Wednesday, April 11, 2007
Aloha Kakou...
We have just read the Imperium Renewables Inc
Draft Environmental Assessment (EA)
for the proposed
biodiesel facility in Campbell Industrial Park (Leeward O`ahu).
It is not available on the web yet, so we have included some
excerpts
from the document for your perusal.
Following the EA excerpts are some other excerpts about the Imperium
facility in Gray’s Harbor, WA and palm oil.
When the EA is available electronically, we will alert the list so that
you can download the document for yourself.
This is another case of Hawai`i running headlong into projects with no
analysis of the impact. The Department of Business, Economic
Development, and Tourism is getting slammed this session for their
ethanol research, which apparently ignored the problems that boaters
and small aircraft owners are experiencing since the 10% ethanol
mandate. Boat gas tanks are corroding and causing major problems and
aircraft refuelers testified that small planes are having similar
problems. The scary part is that some folks are trying to remove the
ethanol from the fuel themselves.
In our view, the community should be involved in these discussions well
before laws are passed. There has never been such a discussion to our
knowledge.
Environmental Assessment for Proposed Biodiesel Facility, Kalaeloa
Barbers Point Harbor, Oahu, Hawaii – Prepared for: Imperium Renewables
Hawai`i LLC
Imperium wants
to import palm oil, and process it here for industrial and power plant
use. The fuel and the parent company profits would benefit others (be
outside of Hawaii).
Imperium Renewables Inc (IRI)
Draft Environmental Assessment (Draft EA)
Comment Deadline: May 8, 2007
Send Comments to
Adrienne Barnes, Project Specialist
Imperium Renewables Hawai'i LLC
1099 Alakea Street, Suite 1800,
Honolulu, Hawai'i 96813.
Glenn Abe, Supervising Property Manager
Hawai'i Department of Transportation, Harbors Division
Hale Awa Ku Moku Building
79 South Nimitz Highway
Honolulu, Hawai'i 96813-4898
Lee Sichter
Belt Collins Hawai'i, Ltd.
2153 North King Street, Suite 200
Honolulu, Hawai'i 96819.
OEQC@doh.hawaii.gov
Office of Environmental Quality Control
235 S. Beretania St., Suite 702
Honolulu, Hawaii 96813
Kalaeloa Harbor
Biodiesel Facility.
The Harbors Division of the Department of Transportation is seeking
public comment on a draft environmental assessment for the proposed
construction and operation of a facility to process up to 100 million
gallons of biodiesel fuel per year. The project site comprises 11.2
acres of undeveloped land located within the special management area at
Kalaeloa Harbor. Approximately 104 million gallons of source oil would
be provided to the facility by ship by way of pipelines from Kalaeloa
Barbers Point Harbor. The facility would also have the capability to
accept oil by intermodal container or truck if available.
The proposed
primary source of vegetable oil for biodiesel production would be palm
oil imported from Malaysia
The facility would be designed for multiple feed stocks and would be
capable of accepting soy, canola, and other natural oils. Ten million
gallons of glycerin would be generated as a byproduct in the production
process, available to be stored on-site or sold to industrial
facilities. The proposed facility would operate 24 hours a day,
employing approximately 50 to 60 persons over three eight hour shifts.
Palm oil is the
proposed primary oil source, but the facility could
accept multiple feed stocks such as soy, canola, and other natural
oils.
Excerpts From the Environmental Statement
Approximately 105 million gallons of source oil per year would be
provided to the facility by ship, via pipelines from Kalaeloa Barbers
Point Harbor. (Draft EA page 4)
Development of a biodiesel production facility on Oahu would provide an
alternative to petroleum-based diesel fuel sources for meeting the
energy needs of Hawaii, primarily for industrial end users. Biodiesel
from the proposed facility could be used as a renewable source of fuel
for electric generation plants owned by HECO. (Draft EA page 5)
Pre-Assessment Consultations:
The following agencies and organizations
were contacted prior to drafting the EA to solicit input: Barry
Fukunaga (DOT), Glenn Abe (DOT), Peter Yound (DLNR), Representative
Sharon Har, Speaker Calvin Say, Representative Hermina Morita,
Representative Clift Tsuji, Senator Mike Gabbard, Senator Russell
Kokubun, Mayor Mufi Hanneman, Councilmember Charles Djou, Honolulu
Department of Planning & Permitting, Maeda Timson
(Mamakilo/Kapolei/Honokai Hale Neighborhood Board) [no
environmental or cultural group consulted] (Draft EA page 40)
Sustainable Palm Oil Corporate Policy
Imperium Renewables, Inc. (IRI)
(Draft EA Appendix A)
IRI's approach to the burgeoning biodiesel industry is based on a
global perspective of the vegetable oil and petroleum markets.
