1
January 18, 2017
Ms. Diana Galperin U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460
Diana,
National Sorghum Producers (NSP) is pleased to provide the supplemental information you requested via email dated October 28, 2016, on our renewable fuel pathway petition for sorghum oil, which we submitted on July 29, 2016.
For ease of reference, we have reproduced your email in its entirety below in black type and provided our answers in red type. As you will see, portions of this supplemental submission contain confidential business information (CBI). We have marked the CBI-containing sections with red headers and footers and yellow highlighting.
We thank you for your attention to and review of this petition. We stand ready to provide any additional information you may require. Please do not hesitate to call me at (806) 638-5334 or contact me via email at john@sorghumgrowers.com.
Thanks,
John Duff National Sorghum Producers (806) 749-3478
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00001
2
Dear Mr. Duff,
We have reviewed your petition and are requesting the following additional information before we can accept your petition as being complete. We understand that some, but not all, of the data requested below is included in the petition you submitted, and we are requesting that the data be provided in the tables/formats specified below to help us complete our evaluation as expeditiously as possible. We ask that all data provided be documented with peer reviewed literature, data from USDA or from other credible sources to the extent possible. If such data are not available, please explain why and include the best information available. Please let us know if you have any questions.
1) In our May 2016 reply to the pathway screening tool (PST) from NSP, we cited section 5.1.2.3 of the RIA to the March 2010 RFS final rule as an example of the type of information needed. For the composition and nutritional value of oiled and de-oiled DGS, the RIA cites Shurson (2006).1 Please fill in the following data table, based on Table 1 in Shurson (2006). See the attached table completed by Dr. Ryan Mass, feed business manager for ICM, on page 6. Dr. Mass's resume is attached on page 7. Please note Dr. Mass's inclusion of net energy in place of metabolizable energy. According to Dr. Mass, this substitution was made because net energy is the primary parameter used by professional nutritionists to formulate rations. Conversely, metabolizable energy is an intermediate calculation used primarily for research purposes. Net energy also allows for more accurate comparisons between species.
1http://www.biofuelscoproducts.umn.edu/sites/biodieselfeeds.cfans.umn.edu/files/cfans asset 416494.pdf 2Yield on wet matter basis 3 Dry mass percent of SDGS = mass of SDGS on dry matter basis / mass of SDGS on wet matter basis 4% = dry mass of nutrient listed in first column / mass of SDGS on dry matter basis 5 ME = Metabolizable energy
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00002
3
Threonine, %
2) Section 5.1.2.3 of the RIA to the March 2010 RFS final rule cited Arora et al. (2008)6as the basis for DGS displacement rates. Please fill in the following data table based on the bottom of Table 14 in Arora et al. (2008). (Only displacement data is needed, as nutritional value will be covered by the data table above.) See the attached table completed by Dr. Mass on page 8. Please note some of the table entries are left blank (for example, soybean meal in beef cattle rations). This is because sorghum DGS does not replace soybean meal in beef cattle rations regardless of the oil content.
Corn displacement Soybean meal displacement Urea displacement
SDGS Displacement rates by animal type (Ib/lb SDGS, 100% dry matter basis)
Beef cows
Dairy cows
Swine
Poultry
Oiled
De-oiled Oiled De-oiled Oiled De
Oiled De
oiled
oiled
a) On page 11 of the ICM Consulting report submitted in the petition, it states "Plant A reported that the plant intentionally reduced the BTS oil recovery in order to maintain the fat value in the DDGS for the marketing feed tag requirements." Please provide information on the nutrient requirements to attain marketing feed tags (% lb of dry matter basis oiled and de-oiled SDGS) for beef cows, dairy cows, swine and poultry. This issue relates solely to the feed tag requirements for a specific customer of Plant A. There are no universally-accepted requirements for feed tags. Instead, each facility guarantees a certain nutritional composition based on its own capabilities and the needs of its customers. See the attached letter to this effect from ICM on page 9. a. Please also provide background information on how de-oiled SDGS are treated in order to be sold on the livestock market. No additional non-mechanical treatments are used in the production and marketing of in de-oiled SDGS. See the attached letter to this effect from Conestoga Energy Partners on page 10. b. On page 3 of the appendix with Dr. Kimberly C. McCuistion's analysis of the nutritional value of sorghum DDGS with and without oil extraction, she notes, "With the removal of the oil, additional sources of fat may be included in the diet through other ingredients to insure adequate energy availability; however, any additional fat sources needed when feeding de-oiled sorghum DDGS should be similar in quantity to those needed when feeding de-oiled corn DDGS." Please provide quantities in lbs of additional fat that need to be added to the de-oiled sorghum DDGS and the most common sources of this fat. Please also provide similar information for corn DDGS. Dr. Mass outlines these minor
6 http://www.anl.gov/energv-systems/publication/update-distillers-grains-displacem ent-ratios-corn-ethanol-lifecycle-0
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00003
4
