Tiny BioDiesel Producers
My purpose is to break the stranglehold that the
National Biodiesel Board
exerts on EPA Tier 1 health effects testing data,
and help Tiny Producers participate in the U.S. Federal Incentives Programs.
What is this all about?
Congress declared that producers of BioDiesel should get paid for each gallon that they produce.
The IRS administers the programs. Before you can get paid, you to have a Certificate from the EPA.
To get the certificate, you have to deal with the EPA. Dealing with the EPA can be very frustrating.
The EPA defines you as a "Small Producer" if your revenues are under 10 Million dollars a year.
If you are selling BioDiesel at $3.00 a gallon, that is just over 3 Million gallons a year or over 275,000 gallons a month!
The EPA has three categories for fuels: Baseline, Non-Baseline and Atypical.
The EPA has declared that BioDiesel is atypical, even though one section of their regs says that a Non-Baseline categorie is created for BioDiesel.
The fact that EPA considers BioDiesel Atypical is what causes all the problems.
If BioDiesel were Non-Baseline, there would be no need for the NBB or Tiny BioDiesel Producers for Small Producers.
Until somebody with the legal knowledge and money wins against them in Federal court, we are stuck with BioDiesel being classified as Atypical.
As a Small Producer, and BioDiesel being Atypical, you need Tier 1 health effects testing data and ASTM D-6751 testing of your fuel in order to get your Certificate.
You do NOT need Tier II health effects testing.
Most who brew in thier backyard are Small Producers, or as I phrase it, Tiny Producers!
If you sell BioDiesel, you must be registered with the EPA.
You can get paid 50 cents or 1 dollar a gallon for producing BioDiesel, depending on the feedstock you use.
You can also get 10 cents a gallon, capped at $1.5 million a year under the Energy Law.
The NBB and the Soybean lobbyists had a lot to do with the following numbers.
Virgin Vegetable Oil is paid at 1 dollar a gallon.
Used or Waste Vegetable Oil is paid at 50 cents a gallon even though it was virgin oil once upon a time.
Anything other than Virgin Oil is paid at 50 cents a gallon.
What does it take to get paid to brew BioDiesel?
You need an EPA Certificate.
You need ASTM D-6751 testing data of your fuel to get the certificate.
You need Tier I health effects testing to get the certificate.
Since the EPA has declared BioDiesel to be atypical, everybody needs Tier 1 health effects testing, no exceptions.
If your revenues are more than $10 Million a year, you need Tier 2 health effects testing as well.
Tiny BioDiesel Producers only need Tier 1 data.
The NBB has Tier 1 and Tier 2 health effects testing data available to thier members.
They say they spent $2.2 Million dollars to get it.
All you have to do is join at the Small Producer level ($2,500 a year + volume dues) to get access.
Check it out at thier Membership Information Page
They do have a Individual membership at $500, but you cannot have any "direct economic interest" in BioDiesel as of 8/07.
Ref
Since all who want an EPA Certificate have a direct economic interest, this is a non-viable membership for us.
When you pay your $2,500 to join the NBB, you get access to both sets of data, even though you may only need Tier 1.
How the NBB got the $2.2 million to conduct the tests to meet those Tier levels is another story.
Why Should You Care?
Tier 1 is all you need unless you produce a LOT of BioDiesel each year.
When you are producing enough to need Tier 2 data, you should join the NBB.
Until then, the goal of The TinyBioDiesel Producers is to provide you with that data much cheaper than the NBB.
So cheaply that the small backyard producer can afford it and get paid for the fuel he uses in his personal vehicles.
Why the Tiny BioDiesel Producers?
My purpose is to provide an alternative to the NBB for Tier 1 data and discount ASTM testing for members.
If you produce 100 gallons a month, you should get $720 a year back from the Fed.
Membership in the NBB is cost prohibitive. $112 to TBP is not a lot to ask.
If you produce 1,000 gallons a month, you should get $7,200 a year back from the Fed.
At 1,000 gallons a month, you could afford to join the NBB, but why?
NBB Small Producer membership would cost you $2,500 while TBP would cost $220.
If you produce 10,000 gallons a month, you should get $72,000 a year back from the Fed.
Even at this production level, all you need is Tier 1 data, so why join NBB?
NBB Small Producer membership would cost you $2,500 while TBP would cost $1,300.
If you produce 100,000 gallons a month, you should get $720,000 a year back from the Fed.
You could afford the NBB, but you still only need Tier 1 data.
At this level, NBB costs $2500 + 10,000 volume dues = $12,500. TBP is $12,100.
If you produce more than 100,000 gallons a month, you would want NBB an voting membership.
You would still be an EPA Small Producer, but you are not a Tiny Producer anymore...
What I am planning and doing!
The first project is get Tier 1 certification.
I am trying to do it with Public Domain, and propreitary, documents.
A first submission was made to the EPA in late 2006.
There has been no offical response to that submission.
It has been over 6 months.
Under their regulations, if you don't hear back in 6 months, you can consider your application granted.
EPA is not famous for following thier regulations, so I don't think I have Tier 1 yet, even though it has been over 6 months.
I will be writing asking for clarification.
I am working on putting together another set of documents that should pass muster.
When I have it, all members can use it.
This may have to be a long range goal.
The second project is to set up a lab and do testing.
I plan to use membership funds to purchase lab equipment to do the ASTM D-6751 Suite of tests.
A complete suite of tests costs just over $1,000 depending on the lab you use.(8/07)
I am hoping that my lab can cut that cost in half or better.
I hold a Bachelor of Science in Chemical Engineering, so I should be able to run a testing lab.
Membership in Tiny BioDeisel Producers
Membership is $100 a year + 1 cent for each gallon that you are paid for producing once we have Tier 1 in place.
I figure that if you are getting paid 60 cents or $1.10 a gallon, a penny a gallon is not too much to ask.
You will get access to Tier 1 data when we get it and discount testing as the lab gets going.
As of 8/19/07 neither of these member benefits are available.
I am targeting Kinematic Viscosity and Flash Point as the first tests.
I did Kinematic Viscosity testing for my father to help hin earn his PhD in Chemical Engineering when I was 14.
It is a test that I already know how to do. I just need the equipment. Automated would be nice...
Might be fun to go back to school and get a PhD to give the lab more credibility.
I don't think that Tiny Producers will care about credibility as long as EPA accepts the test results.
These tests will then be available to members at cost plus 10%.
Since the cost of the equipment will be covered by memberships and volume charges, the only cost for
members will be technician time and consumables. That should make the tests cheap.
Estimated cost for Kinematic Viscosity and Flash Point is $10 each. This compares to $40 and $50 at commercial labs.
I hope to cut the cost for a complete suite of tests to over half of what the commercial testing places charge.
If this sounds like something you would like to be a part of or support:
Send a check for $100 to:
Tiny BioDiesel Producers
P.O. Box 1127
American Fork, Utah 84003
or
Send $100 of gold to e-gold #252282
or to e-bullion #A36779
then send an email with your contact information and the batch number to tinybiodiesel at kmjmail.com
If you do not have an e-gold account, get one here:
E-Gold
My favorite funder of e-gold accounts: Not accepting deposits right now...
(They are located just up the freeway from me, and give fast service.)
The Bullion Exchange
E-Buillion Accounts can be secured here:
E-Bullion
End Notes
Still working on these.
1. 40 CFR
TinyBioDiesel Producers is a wholly owned subsidiary of KMJ Enterprises, Inc, a Utah Corporation.
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