Re: [biofuel] First stage foolproof method
> > > >
> > > >
> > > > > Ken & others- First I would like to thank all of you
for
> > your
> > > > help & your
> > > > > prompt replies. I thought it might be useful for me to
> > describe
> > > > what I have
> > > > > in mind.
> > > > >
> > > > > One of the missions we would like to undertake is to
> > > > demonstrate the
> > > > > effectiveness of biodiesel as a fuel to the local
community
> > and
> > > > government.
> > > > > The quality of my fuel is important. While energy
> > (electricity)
> > > > is cheap
> > > > > here, cost is very important, hence my desire to use
solar
> > as a
> > > > heat source
> > > > > when practical. I believe that WVO can be preheated in
a
> > pcv
> > > > pipe grid using
> > > > > the sun. When painted black it is less suseptible to
UV.
> > Not
> > > > along term
> > > > > solution but will do for now.
> > > > >
> > > > > After we are comfortable with our process, we intend to
> > > > convince the City of
> > > > > Eufaula to have the Recycling  Dept. collect all WVO
> > produced
> > > > locally (not
> > > > > currently doing this) and produce their own clean fuel.
I
> > know
> > > > other cities
> > > > > in USA are producing biodiesel but none as small as us
> > > > (15,000). Most
> > > > > biodiesel info I have seen is geared either to large
> > capacity
> > > > production or
> > > > > individual and farm production. Once we have coverted
our
> > own
> > > > city, we will
> > > > > try to convince other small communties in Alabama and
> > > > eventually the South
> > > > > East to do the same.
> > > > >
> > > > > Somebody recently made referrence to the EPA and their
> > > > discouragement of
> > > > > small biodiesel prodution in an e-mail on this list. I
am
> > > > unfamiliar with
> > > > > this but don't doubt it.  Ron Dodson (neat guy and a
very
> > > > creative thinker)
> > > > > is the head of Audubon International. That is the group
we
> > are
> > > > doing this
> > > > > with. Ron also sits on the National Biodiesel Board. We
can
> > > > probably get
> > > > > some support for this idea through him.
> > > > >
> > > > > Bill C.
> > > > >
> > > > > ----- Original Message -----
> > > > > From: "Ken Provost" <[EMAIL PROTECTED]>
> > > > > To: <biofuel@yahoogroups.com>
> > > > > Sent: Monday, June 10, 2002 6:43 PM
> > > > > Subject: Re: [biofuel] First stage foolproof method
> > > > >
> > > > >
> > > > > > >Next question. What problems might I encounter using
> > > > > > >anhydrous ethanol as opposed to methanol as a
reactant
> > > > > > >in this process?
> > > > > >
> > > > > > I believe the first step involves mostly
esterification
> > but
> > > > also
> > > > > > some transesterification. I don't know how much
you're
> > > > > > relying on the glycerine to fall out of the reaction,
but
> > it
> > > > > > won't leave the solution as readily or as completely
when
> > > > > > ethanol is used. Also, you have to use more ethanol,
> > > > > > of course, since the molecular weight is greater than
for
> > > > > > methanol (ratio 46 to 32). If you want to continue
with
> > > > > > ethanol in the 2nd step, which is PURELY
> > transesterification,
> > > > > > the problem with the glycerine failing to separate
from
> > > > > > the biodiesel can become quite bothersome,
particularly
> > > > > > with any water in there, or free fatty acids above
1%.
> > > > > >
> > > > > >
> > > > > > Biofuel at Journey to Forever:
> > > > > > http://journeytoforever.org/biofuel.html
> > > > > >
> > > > > > Biofuels list archives:
> > > > > > http://archive.nnytech.net/
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