additional requirements on page 8. Also attached on pages 11-12 are two rations (one for sorghum and one for corn) balanced by Dr. Mass using de-oiled distillers grains, c. Please provide the following information on the market value of SDGS with and without oil extraction: a. Monthly historical prices (in nominal terms) for past 5 years of SDGS with and
without oil extraction $/lb See this information attached on pages 13-14. Please note data for the three White Energy plants are only available beginning in 2014. This is due to an ownership change that has made gathering accurate accounting information difficult. Also note these data are marked as CONFIDENTIAL BUSINESS INFORMATION. b. Please also provide values for corn DDGS oiled and de-oiled. Prices for corn and sorghum distillers grains are not separated in public datasets as prices received do not differ based on the feedstock. See the attached letter to this effect from the USDA Agricultural Marketing Service on page 15. 4) Please fill out "Tab 2. Process" on the spreadsheet titled Data Submission Template for New Pathway Petitions Version 2.0 and located at https://www.epa.gov/sites/production/files/2015-08/420bl4071.xlsx. a. In this spreadsheet please provide the mass and energy balance of a representative dry mill grain sorghum ethanol facility with both sorghum oil and no sorghum oil extraction. If you wish to provide data for multiple dry mill facility configurations, please fill out separate spreadsheets for each one and submit all of them with clear labelling explaining the differences. See the attached spreadsheets completed by ICM detailing mass and energy balances for dry mill ethanol production facilities using grain sorghum as a feedstock. One includes oil extraction, and one does not. These sheets are attached as PDFs on pages 16-17 along with a letter from ICM on the process of completing the sheets on page 18. Please note they are marked as CONFIDENTIAL BUSINESS INFORMATION. b. Please also fill provide separate spreadsheets with the mass and energy balance of representative fuel production processes for the conversion of extracted grain sorghum oil to finished fuel. This should include the following fuel production processes:
i. Biodiesel produced via transesterification See the attached spreadsheet completed by engineering consulting firm Saola Energy LLC on page 19. We have also attached at page 20 a letter from Saola on the process of completing the sheet. Please note the sheets are marked as CONFIDENTIAL BUSINESS INFORMATION.
ii. Renewable diesel, jet fuel, naphtha and LPG produced via hydrotreating (with and without co-processing). (Note that on the cover sheet of your petition you listed the production process as "hydroheating" but we assume you meant "hydrotreating" as currently listed in Table 1 to 40 CFR 80.1426, if that is incorrect please clarify.) You are correct. We indeed mean "hydrotreating." Thank you for catching this typo. The separate spreadsheets you requested were completed by Saola Energy and attached on page 21. Please note it details the mass and energy balance of renewable
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00004
5
diesel only. Also note these are marked as CONFIDENTIAL BUSINESS INFORMATION. iii. Heating oil produced via transesterification and/or hydrotreating. At this time, NSP cannot provide the requested supplemental information for jet fuel, naphtha, LPG and heating oil. As of this writing, there is no market for sorghum oil-derived jet fuel, naphtha, LPG or heating oil, and to our knowledge, no facilities are considering producing these fuels. We respectfully reserve the right to supplement this pathway petition in the future with jet fuel, naphtha, LPG and heating oil data, should they become relevant. In the meantime, we respectfully request EPA proceed with processing our pathway petition on the sorghum oil to renewable diesel and biodiesel pathways.
5) Please explain all of the units for the data in the table found on page 52, in the PDF version of your petition which lists production and sorghum use figures. The applicable units have been added and the updated table is attached on pages 22-24. Please note it is marked as CONFIDENTIAL BUSINESS INFORMATION.
6) On page 6 of your petition, you write "Moreover, the EPA's approval of these fuel pathways will result in near-immediate introduction of a monthly volume of 310,725 gallons (466,088 million ethanol-equivalent gallonsi) of grain sorghum oil biomass-based diesel and advanced biofuels into the stream of commerce. " Please clarify how this figure was calculated. This was calculated by multiplying the cumulative monthly volume of sorghum oil produced by the six dry mill ethanol production facilities discussed in this petition multiplied by the biofuel yield per pound of oil divided by the number gallons of biofuel per pound. This note of clarification has been added. See attached for a copy of the applicable page and highlighted note on page 25.
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00005
6
the
of innovation'
December 2, 2016
Nutrient Profile of Reduced-Oil Sorghum Distillers' Grains Submitted by Ryan A. Mass, PhD ICM Feed Business Manager
There exists in the scientific literature no information about the feeding value and nutrient profile of reduced-oil sorghum distillers' grains for livestock. However, data exist about the effect of reducing the oil in corn distillers' grains. It is the professional opinion of ICM, Inc that sorghum and corn behave similarly in terms of the way nutrients flow through an ethanol plant and deposit in the distillers' grains. Therefore, it is logical to apply the ratios taken from the corn distillers' grains data to the sorghum distillers' grains data. Please find below. Only refereed sources of data are used in this analysis.
