Been talking about this offlist with Jon Van Gerpen of Iowa State
University. I sent him my "Conversation with the EPA Tome". Here's
some  more info. I actually had brought up with Jim Caldwell "the
lowest possible biodiesel viscosity issue" as compared with the lower
temps of diesel's viscosity- but didn't get far with it.

 
 In fact the more I think about it, the more bothered I am about the
problem of 'biodiesel doesn't meet diesel specs'. Of course it
doesn't, but it works fine just the same, and the faster this
comparison stops being made, the faster we stop having problems such
as the California CDFA issue (please search the archives here), where
oil company representatives successfully lobbied to have B100 'must
meet petrodiesel specs' in California- effectively outlawing it since
it can't- though how much that's enforced we haven't seen yet.



Quote from Jon Van Gerpen:

Mark:

Jim Caldwell is the person at EPA that I contacted through email.  It 
sounds like you got more from him than I could.  

This is the first time that I have heard that their concern was 
viscosity.  In the past, I have heard that they were concerned about
the distillation points. 
 
<snip>

There is some slight justification for being concerned about viscosity.  
The fuel injection system on a diesel engine will inject more fuel if 
the fuel has a higher viscosity (due to less internal leakage in the 
pump).  We have measured this effect when comparing diesel fuel and 
biodiesel.  However, since biodiesel has a lower energy content, the
effect 
is such that the engine still produces less power and operates at a 
lower overall fuel-to-air ratio with biodiesel than with diesel fuel.
 You 
might be familiar with this issue in the context of maximum engine 
power.  Since biodiesel has about 8% less energy per unit of volume, we 
would expect about 8% less maximum power from the engine.  However, 
reported results are usually in the 6-8% range.  This slight
discrepancy is 
due to viscosity.

The viscosity of soybean-based biodiesel varies from 4-12 cSt over the 
temperature range from  40 deg C to 0 deg C.  Since the biodiesel 
solidifies at about 0 deg C, the value of 12 is the lowest viscosity we 
would expect to see for this feedstock.  Grease-based biodiesels can be 
higher but I don't have any low temperature viscosity data for them. 
They 
also will not go to as low of a temperature before gelling.  Regular 
diesel fuel will have a viscosity of 12 cSt at about -13 deg C.  Since 
this is within the normal operating range for the engine, I see no reason 
to expect deleterious effects from the higher viscosity of biodiesel.






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