Palm oil has received a disproportionate amount of negative publicity
due to its perceived reliance on environmentally unsound practices as
the industry expands. While it is acknowledged that there are issues
which need to be addressed, it runs deeper than the issues of one
specific industry. There are issues surrounding the agricultural
practices of all crops including deforestation, sustainable and legal
land use, pesticides and fertilizers, monoculture, the list goes on
with many various issues.
The need to compete within the energy industry requires usage of the
most efficient source of biomass-based oil crops that can be grown on
our lands; this is critical to the long term strength and success of
both agriculture and energy. However, being a company founded on sound
environmental principles also requires active participation to ensure
the establishment of a sustainable and less damaging method to grow
these biomass-based oil crops.
IRI's approach to solving these issues is to proactively engage in
organizations which can make a difference here and now; organizations
which are not just industry mouthpieces or environmentally radical
groups which do not give proper weight to the realities of the world we
live and refuse to accept the dynamic nature of our society. The RSPO
addresses these needs.
The RSPO was founded by the World Wildlife Foundation (WWF), the
Malaysian Palm Oil Association (MPOA), and a group of major palm oil
producers and users including Golden Hope Plantations Berhad and
Unilever. The RSPO has the membership and support of a wide variety of
industry and NGO groups which give it the knowledge to implement sound
practices as well as the "teeth" to enforce these practices and truly
make a change in the way palm oil is grown, processed, and used.
The questions the RSPO is attempting to address are numerous and
extremely complex, but there is an answer and a solution is possible.
IRI intends to be a part of that solution. We will continue to
use palm
oil as a feedstock for biodiesel production and will gladly defend this
decision to critics who refuse to look at the true problems facing our
world and who instead focus on excluding an extremely versatile and
efficient crop for reasons more to do with ignorance and protectionism
than reality.
IRI has included the following language regarding sustainability in our
contracts with our first supplier of palm oil,
Cargill:
Seller and Buyer recognize that the
sustainability of palm oil
production is an important issue in the bio fuels market. Seller is a
member of the Roundtable on Sustainable Palm Oil ("RSPO') and will be
part of the pilot process to test the agreed criteria over the next two
years on one of its plantations. Buyer and Seller agree to exchange
information about the development of sustainability criteria for palm
oil production during the term of the Agreement. Seller agrees to offer
Buyer a range of options for sustainable palm oil supply as they become
available. Seller will work in good faith to develop the sustainability
of palm oil production according to the criteria relevant in the target
market of the product.
We will continue to require all future suppliers to be full and active
participants in the RSPO and ensure they implement the criteria as they
are developed and approved by the RSPO. This language provides
assurance that our partners, as well as ourselves, will continue to be
a part of the solution.
Above and beyond the language in the contract, IRI actively works with
the Corporate Social Responsibility departments and the Sustainable
Practices representative of the companies we contract with to ensure
each company is doing everything it can to use sustainable practices in
the production of palm oil as well as all oil seed crops.
The RSPO is developing a formalized system which all palm oil producers
can follow; however, many companies are implementing and have
implemented sustainable practices well ahead of the RSPO official
guidelines. These are the companies with which we do business.
A very tangible example of this is that we make every effort to source
palm oil from plantations on peninsular Malaysia and, when not
possible, from plantations which have been in existence since 1996 or
earlier. This is one way we can assure we do not buy palm oil grown on
recently destroyed virgin rainforest. The most severe sustainability
issues revolve around the destruction of virgin rainforest found in
East Malaysia and Indonesia.
IRI has made a strategic decision to take advantage of the benefits
offered by sourcing multiple feedstocks from around the globe. With
this decision comes risk. Instead of ignoring the second most traded
vegetable oil in the world, IRI is committed to exert extensive time
and energy to being part of the solution.
Renewable
Energy - Our Point of View
As a nation, we need to create a market for biofuels. We here at
Imperium Renewables believe that biodiesel is the right fuel for us to
pursue. Our nation and the world are starting a 500 lap race against
competitors who are starting at the 499 mile marker. The oil industry
is the most subsidized and politically entrenched industry in the
country. How so?
Whereas the average tax rate for companies in the US is about 18
percent, the oil industry is taxed at about 11 percent which equates to
a tax savings of about $1.5 billion in 2000 and more than $140 billion
since 1968. Unless the government will underwrite development of
alternative energy, it will be left to the private equity markets. And
no investor will back a company if there isn't a market for a product.
Today's biofuel efforts are just that - the beginnings of a new market
for which we need to prove there is demand.