Nutrient Dry Matter, % Crude Protein, % Crude Fat, % (a.k.a. Ether Extract) Net Energy- beef growing, kcal/kgA Net Energy- beef finishing, kcal/kgA Net Energy- dairy, kcal/kgAA Net Energy- swine, kcal/kg Net Energy- poultry, kcal/kgAAA Neutral Detergent Fiber (NDF), % Acid Detergent Fiber (ADF), % Ash, % Calcium, % Phosphorus, % Lysine, % Methionine, % Cystine, % Tryptophan, %
Full-Oil Sorghum DDGS* 89.84 30.80 9.75 2144 2011 1855 2394 2283 33.60 22.68 6.62 0.12 0.76 0.82 0.54 0.53 0.25
Reduced-Oil Sorghum DDGS**
89.94 31.36 3.91 1924 1830 1873 2053 2135 37.23 31.91 7.60 0.08 0.96 0.62 0.47 0.61 0.23
` Data (unless noted) taken from Nutrient Requirements of Swine, 2012 National Academies Press, Washington DC, pg 329
" Data calculated using the ratio of 1) corn DDGS, >6 and <9% Oil; and 2) corn DDGS, <4% Oil from Nutrient Requirements of Swine. 2012 National Academies Press, Washington DC, pp. 266 and 267 ANutrient Requirements of Beef Cattle. 2016 National Academies Press, Washington DC, pg 295
AA Mjoun et a!., 2010 Journal of Dairy Science 93:288-303. Lactation performance and amino acid utilization of cows fed increasing amounts of reduced-fat dried distillers grains with solubles.
AAABarekatain et al., 2014 Poultry Science 93:2793-2801. Effect of sorghum distillers' dried grains and microbial enzymes on net energy values of broiler diets.
31 ON. First Street P.O.Box 397 Colwich, Kansas 67030 USA Phone: +1.316796.0900 Fax: +1.316.796.0570
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00006
7
of innovation'
Ryan A. Mass
EDUCATION - ANIM AL SCIENCE
2002 1998 1995
Doctor of Philosophy Master of Science Bachelor of Science
University of Nebraska University of Nebraska Iowa State University
PROFESSIONAL EXPERIENCE
Oct, 2016 - Present
ICM Ventures, Incorporated
Colwich KS
Recruited to lead their new feed business, I evaluate the commercial viability of new ingredients
through the design and supervision of research and development. I will lead the launch of ingredients
deemed to be commercially viable into the marketplace. I also support the sales and marketing team of
this ethanol equipment manufacturing firm as it continues to be the market-leading provider of new
technologies.
Jan, 2010 - Sep, 2016
XF Enterprises
Pratt KS
Recruited to lead the consulting division of Nutrition Service Associates in Pratt Kansas, I
supervised one nutritionist and all custom formulas. I also served as the consulting nutritionist for the
Anipro / Xtraformance Feeds division of the company.
In addition, I served as the sales and technical representative of Westway Feed Products for
Kansas and adjoining areas from July 2012 to July 2015. I set gross margins on liquids and pellets, quoted
prices, and delivered customer service.
Major Accomplishments
-9% annualized sales growth during my tenure
-Sold over 2,000 tons of rock pellets (Westway's new technology)
-Added 22 consulting clients
Sep, 2006 - Dec, 2009
Lallemand Animal Nutrition
Milwaukee Wl
Recruited to lead all beef technical consultation globally for their yeast and bacterial DFM
products, my time was split equally among applied research projects, technical support, and sales.
Major Accomplishment- Impact of a new direct-fed microbial on intake and ruminal pH.
Nebraska Beef Report MP92, pp. 99-101.
Apr, 2003 - Aug, 2006
XF Enterprises
Pratt KS
Marketed and provided technical services to a diverse clientele as an associate member of
Nutrition Service Associates. Clients included feed ingredient companies, beef and dairy producers, an
independent feed store, and an analytical laboratory. I also developed new cattle nutrition products.
