Hello Tom Leue

>A good summary of the situation, but the conclusions are at variance with the
>"prevailing wisdom" up to this point.

Prevailing wisdom indeed.

>I had understood from Keith Addison and
>others that they would accept biodiesel as a non-baseline fuel. Apparently we
>were wrong.

No, THEY were wrong. As Biofuels-biz members investigated the issues, 
the EPA people changed their tune, moving from one side to the 
opposite side, until it accorded with their own regulations, which 
previously it hadn't done. Sopata and Caldwell made statements and 
gave undertakings. For instance:

>I have spoken with Joe Sopata at EPA and he tells me that producers who sell
>less than $10,000,000 annually are exempt from Tier I and Tier II as long as
>thier fuel meets ASTM.  So far, in my discussions with DOE, EPA, ATF, and

>I spoke today with three people regarding exemptions for small 
>manufacturers from Tier I & II.
>
>Joe Sopata again stated that fuels meeting all ASTM standards for 
>biodiesel are eligible for the exemptions.
>
>Jim Caldwell at EPA stated the same. Also that the test for being a 
>non-baseline fuel is meeting the standards. Not meeting the 
>standards puts fuel in the atypical category and comes with 
>requirements for Tier I...

I kept saying it needed a test case to nail it down, various people 
said they'd be doing that, nobody did, and now it's unravelled as the 
EPA has yet again changed its tune. The opportunity was there, now 
it's lost. Too bad.

Keith Addison
Journey to Forever




>I offer the communication of May, 2002 from Dr. Tyson of the
>NREL, below on this topic that tries another approach:
>
>Dear Tom:
>
>I spoke with Joe Sopata at EPA again today and we dug down into this issue
>some more.   I have a correction or two and some more information.

<snip>


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