NACEPT
Shaping the Nation's Environmental Policy
National Advisory Council for Environmental Policy and Technology
July 13, 2007
Administrator Stephen L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Re: Strategic Framework for Biofuels Efforts
Dear Administrator Johnson:
The Environmental Protection Agency has requested that the National Advisory Council for
Environmental Policy and Technology "recommend a strategic framework around which EPA
might plan its work related to biofuels to ensure its contribution to expedient and
environmentally sustainable development of energy supplies." Because developments in the area
of biofuels are happening so quickly, NACEPT has chosen to make its recommendations in the
form of a series of advice letters to the Administrator.
In our first letter, of February 20, 2007, we recommended that EPA should (1) act promptly to
make the high-level appointment to the federal interagency Biomass R&D Board, (2) develop an
integrated, collaborative, multi-media biofuel strategy and create a position of Biofuels
Coordinator, (3) give this EPA biofuel initiative strong, highly visible support from the top, and
(4) use this initiative as a deliberate experiment and apply the lessons learned. We understand -
and are appreciative - that you have considered these recommendations and have begun
implementing much of them already.
In this second letter, NACEPT recommends the basis for a strategic framework for organizing
EPA and interagency biofuel efforts. NACEPT has kept close to its biofuels mandate. However,
the Council is mindful that the President's ambitious "20 in 10" initiative is not likely to be met
by biofuels alone, and that alternatives likely will be needed. The framework we are proposing
lends itself to easy adaptation for all sources of transportation fuels, thus affording a single
mechanism for comparisons of many different options.
The complexity of the biomass challenge and the combined dynamics of the existing agriculture,
forestry, energy, waste management and waste-to-energy, chemical, and transportation markets
pose many difficulties even for reaching consensus on how to parametize and model the many
different individual operations for making biofuels. These difficulties are compounded by the
fact that people in different agencies and different offices within agencies naturally tend to view
the biofuels challenge through the lens of their own particular organization charts. As a result,
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people restrict their vision of what needs to be done, talk past each other, engage in unnecessary
turf battles, and miss opportunities for cooperation.
To help overcome these difficulties, NACEPT recommends that a shared high-level systems
framework be adopted so that all the programs and media within EPA can envision, analyze, and
take steps to assume their proper role in the overall biofuels program and to communicate in a
productive way. In fact, given the myriad agencies involved in the national biofuels effort,
NACEPT strongly suggests that EPA present this systems perspective to the Biomass R&D
Board to facilitate interagency work and cooperation.
Fortunately, an appropriate high-level framework already exists: the operational concept of the
Biofuels Supply Chain. This supply chain includes five major elements: 1) Feedstock
Production, 2) Feedstock Logistics, 3) Biofuels Production, 4) Biofuels Distribution, and
5) Biofuels End Use. This is the way businesses and investors in the biofuels area structure their
thinking. This is also the perspective researchers adopt for doing biofuels life cycle assessments
(LCA) [1] and therefore has the added benefit of being consistent with well-established analytical
methods designed to identify all the flows to and from the environment associated with biofuel
production and use.
The biofuels supply chain is the highest-level descriptor of the overall system that needs to be
created. Using this as the lens for viewing the biofuels challenge can give everyone a common
organizing framework and help all parties see the "big picture" as opposed to the organizationally
constrained view. It will act to keep the focus and emphasis on what needs to be done to make
the system as a whole work. It will facilitate further systematic decomposition of the overall
system until there a level of definition achieved that can be used to define individual pieces of
work that can be planned and accomplished.
Figure 1: The Biofuels Supply Chain
r-
Feedstock
Production
— >•
Feedstock
Logistics
-*
Biofuels
Production
-»
Biofuels
Distribution
-»
Biofuels
End Use
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Brief functional descriptions of the five elements or subsystems of the biofuels supply chain are
provided in Table 1. To achieve the goal announced by the President on January 2007 of
replacing 20% of gasoline consumption by 2017, all five of these supply chain systems will have
to be developed to the requisite capacity. This 2017 goal and the capacities needed to meet it are
now a focus of the Biomass R&D Board.
Table 1: Major Systems within the Biofuels Supply Chain
Supply
Chain
Systems
Feedstock
Production
Feedstock
Logistics
Biofuels
Production
Biofuels
Distribution
Biofuels End
Use
Functional Descriptions
Sustainably produce supplies of regionally available herbaceous and woody biomass,
including agricultural and forest residues, energy crops and waste materials.