Major Accomplishments
-Invented the technology used for QualiTech Precision Micronutrients
-Co-invented U.S. Patent #8,048,457- "Saponin and Preservative Compositions"
310 N. First Street R0. Box 397 Colwich, Kansas 67030 USA Phone: +1,316.796,0900 Fax:+1.316.796.0570
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00007
8
the
of innovation'
Displacement of Commodities by Sorghum Distillers' Grains December 5, 2016
Ryan A. Mass, PhD, ICM Feed Business Manager
An ingredient displacement model developed previously (Arora et al, 2008) requires expansion for sorghum distillers' grains. It is the professional opinion of ICM, Inc. that the only application of reduced oil sorghum distillers' grains which would result in reduced feeding value for livestock is for beef cattle in the feedlot. Opheim et al. (2016) demonstrated recently that all types of distillers' dried grains (whether from corn or sorghum, with or without full-oil) have the same feeding value for cattle when the diets were formulated to have the same amount of fat. Therefore, because oil had to be added at the expense of corn when reduced-oil sorghum distillers' dried grains were fed in that experiment, the corn displacement ratio for beef cattle has been lowered in the table commensurately for reduced oil sorghum distillers' grains by 1.89% compared to the full-oil option (see attached example rations which demonstrate how this concept is applied in a practical setting).
No effect of oil reduction in sorghum distillers' grains on the displacement of the feed ingredients listed would be observed for the other species. This phenomenon is explained by the fact that the oil itself provides little marginal benefit in those applications (over and above that of the energy and protein otherwise present). Ramirez et al. (2016) demonstrated recently that feeding reduced oil distillers' grains is beneficial to dairy cows because there is less likelihood for the onset of milk fat depression, which is caused by a fat-induced change in the rumen microbial community of those animals. Kerr et al. (2016) described several studies which have "have shown that increased concentrations of free fatty acids have a negative impact on lipid digestion and energy content" of cereal grains oils for swine and poultry.
ingredient
Corn Soybean Meal
Urea
Beef Cattle FullOil Reduced Oil
1.196
1.173
Sorghum Distillers1Grains Displacement Ratio (lb of ingredient / lb of SDGS, dry matter basis)
Dairy Cattle FullOil Reduced Oi!
Swine FullOi! Reduced Oi!
0.731
0.731
0.890
0.890
Poultry FullOil Reduced Oil
-
-
0.633
0.633
0.095
0.095
0.056
0.056
-
-
-
-
-
-
Literature Cited
Arora et al., 2008. Argonne National Laboratory. Update of distillers grains displacement ratios for corn ethanol life-cycle analysis.
Kerr et al., 2016. Journal of Animal Science 94:2900-8. Lipid digestibility and energy content of distillers1corn oil in swine and poultry.
Opheim et al., 2016. Journal of Animal Science 94:227. Biofuel feedstock and blended coproducts compared with deoiled corn distillers grains in feedlot diets: Effects on cattle growth performance, apparent total tract nutrient digestibility, and carcass characteristics.
Ramirez et al., 2016. Journal of Dairy Science 99:1912-28. Reduced-fat dried distillers grains with solubles reduces the risk for milk fat depression and supports milk production and ruminal fermentation in dairy cows.
31 ON. First Street P.O.Box 397 Colwich, Kansas 67030 USA Phone: +1.316796.0900 Fax: +1.316.796.0570
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00008
9
of innovation'
October 31, 2016
Dear Sir or Madam,
I am writing to clarify a statement made on page 11 of the consulting report referenced in the sorghum oil petition. The plant in question, Plant A, had a fat requirement in its individual feed tag that required it to extract less oil than most plants. This was not a reflection of a problem but rather a specific matter related to Plant A's individual feed tag that was negotiated with that individual customer.
Feed tags are documents provided to customers detailing the composition of feed products, and these can vary by facility and feed type (wet, dry, partially dry, etc.). Thus, there is no single standard for distillers grains composition. This is the reason for the special feed tag requirement that led Plant A to extract less oil.
Thank you for the opportunity to comment, and please let me know if you have any questions.
Thanks,
Jeff Scharping
Director - ICM , Inc.
31 ON. First Street P.O.Box 397 Colwich, Kansas 67030 USA Phone: +1.316796.0900 Fax: +1.316.796.0570
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00009
10
commodities, lie
Dear Sir or Madam, Conestoga Energy Partners and White Energy, through a joint venture known as C&W Commodities, market wet and dried sorghum and com distillers grains with oil and without oil produced in six dry mill ethanol facilities in Kansas and Texas. We market these products to livestock producers without any additional non-mechanical treatments. The only added step after the coproduct exits the facility is rotary drying for the feed we market on a dry matter basis. This process is identical for sorghum distillers grains with oil and without oil and com distillers grains with oil and without oil. The coproducts are segregated based on their moisture content and stored in staging facilities. Just prior to delivery or pickup, an auger or belt is used to load the coproduct onto a trailer for transport to livestock producers. Thank you for the opportunity to comment, and please let me know if I can answer further Questions.