If renewable energy could get even a fraction of the hundreds of
billions of dollars that the oil industry has enjoyed, and continues to
enjoy, we wouldn't even be talking about food vs. fuel. In fact, this
paper will discuss some of the exciting alternative feedstocks already
under development which will make this argument moot. The first thing
you need to understand, however, is that the use of today's agri-based
feedstocks is both necessary and likely temporary. We begin with some
facts.
The Truth about Today's Agri-based
Feedstocks
The base feedstocks for today's biodiesel are all vegetable oils. They
come from a range of seeds, including soybeans, rapeseed, mustard seed,
canola seed and palm. What most people don't know is that the oil we
use in biodiesel is a byproduct of crushing these seeds. With the
exception of palm oil, these seeds are primarily and initially
harvested for other uses.
The process involves crushing the seed and separating the non-oil
components (the "meal") for use in everything from packaged goods to
feed for livestock, and the oil, which has traditionally been used in a
variety of low-end consumer food products (like salad dressings) and
industrial products (like engine lube).
Currently, vegetable oil used in the production of biodiesel does not
supplant or divert oil used for food. Our industry is simply using the
supply of vegetable oil that is a byproduct of the existing market for
both meal and oil from these types of feedstock.
We are not even using all of the surplus that exists today. Each year,
more than 95 million tons of vegetable oil is produced in the world.
The biodiesel industry last year consumed 2.3 million tons worldwide,
or just 2 percent of our worldwide vegetable oil supply. Even
forecasted growth in our industry 10 years out shows us barely
exceeding the existing surplus.
And, as a nation, we have tremendous capacity to increase the
production of these feedstocks - without replacing or cannibalizing
existing crops. How? There are two opportunities. The first is simply
including crops such as mustard, canola or even high oil yield soybean
with other vegetable oil seeds as part of an existing crop rotation
program, either replacing placeholder crops or planting during a
typical fallow year. Studies have shown a 10 percent increase in the
yield of wheat crops in the year following the harvest of canola
crops.
Another potential solution is to plant bio-energy crops on lands
currently dormant as a result of the U.S. government's Conservation
Reserve Program (CRP), which aims to protect millions of acres of
American topsoil from erosion and which is designed to safeguard the
nation's natural resources.
Acreage enrolled in the CRP is planted to resource-conserving
vegetative covers, making the program a major contributor to increased
wildlife populations in many parts of the country. There's no reason
participants in this program couldn't plant soy or other feedstocks.
In Washington state alone, we have 2.5 million acres that have the
potential to support canola or mustard seed crops. Developing these
would be enough to provide the oil for our Grays Harbor plant.
Despite the
conjecture of those who oppose the use of these feedstocks
to create clean, renewable fuel, we are not taking food out of people's
mouths to power our cars. Far from it.
We are utilizing existing excess supply of vegetable oil and using it
to create environmentally-friendly fuel that will replace current
petroleum-based fuel.
The Truth about Energy Yield
There has also been much discussion about the energy yield of
biodiesel. Naysayers
claim that it still takes fuel to make biodiesel -
after all, you need fuel to drive the harvesters, crush the seeds and
deliver the oil to the production facility. That's true. But
that fuel
cost is amortized over a number of other uses - remember that the same
fuel is used to create meal and other products. In addition, carbon
that is emitted in the harvesting is then recaptured by the plants the
following year (since plants "digest" carbon to as part of the
photosynthesis process).
With petroleum fuels, you expend carbon to "harvest" the fuel, and then
expend it to burn the fuel -there is no recapturing. DOE, EPA and other
government agencies have put forth massive amounts of documentation
that shows the life cycle balance of biofuels (and biodiesel
specifically) provides a large reduction in greenhouse gases over
petroleum, even with the equipment, nitrogen and other petrochemical
usage included. Finally, biodiesel has been shown to have the highest
energy yield of commercially available renewable liquid fuels with a
whopping increase of 320%.
The Truth about Palm Oil
Imperium Renewables will use imported palm oil from Malaysia to produce
biodiesel in our Grays Harbor plant. There's been no shortage of
concern about the negative impact that palm oil plantations has had on
the rainforests of the world, specifically in Malaysia and Indonesia.
It is important to note two things related to this. First, the market
for palm oil has been strong well before biodiesel and would exist
without it. Second, the countries most able to export palm oil are
among the most destitute in the world. Palm oil represents an economic
boon to them.
This does not excuse the destruction of the environment - but it does
provide a frame of reference. After all, we in the United States did a
pretty good job of deforestation of our country when we settled it (and
some would argue, we still do). At Imperium, we believe that we can
positively affect the market for palm oil through collaboration across
the value chain. We are a member of a unique organization called the
Roundtable for Sustainable Palm Oil (RSPO www.rspo.orq).