Implement biomass feedstock infrastructure, equipment, labor force, and systems to
carry out harvesting, collection, storage, pre-processing, and transportation
operations.
Deploy cost-effective biomass-to-biofuels conversion facilities that meet all safety
and environmental regulations to produce biofuels that meet quality standards.
Implement biofuels distribution infrastructure to carry out storage, blending,
transportation, and dispensing operations.
Deploy publicly available biofuels and biofuels-compatible vehicles with same
performance as vehicles operating on conventional petroleum-based fuels.
Because of the wide diversity of potential biomass feedstocks, conversion technologies, biofuels
products and co-products (See Table 2), and the postulated size of the biofuels industry,
feedstock resources and conversion technologies will be combined in a multitude of specific
biofuels supply chain configurations. Viable biofuels supply options will become clearer as
increasing levels of detail evolve about feedstocks (and competing uses for these, such as food,
feed and fiber), technologies and profitable co-products are developed and the industry evolves.
Using the biofuels supply chain as a strategic framework makes it possible to array these complex
options in an easily understandable way and accommodate the rapidly expanding knowledge
base.
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Table 2: Examples of the Feedstock and Technology Options
Feedstock Production
Agricultural Forest Residues
Crops -Logging
-Corn Residues
-Sorghum -Forest
-Barley Thinnings
-Oats -Fuel
-Wheat Treatments
-Soybeans -Hog Fuel
-Canola -Sawdust
-Rice -Paper Sludge
-Alfalfa -Black Liquor
-Other Crops
Wastes
Agricultural -Manure
Residues -Fats & Greases
-Corn Stover -MSW
-Wheat Straw -Urban Wood
-Barley Straw Waste
-Rice Straw -Food
-Cotton Lint Processing
Waste
Energy Crops
-Switchgrass
-Energy Cane
-Sweet Sorghum
-Hybrid Poplar
-Willow
-Other
Coppicing Trees
Feedstock
Logistics
Harvesting and
Collection
-Single-pass
-Multi-pass
-Baled
-Bulk
Storage
-Dry storage
-Wet storage
-Baled
-Bulk
-Landfills
(MSW)
-Floating storage
Preprocessing
-Shredding
-Pelletizing
-Briquetting
-Ensiling
-Drying
-Separation
Transportation
-Truck
-Rail
-Barge
-River/Stream
Floating
Biofuels & Co-
Product
Production
Fuel Types
-Ethanol
-Biobutanol
-Mixed Alcohols
-Biodiesel
-Green Diesel
-Renewable
Diesel
-FT Diesel
-FT Gasoline
-Dimethyl Ether
-Synthesis Gas
-Hydrogen
Biochemical
Conversion Ops.
-Acid Hydrolysis
-Pretreatment &
Enzymatic
Hydrolysis
-Fermentation
Thermochemical
Conversion Ops.
-Gasification
-Pyrolysis
-Hydrothermal
Depolymerization
-Fuel Synthesis
-Combustion
Anaerobic
Digestion
-Aqueous
-Dry
Biofuels
Distribution
Transportation
-Truck
-Rail
-Barge
-Pipeline
Storage
-Blending
Terminals
Dispensing
-Dedicated Pumps
-Blending Pumps
Biofuels
End Use
-Light Duty
Vehicles
-Light Duty
Trucks
-Heavy Duty
Trucks
-Off Road
Vehicles
-Locomotives
-Airplanes
-Jets
-Boats
-Ferries
-Ships
-Handheld
Power
Equipment
-Generators
-HVAC
Units,
-Etc.
The two tables below show how the biofuels supply chain can be used within EPA as a strategic
framework for thinking through what EPA is already doing in this area, what else needs to be
accomplished, and where within EPA work needs to be done. Table 3 is a framework for EPA
regulatory roles and Table 4 for environmental stewardship support roles. (NACEPTpoints out
that there is no implication that EPA has the legal authority or should be involved in every area.
However, each area should be considered to assure that a comprehensive approach is taken to
sustainable biofuel production.)
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NACEPT recommends that Tables 3 and 4 be used to structure a comprehensive survey within
EPA to determine current or projected future roles in biofuels within the regions, the research
organizations and headquarters. The survey should be filled out by heads of all offices within
the Agency or people designated by them.