Matt Durler Vice-President of Marketing C&W Commodities, LLC
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00010
Ration Analysis
Bluebird Feeders
DALEX CONNECT
Pricing Sorghum DDGS - Ingredient Detail
Ingredient Name Corn Grain - Flaked - 24 lb Sorghum DDGS- 9.75% fat Alfalfa Hay 17- 46 NDF Molasses - Cane Limestone - Ground Distillers' Corn Oil Salt - White Vitamin ADE Premix 1 Trace Mineral Premix Sorghum DDGS- 3.91% fat Total
Costs($/Formula) Ingredient Cost
Pricing Sorghum DDGS - Nutrient Analysis (DM %)
Protein Net Energy Gain / NRC96 Calcium Chlorine Cobalt Copper Iodine Iron Magnesium Manganese Phosphorus Potassium
% Mcal/cwt
% % ppm ppm ppm ppm % ppm % %
AF lb 1,325.21
461.65 108.75
60.00 22.00 14.61
4.15 3.07 0.57
2,000.00
161.03
% of AF 66.26 23.08 5.44 3.00 1.10 0.73 0.21 0.15 0.03
100.00
15.30 68.79
0.60 0.24 0.80 12.59 0.73 92.35 0.13 40.96 0.23 0.48
Salt Selenium Sodium Sulfur Zinc NDF Fat Vitamin A Vitamin D Vitamin E TDN / NRC96 Moisture
11
Ryan Mass
Prepared on:December 05, 2016
% of DM 63.81 25.01 5.89 2.64 1.32 0.87 0.25 0.18 0.03
100.00
Ingredient AF AF Shadow Price
$/ton
(ton)
142.86
174.00
100.00
200.00
52.00
588.00
56.00
5,555.00
4,444.00
1,000.00
165.07
% ppm
% % ppm % % lU/lb lU/lb lU/lb % %
0.25 0.30 0.12 0.13 10.71 8.88 6.00 2,000.00 199.41 92.32 70.47 16.93
Animal performance is not guaranteed by feeding of specific rations. C hanges in composition of feeds, methods of feeding, environment, and general management will affect performance.
December 05, 2016
Page 1 of 1
WDC 373450807V2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00011
Ration Analysis
Bluebird Feeders
DALEX CONNECT
Pricing Sorghum DDGS - Ingredient Detail
Ingredient Name Corn Grain - Flaked - 24 lb Sorghum DDGS- 3.91% fat Alfalfa Hay 17- 46 NDF Molasses - Cane Distillers' Corn Oil Limestone - Ground Salt - White Vitamin ADE Premix 1 Trace Mineral Premix Total
Costs($/Formula) Ingredient Cost
Pricing Sorghum DDGS - Nutrient Analysis (DM %)
Protein Net Energy Gain / NRC96 Calcium Chlorine Cobalt Copper Iodine Iron Magnesium Manganese Phosphorus Potassium
% Mcal/cwt
% % ppm ppm ppm ppm % ppm % %
AF lb 1,300.30
462.85 108.75
60.00 38.31 22.00
4.15 3.07 0.57 2,000.00
161.02
% of AF 65.02 23.14 5.44 3.00 1.92 1.10 0.21 0.15 0.03 100.00
15.17 68.76
0.60 0.24 0.81 12.55 0.74 91.71 0.13 41.03 0.23 0.47
Salt Selenium Sodium Sulfur Zinc NDF Fat Vitamin A Vitamin D Vitamin E TDN / NRC96 Moisture
12
Ryan Mass
Prepared on:December 05, 2016
% of DM 62.44 25.00 5.87 2.63 2.28 1.31 0.25 0.18 0.03 100.00
Ingredient AF AF Shadow Price
$/ton
(ton)
142.86
151.00
100.00
200.00
588.00
52.00
56.00
5,555.00
4,444.00
% ppm
% % ppm % % lU/lb lU/lb iU/lb % %
0.25 0.30 0.12 0.12 10.51 8.74 6.00 1,995.98 199.01 92.13 71.58 16.70
Animal performance is not guaranteed by feeding of specific rations. C hanges in composition of feeds, methods of feeding, environment, and general management will affect performance.
