Great letter, should use a spell checker though. Thanks Chuck
----- Original Message -----
From: girl Mark
To: [EMAIL PROTECTED]
Sent: Monday, October 13, 2003 9:24 PM
Subject: [biofuel] Mark's letter to the CDFA
The CDFA/DMS public comment period deadline (about the
biodiesel-negative warning labeling)is tomorrow,
though they will read anything they get by mail till
the 20th (send in letters...)
Here's my longwinded rebuttal to some of their
concerns about biodiesel standards.
Mark
Dear sirs,
My name is Maria Alovert and I am a biodiesel user and
an auto mechanic. I spend a lot of my time
volunteering in programs which educate consumers of
B100 about the differences between petroleum diesel
and biodiesel, and as a mechanic, have advised
consumers on proper use of B100 and associated issues.
I have in the past spent some time lobbying NAFT Gas
in Fairfax to carry B100, and agree with the CDFA/DMS
that good labeling will avert unexpected problems for
consumers.
However, I do not believe that the labeling as
currently proposed will meet this need without causing
the biodiesel industry and retailers serious damage in
the rate of public acceptance. I believe that this is
the opposite of what the CDFA proposals intend. I urge
that these proposals be put to a new round of public
input and study.
I have studied the ASTM standards for petroleum diesel
and for B100 extensively, and am concerned that
requiring the D-975 standard for biodiesel blends is
an unnecessary requirement that is impossible to meet.
I believe this will have the effect of discouraging
biodiesel use and more particularly of discouraging
biodiesel retailing, which will set a large barrier to
public acceptance.
It has been brought to my attention that some of
these changes came about as a result of commentary by
Chevron Products Company. I have copied parts of their
testimony below and wish to offer a rebuttal to some
of their concerns:
Quote:
CHEVRON PRODUCTS COMPANY'S COMMENTS ON DFA'S PROPOSED
AMENDED REGULATIONS CONTAINED IN TITLE 4, DIVISION 9,
ARTICLE 5
Chevron Products Company (Chevron) is in agreement
with the changes proposed for Sections 4140, 4145 and
4146. Our remaining comments are confined to the
sections dealing with "biodiesel fuel".
Section 4147 (a): This statement suggests that
biodiesel as a 100% pure fuel is okay if it meets ASTM
D 6751. The title of ASTM D 6751 has the words "Blend
Stock". This specification is intended to give the
requirements for biodiesel as a blend component in a
final blend meeting ASTM D 975. The specification does
not give ASTM approval for the 100% biodiesel as a
diesel fuel (nor does it disapprove). Pure biodiesel
does not meet ASTM D 975, which is the requirement for
diesel fuels in ASTM. So this statement appears to be
inconsistent with ASTM's intent and with Section 4147
(b).
End quote
The ASTM D-6751 specification never states at which
percentage blend, a blend of biodiesel and petroleum
diesel becomes problematic due to not meeting D-975.
By inference, it would seem that a blend of 99%
biodiesel and 1% petroleum diesel meets the intent of
ASTM in offering a specification for B100 as
blendstock, or ASTM would have indicated at which
blend level the specification no longer applies.
Additionaly, the ASTM D-6751 is similar to the
European specifications, and there has been longterm
B100 use in some countries in the EU which has not led
to the problems that Chevron may be concerned about.
It is also the interpretation of the EPA and of the
biodiesel industry, as well as some vehicle
manufacturers, that ASTM D-6751 biodiesel fuel is a
satisfactory on-road motor fuel up to B100.
The ASTM standards are decided in a lengthy process of
study which takes many years to complete. I trust that
the ASTM committee did not find anything objectionable
in high-level blends up to B100, or else this
information would have been included in the carefully
written ASTM D-6751 standard.
I am concerned that the CDFA may in effect overturn
the decisions of the ASTM standards committee by
requiring that biodiesel blends meet ASTM D-975, with
only minimum public comment period lasting a few
weeks. I am deeply concerned that this may affect
biodiesel acceptance and affect the biodiesel industry
in California, and I am further concerned that these
state standards may be adopted by other states which
follow California's regulations.
It is physically impossible for biodiesel to meet
D-975 because D-975 describes a chemically different
fuel than biodiesel does. If astm D-7651 B100 is
satisfactory as a blendstock, and petroleum diesel
fuel ASTM D-975 is satisfactory as a blendstock, I am
concerned that one specification should be made to
override the other in our state requirements without
sufficient study to warrant this.
There are in fact many advantages to fuels which meet
D-6751, over those of D-975: cetane is always higher
in B100, and flash point is lower, which translates to
safer handling of biodiesel than of more flammable
petroleum diesel. Biodiesel rarely fails the copper
strip corrosion test, which cant be said for D-975. In
addition, lubricity, which is not specified in either
standard, is far higher for biodiesel than for
petroleum diesel, as tested by SLBOCLE (ASTMN D
6078-99) and the HFRR (ASTM D-6079099) tests.