Every person completing the survey should complete the whole form, not just the part of it
dealing with their own office. For every task respondents identify, they should specify whether
EPA has a sole leading role, a collaborative leading role, or an assisting role to others within the
federal family. Respondents should address all of EPA's basic areas of work including:
• Science and technology development in order to assess and mitigate environmental
impacts;
• Policy and regulation development to optimize environmental protection and
enhancement while minimizing bureaucratic obstacles;
• Regional implementation and oversight of state regulations and enforcement, as
appropriate;
• Acceleration of environmental permitting where consistent with environmental protection
and enhancement;
• Voluntary program initiatives; and
• Public outreach and communication to states, tribes, industry, other government entities,
and the public.
The results of this survey can provide the basis for a comprehensive, strategic biofuels program
at EPA which will be well integrated internally and form an essential part of the national effort
for a sustainable biofuels program.
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Table 3. EPA Regulatory Roles in the Biofuels Supply Chain
(SL= Sole Leading Role, CL=Collaborative Leading Role, AO=Assisting Role to Others)
EPA Functions and Roles
Basic
Functions
Develop
Environmental
Policies and
Regulations
Federal
Implementation
and Oversight
of State
Implementation
Develop S&T to
Assess and
Mitigate
Environmental
Impacts
Technical
Areas
Air
Water
- Quality
- Quantity
Solid Waste
Pesticides &
Toxics
Use of Land
Energy
Policy
Decision Tools
Air
Water
- Quality
- Quantity
Solid Waste
Pesticides &
Toxics
Land and Soil
Quality
Energy
Implementation
Decision Tools
Air
Water
- Quality
- Quantity
Solid Waste
Pesticides &
Toxics
Land and Soil
Quality
Energy
Sustainability
S&T Decision
Tools
Biofuels Supply Chain Elements
Feedstock
Production
Feedstock
Logistics
Biofuels
Production
Biofuels
Distribution
Biofuels
End Use
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Table 4: EPA Environmental Stewardship Support Roles in the Biofuels Supply Chain
(SL= Sole Leading Role, CL=Collaborative Leading Role, AO=Assisting Role to Others)
EPA Functions and Areas
Basic
Functions
Develop
Voluntary
Program
Initiatives
Communication
to the Public
Develop S&T to
Assess and
Improve
Environmental
Stewardship
Technical
Areas
Air
Water
- Quality
- Quantity
Solid Waste
Pesticides &
Toxics
Land and Soil
Quality
Sustainability
Energy
Voluntary
Program Tools
Air
Water
- Quality
- Quantity
Solid Waste
Pesticides &
Toxics
Land and Soil
Quality
Sustainability
Energy
Communication
Tools
Air
Water
- Quality
- Quantity
Solid Waste
Pesticides &
Toxics
Land and Soil
Quality
Sustainability
Energy
S&T
Environmental
Stewardship
Tools
Biofuels Supply Chain Elements
Feedstock
Production
Feedstock
Logistics
Biofuels
Production
Biofuels
Distribution
Biofuels
End Use
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In summary, NACEPT recommends that you and others you designate take the following
actions:
1. Formally adopt the Biofuels Supply Chain as a strategic framework for biofuels-
related work across the Agency.
2. Present the Biofuels Supply Chain to the intergovernmental Biomass R&D
Board as a framework for embracing a full systems approach and helping to
clarify roles and priorities among the various Departments and Agencies.
3. Prepare a questionnaire, based on the content of Tables 3 and 4, and send it
from you to all Agency Assistant Administrators and Regional Administrators
with a request that they complete and return it by a specified deadline; arrange
for the results to be collated and used to further the development of a
comprehensive strategic biofuels plan and program within the Agency.
On behalf of NACEPT, we appreciate the opportunity to offer our comments and hope they are
helpful. Please let us know if you or others would like to meet to discuss these recommendations
at any time.
Sincerely,
John L. Howard, Jr.
Chair
cc: Frank Stewart, Working Group Co-Chair
Bob Olson, Working Group Co-Chair
Marcus Peacock, Deputy Administrator
Charles Ingebretson, Chief of Staff
Ray Spears, Deputy Chief of Staff
George Gray, Assistant Administrator, Office of Research and Development
Robert Meyers, Acting Assistant Administrator, Office of Air and Radiation
John Askew, Region 7 Administrator
Rafael DeLeon, Director, Office of Cooperative Environmental Management
Sonia Altieri, NACEPT Designated Federal Officer
References:
[1] The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) Model,
http://www.transportation.anl.gov/software/GREET/.
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