December 05, 2016
Page 1 of 1
WDC 373450807V2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00012
13
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Hereford Month(Year) ....... WDGS.. November(ll)i December(ll) | January(12) j February(12) j March(12) ;
April(12) : May(12) j June(12) ! July(12) I August(12) j September(12)i October(12) j November(12)| December(12) j January(13) j February(13) | March(13) j April(13) ; May(13) ! June(13) ' July(13) j August(13) j September(13)i October(13) | November(13)i December(13) j January(14) | February(14) j March(14) | April(14) ; May(14) j June(14) ;
Plainview
Russell
Western Plains Energy
Arkalon
Bonanza
WDGS WDGS DDGS WDGS
DDGS WDGS DDGS WDGS DDGS
CBI / Ex. 4
Kansas Ethanol WDGS DDGS
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW Tier 1
ED 002061 00164223-00013
14
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Month(Year) July(14)
August(14) September(14)
October(14) November(14) December(14) January(15) February(15)
March(15) April(15) May(15) June(15) July(15) August(15) September(15) October(15) November(15) December(15) January(16) February(16) March(16) April(16) May(16) June(16) July(16) August(16) September(16)
Hereford WDGS
Plainview
Russell
Western Plains Energy
Arkalon
Bonanza
WDGS WDGS DDGS WDGS
DDGS WDGS DDGS WDGS DDGS
CBI / Ex. 4
Kansas Ethanol WDGS DDGS
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW Tier 1
ED 002061 00164223-00014
USDA United States Department of Agriculture
Agriculture Marketing Service Livestock, Poultry, &Seed Program Livestock, Poultry & Grain Market News
http://mm/,ams.usda,gov/LPSMarketNew$Page
15
12819 Country Place Drive Saint Joseph, Mo 64505 Voice: (816) 676-7000 Fax; (816) 279-8902 Email: stjoe.lpgnvi@usda.gov
John Duff Strategic Business Director National Sorghum Producers 4201 North Interstate 27 Lubbock, TX 79403
November 29, 2016
To Whom It May Concern:
The USDA's Agricultural Marketing Service is responsible for the National Daily Ethanol Report. This is a bioenergy report that includes price data for dry, modified, and wet distillers grain, corn oil, and ethanol for the following states: Eastern Corn Belt (Illinois, Indiana, Ohio, Michigan), Iowa, Kansas, Minnesota, Missouri, Nebraska, South Dakota, and Wisconsin. Information included in this report is collected daily.
Corn and sorghum grain bids are collected and included on this report; however, corn-based and sorghum-based distillers grain prices are not separated on the report, as current industry practices are to blend corn and sorghum distillers grains and market as one product.
Thank you for the opportunity to comment.
Regards,
Russ Travelute, Field Chief, LPGMN
In accordance with Federal civil rights law and II. S. Department of Agriculture (USDA} civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender
expression), sexualorientation, disability, age, maritalstatus, family/parentalstatus, incomederivedfromapublicassistanceprogram, politicalbeliefs, orreprisalorretaliationforprior civilrights activity, in anyprogramoractivityconductedorfundedby USDA (notallbases applytoallprograms}. Remedies andcomplaintfiling deadlines varybyprogramorincident.
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00015
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
16
Data Submission Template for Petitions Involving Fuel Production Processes Not Previously Modeled
Requested Pathway
Fuel Produced
Ethanol
Feedstock
Grain Sorghum
Process
Dry Grind
D-Code Request (see Table V.C-7-D-Code Designations)
D-5
Expected performance of a processing plant based on past data from numerous plants. Yields are in accordance with the evaluation provided. The energy use constants are from estimations based on numerous reported plant data, and averaged. This plant is not operating any oil separation equipment and is drying 100% of it's DDGS.
Mass and Energy Balance Information [Mass
Mass Value
Units
Volume Value
Units
Lower Heating Value (LHV)
Value
Units
Data Source Source (Required)
1Energy balance information should include a list of any energy and process heat inputs and outputs used in the pathway, including such sources produced off site or by another entity. 2Energy input information should include fuels used by type, including purchased electricity. Indicate the source, type o f fuel required, efficiency, and tem perature/pressurefor any steam or hot water purchased for the fuel production process. 3The extent to which excess electricity or other heat sources are generated and distributed outside the production facility should be described.
ICM Trade Secret Information exempted from Public Disclosure under Freedom of Information A ct 5 U.S.C. 552(b)(4). ICM Proprietry/ConfidentiaI and Trade Secret Information protected by Consulting Agreement, U.S. Economic Espionage Act, and Uniform Trade Secrets Act. Oil Methods Protected by US Patent No. 8192627. Fiber Separation TechnologyTM and Generation 1.5 Grain Fiber to Cellulosic Ethanol TechnologyTM are Patent Pending. 2017 ICM, Inc.
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Tier 1
ED 002061 00164223-00016
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
17
Data Subm ission Tem p late for P etitions In vo lvin g Fuel Production Processes Not Previo usly M odeled
Requested Pathway
Fuel Produced
Ethanol
Feedstock
Grain Sorghum
Process D-Code Request (see Table V.C-7-D-Code Designations)
Dry Grind D-5
Expected performance of a processing plant based on past data from numerous plants. Yields are in accordance with the evaluation provided. This plant is operating oil removal equipment, and drying all DDGS co-product. The energy use constants are from estimations based on numerous reported plant data, and averaged. The increase in electricity from the equipment to remove corn oil is usually less than 2% of the plants total connected horsepower. The decrease in natural gas usage is due to less DDGS product overall being dried.