Lubricity is proven to be a cause of fuel system
failure, and biodiesel blends are specifically
utilised to improve a petroleum diesel's petformance
on the above tests.
One concern which is expressed by the Chevron
commentary is referenced below, concerning viscosity:
Quote:
Section 4148: Chevron does not believe that such
labeling sufficiently protects the general public.
B100 is not in our opinion a "fill and go" substitute
for petroleum diesel fuel. First of all it does not
meet ASTM D 975. One aspect of that is that it has
higher viscosity, which can affect injector operation
and cause fouling and that can adversely affect power
and mileage.
End quote
This is not, in practice, a major concern. The D-975
standard specifies viscosity of petroleum diesel fuel
at a certain temperature. So does the kinematic
viscosity test ASTM 445 for biodiesel. The two
viscosities do not differ greatly enough to affect
performance or fuel system at these temperatures.
I presume that the concern above is with what happens
to biodiesel in fuel systems at the lower temperatures
at which it is still operable (liquid).
The reality is that engine manufacturers do NOT
produce fuel systems to handle only fuels at these
temperatures, or produce fuel systems that only work
in summertime operation. It has been shown that
petroleum diesel, even that meeting D-975 standards,
has a greatly reduced viscosity at lower temperatures,
just as biodiesel does. However biodiesel stops being
usable at a higher temperature than petroleum diesel,
while it is well within the acceptable viscosity range
at which petroleum fuels are considered acceptable in
winter use.
The effect this has on the above concern is as
follows:
The viscosity of petroleum diesel at it's lower end of
operating range (ie 20F for instance) is very similar
to that of biodiesel at the lower end of operating
range (closer to 32F). Viscosity at biodiesel's higher
operating temperatures falls well within the
acceptable range of petroleum fuels. Long experience
has shown that diesel fuel systems do not fail due to
the poor viscosity of petroleum diesel in winter. The
same logic can be applied to the viscosity of
biodiesel at it's lower operating temperatures.
Another concern from Chevron's commentary is quoted
below:
Quote:
B100 is not in our opinion a "fill and go" substitute
for petroleum diesel fuel. First of all it does not
meet ASTM D 975. One aspect of that is that it has
higher viscosity, which can affect injector operation
and cause fouling and that can adversely affect power
and mileage.
End Quote
Rebuttal:
I do not believe that lower mileage and power has been
effectively demonstrated as a result of viscosity,
otherwise it would be seen in petroleum diesel in
wintertime as well, which it is not. Biodiesel made to
ASTM D-6751 standards cleans injectors and fuel
systems, rather than fouls them. Biodiesel does have
slightly lowered fuel economy for different reasons,
yet consumers are usually made aware of this, it is
not due to biodiese not meeting D-975, and it is not
reason to call B100 'not a fill and go' fuel.
Quote, again:
Secondly, we feel it requires more careful handling.
For example, it tends to clean out diesel systems when
first used which can cause filter plugging; it is more
bioactive than petroleum diesel and thus more
susceptible to biogrowth and tends to have shorter
storage life. In our opinion, B100 should be
restricted to owners that are knowledgeable, capable
and prepared to deal with these issues. (Also,
comments to Section 4149 apply here.)
End quote
Rebuttal:
All of us who handle B100 and do B100 education, are
aware that consumers need to be educated on the
solvency and microbial attack. In reality, though,
solvency is one area in which consumers have been made
aware of the differences between B100 and petroleum
diesel. Proper, non-alarmist labeling will accomplish
this. 'Restricting' use of B100 is not the proper
approach, good labeling is. I believe that you have
recently received a lot of commentary from the general
public which offers alternatives to the "Caution:"
statement. Again, I urge the CDFA to put this matter
to a new round of public input before proceeding with
new labeling and requirements.
Quote:
Section 4149: Chevron does not believe that such
labeling sufficiently protects the general public if
the blend is over 5% biodiesel. While some have, many
OEM's have not endorsed biodiesel contents over 5%.
Use of diesel with higher than 5% biodiesel could
compromise the warranty with some engine
manufacturers. Biodiesel has a tendency to swell
materials that can be used in the seals and o-rings of
the fuel system in vehicles. It is our understanding
that the high pressure fuel pump- injector systems on
new diesel engines is a significant part of the cost
of the engine.
End quote
I do now know of any instances of fuel injector pump
failure as a result of B100 use or that of blends
lower than B100. Most commonly, fuel lines in older
vehicles sometimes leak. This is well known among
consumers and does not require the cautionary label,
only a more moderate wording. Chevron's argument that
biodiesel could cause a fuel pump replacement is not
backed up by fact or experience, either in the US with
ASTM D-6751 fuel or in Europe with it's more extensive
B100 experience. Once again, if this was the type of
information that the CDFA decision was based on, I
believe that we need a new round of public input and
workshops to determine labeling and regulations
satisfactory to all.
Respectfully, Maria Alovert
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