________________________
Mass iand Energy Balance Information Mass
Mass Value
Units
Volume
Value
Units
Lower Heating Value (LHV)
Value
Units
Data Source
Source (Required)
Year
CBI / Ex. 4
1Energy balance information should include a list of any energy and process heat inputs and outputs used in the pathway, including such sources produced off site or by another entity. 2Energy input information should includefuels used by type, including purchased electricity. Indicate the source, type of fuel required, efficiency, and temperature/pressure for any steam or hot water purchased for the fuel production process. 3The extent to which excess electricity or other heat sources are generated and distributed outside the production facility should be described.
ICM Trade Secret Information exempted from Public Disclosure under Freedom of Information Act 5 U.S.C. 552(b)(4). ICM Proprietary/Confidential and Trade Secret Information protected by Consulting Agreement, U.S. Economic Espionage Act, and Uniform Trade Secrets Act. Oil Methods Protected by US Patent No. 8192627. Fiber Separation Technology'" and Generation 1.5 Grain Fiber to Cellulosic Ethanol Technology'" are Patent Pending. 2017 ICM, Inc.
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Tier 1
ED 002061 00164223-00017
18
the energy of innovation" To Whom It May Concern, The attached EPA Pathway Sheets are an estimation based on ICM Inc.'s knowledge of the first generation ethanol process. The estimates were calculated on a number of different inputs which are to the best of our knowledge industry equivalents.
Director of Technology Development--St. Joseph Phone: 316.977.8507 Cell: 316.648.1399 Jeremy.Javers@lcmlnc.com
ICM Trade Secret Information exempted from Public Disclosure under Freedom of Information Act 5 U.S.C. 552(b)(4). ICM Proprietary/Confidential and Trade Secret Information protected by Consulting Agreement, U.S. Economic Espionage Act, and Uniform Trade Secrets Act. Oil Methods Protected by US Patent No. 8192627. Fiber Separation TechnologyTM and Generation 1.5 Grain Fiber to Cellulosic Ethanol TechnologyTM are Patent Pending. 2017 ICM, ine.
2811 South 11th Street St. Joseph, MO 64503
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
icminc.com ED 002061 00164223-00018
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
19
Data Submission Template for Petitions Involving Fuel Production Processes Not Previously Modeled
Requested Pathway
Fuel Produced
Biodiesel
Feedstock
Sorghum Oil
Process
Enzymatic
D-Code Request (see Table V.C-7-D-Code Designations)
S c e n a rio :
Based on data for a 2.5MMGPY biodiesel facility utilizing corn oil as the feedstock. There is no fundamental difference between corn oil and sorghum oil as a feedstock for the biodiesel process.
M ass,and Energy Balance Inform ation
Mass
V alue
U n its
V olum e
V alue
U n its
Low er H eating V alue (LHV)
V alue
U n its
Data Source So urce (R eq uired ) - See cell C8
Year
CBI / Ex. 4
1Energy balance information should include a list of any energy and process heat inputs and outputs used in the pathway, including such sources produced off site or by another entity. 2Energy input information should include fuels used by type, including purchased electricity. Indicate the source, type of fuel required, efficiency, and temperature/pressure for any steam or hot water purchased for the sThe extent to which excess electricity or other heat sources are generated and distributed outside the production facility should be described.
WDC 373450807V2
Sierra Club v. EPA 18cv3472 NDCA
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Tier 1
ED 002061 00164223-00019
20
Saola Energy LLC 209 E William St, Suite 340A
Wichita, Kansas 67202
January 9, 2017
To Whom It May Concern,
Saola Energy LLC provides project management and process engineering support to clients on diverse projects in market sectors such as ethanol, renewable diesel, biodiesel and oil refining. The attached spreadsheets were completed based on Saola's expertise in these areas. Please do not hesitate to contact us if you have any questions.
Thank you,
Ben Root Process Engineer
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00020
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
21
Data Submission Template for Petitions Involving Fuel Production Processes Not Previously Modeled
Requested Pathway
Fuel Produced
Renewable Diesel
Feedstock
Sorghum Oil
Process D-Code Request (see Table V.C-7-D-Code Designations)
Hydrodeoxygenation and Isomerization |
Scenario:
Based on data for a 4.5MM6PY renewable diesel facility utilizing corn oil as the feedstock. There is no fundamental difference between corn oil and sorghum oil as a feedstock for the renewable diesel process. Yield values are simulated and can vary with changing process conditions.
M ass and Energy Balance Inform ation
Mass
V alue
U n its
Volum e
V a lu e
Units
Lower Heating V alue (LHV)
V alue
Units
Data Source Source (R equired) - See cell C8
Year
Energy balance information should include a list of any energy and process heat inputs and outputs used in the pathway, including such sources produced off site or by another entity. 2Energy input information should include fuels used by type, including purchased electricity. Indicate the source, type of fuel required, efficiency, and temperature/pressure for any steam or hot water purchased for 3The extent to which excess electricity or other heat sources are generated and distributed outside the production facility should be described.
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Tier 1
ED 002061 00164223-00021
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
22
Month
Kansas Ethanol Oil Production
(millions of pounds)
Kansas Ethanol Grain Sorghum
Use (percent of total bushels
used)
White Energy Hereford
Oil Production
(millions of pounds)
White Energy Hereford Grain Sorghum
Use (percent of total bushels
used)
White
Western
Conestoga
Energy
White
Energy Plainview Western
Plains Energy
Conestoga Energy
Partners
Conestoga
Conestoga Energy
Energy
Bonanza Energy
Grain Plainview
Plains
Grain Partners
Grain
Partners
Partners
Oil
Sorghum Energy Oil Sorghum Bonanza Sorghum Arkalon Oil Arkalon Grain
Use Production Use
Oil
Production
Use
Production Sorghum Use
(millions (percent (millions (percent Production (percent (millions (percent of
of total of pounds) of total (millions
total bushels
of pounds)
of total of pounds)
bushels
bushels of pounds) bushels
used)
used)
used)
used)
May 2016
April 2016
March 2016
February 2016
January 2016
December 2015
November 2015
October 2015
September 2015
August 2015
CBI / Ex. 4
WDC 373450807v2
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00022
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
23
July 2015
June 2015
May 2015
April 2015
March 2015 February 2015 January 2015 December 2014 November 2014 October 2014 September 2014 August 2014
July 2014
June 2014
May 2014
CBI / Ex. 4
WDC 373450807v2
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00023
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
24
April 2014
March 2014
February 2014
January 2014
December 2013
November 2013
October 2013
CBI / Ex. 4
WDC 373450807v2
CONFIDENTIAL BUSINESS INFORMATION HIGHLIGHTED IN YELLOW
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00024
25
1. Fuel Pathway Description (No information claimed CBI)
Through this petition, we are asking the EPA to approve renewable fuel pathways for the production of certain biofuels from grain sorghum oil. Our proposed pathways meet and exceed the regulatory requirements for approval as advanced biofuels and will have no adverse impact on the number of acres planted for the production of food, nor on the use of the de-oiled, dry grain sorghum distiller's grains as animal feed. Moreover, the EPA's approval of these fuel pathways will result in near-immediate introduction of a monthly volume of 310,725 gallons (466,088 million ethanol-equivalent gallons1) of grain sorghum oil biomass-based diesel and advanced biofuels into the stream of commerce^Shis was calculated by multiplying the cumulative monthly volume of sorghum oil produced by the six dry mill ethanol production facilities discussed In this petition multiplied by the biofuel yield per pound of oil divided by the number of gallons of biofuel per pound. See section B{4) for a detailed explanation of this and related calculations!
With the exception of the feedstock used, the pathways described in this petition for the production of biodiesel, renewable diesel, jet fuel, heating oil, naphtha and LPG (collectively referred to as "biofuels" in this document) are identical to the pathways used in the production o f biofuels from non-food grade corn oil ("NFGCO").2The greenhouse gas benefits of grain sorghum oil and its co-products are comparable to those for NFGCO. Accordingly, we are seeking RIN D-codes identical to those approved for NFGCO.
The feedstock in this petition is grain sorghum oil derived from dry mill ethanol production. The oil is separated from the distillers' grains with solubles ("DGS") by a process identical to that used to separate the NFGCO from DGS in a dry mill ethanol facility using corn as a feedstock. Separation involves centrifuging the DGS to remove the sorghum oil, which is then used for the production of biofuels onsite or at a separate facility. The de-oiled DGS is sold as animal feed.
The separation process is powered by electricity, and this petition presents no new energy-saving technology for the separation of grain sorghum oil compared to that of NFGCO.3The key differences between NFGCO and grain sorghum oil are modest lifecycle and marketing distinctions for the ethanol co-products produced when using the alternative plant feedstocks.
The EPA has previously approved grain sorghum as a feedstock for both conventional (D-code 6) and advanced (D-code 5) RINs. In those pathway approvals; however, the greenhouse gas ("GHG") lifecycle analysis ("LCA") was based on "whole DGS"; i.e., with oil included.
The EPA previously considered livestock feed replacement rates for de-oiled corn DGS. (See section 5.1.2.3 of the RIA.) The RIA did not analyze feed replacement rates for de-oiled grain sorghum DGS, however.
- " Com m ent [ j l] : Note of clarification added at EPA's request.
1See section D(2)(lii) for discussion of equivalence values. 2The NFGCO biofuel pathways were discussed at length In the RFS2 Regulatory Impact Analysis ("RIA") (EPA-420-R10-006). 3 Individual producers are free to obtain the necessary electricity from renewable sources, like solar or wind, but we do not assume such sourcing for purposes of this petition.
6
WDC 373450807v2
Sierra Club v. EPA 18cv3472 NDCA
Tier 1
ED 002061 00164223-00025