Founded in 2001 by the World Wildlife Fund (WWF, www.wwf.org), the RSPO
is an association created by organizations carrying out their
activities in and around the entire supply chain for palm oil to
promote the growth and use of sustainable palm oil through co-operation
within the supply chain and open dialogue with its stakeholders. Its
key objectives are as follows:
* Research and develop definitions and criteria for the
sustainable production and use of palm oil;
* Undertake practical projects designed to facilitate
implementation of sustainable best practices;
* Develop solutions to practical problems related to the adoption
and verification of best practices
for plantation establishment and management, procurement, trade and
logistics;
* Acquire financial resources from private and public funds to finance
projects under the auspices
of the Roundtable on Sustainable Palm Oil;
* Communicate the Roundtable's work to all stakeholders and to a
broader public.
Why is palm oil so important to the
biodiesel industry?
Because it has the highest yield per acre (650 gallons) of any oilseed
and this is critical to keeping our costs competitive with
petroleum-based alternatives. There is, however, a catch. Biodiesel
created from palm oil does not perform as well in cold climates as it
does in warm climates. Therefore, palm oil can never be relied upon for
100 percent of the feedstock. Coincidentally, biodiesel based on
oilseed grown in colder climates like the US and Europe tends to
perform better in cold climates. We believe this is nature's way of
keeping us focused developing on next-generation feedstock. ...
New feedstock development
So far, we've discussed a few key insights to the biodiesel industry.
To recap: first, we need to prove there's a market for biodiesel, so we
are using first-generation, available biomass to create fuel that is
already at work in conventional diesel engines. The feedstock used to
create our fuel, is surplus oil obtained from a wide range of seeds and
plants which are already being harvested for other uses. We are also
taking steps to ensure that the feedstock is developed in a sustainable
manner.
But we know that long term, we need alternatives. Why? Because demand
for fuel will continue to increase, and eventually we won't have enough
land to produce feedstock. The good news is that we won't ever reach
that point. There are a number of promising alternatives to plant
biomass already being developed today. The most promising is algae.
That's right - algae.
Today, algae farms connected to coal plant smokestacks absorb carbon
dioxide as it exits the stack. The resulting emissions contain 40% less
C02 (a larger cut than the Kyoto treaty mandates) and 86% less nitrous
oxide. Because the algae grow so fast, a single acre can produce up to
15,000 gallons of oil. Compare that to palm oil's 600 gallons per acre
and soy's 60 gallons per acre and you can see why algae is the
feedstock of the future. But that's not all. A byproduct of the algae
can be used as feedstock for ethanol, so out of one smokestack you get
the building blocks for two renewable fuels.
What kind of scale are we talking about? Some estimates calculate that
just one 1,000 megawatt power plant using this type of system could
produce more than 40 million gallons of biodiesel and 50 million
gallons of ethanol a year. And based on the size of a plant and
surrounding real estate to host a tank farm, some believe that there
are up to 1,000 potential locations.
Do the math. That's a lot of fuel. Forty billion gallons per year to be
exact, and that's just for the United States.
And this is not a pipe dream. On November 30, 2006 a company announced
the results of a field test in Arizona. "This is the first time ever
that algae biomass created on-site by direct connection to a commercial
power plant has been successfully converted to both these biofuels,"
said Isaac Berzin, founder and Chief Technology Officer of GreenFuel,
one of several companies that develop this technology. "The conversion
and certification of the fuels were conducted by respected, independent
laboratories."
What's really amazing about this is the relatively short amount of time
it has taken to create this breakthrough technology. Who knows what
will be invented in the next 20 years?
One thing is
for sure - we won't be having this silly food vs. fuel
argument.
Renewable Energy and the Quadruple Bottom Line
Many people these days talk about the triple bottom line when they talk
about environmentally sustainable development or organic farming. They
mean that developing sustainable products or fostering sustainable
lifestyles have economic, social and environmental benefits. Imperium
Renewables believes that renewable energy, specifically biodiesel,
creates a quadruple bottom line. The fourth component it adds is
security.
* Economic: Biodiesel is a unique example of an industry that spreads
benefit across the entire value chain. In the case of our Grays Harbor
facility, more than 250 jobs are being created during the construction
phase with over 50 full time jobs at the plant once it opens. We expect
to become the state's largest purchaser of Canola oil grown by
Washington state farmers. Distributors and retailers blend biodiesel
with existing diesel or sell it unblended - either way fewer dollars
are leaving our state. Economies of scale will result in biodiesel
being priced at, or likely below, petroleum diesel, saving companies
and individuals money at the pump. In addition with Imperium Grays
Harbor in operation, it will produce 10% of Washington's diesel demand.
Washington exports over $25,000,000 per day in petrodollars. Imagine if
we can capture even a small portion and keep it right here in the
state. The National Biodiesel Board has calculated that for every
dollar that biodiesel is supported in federal tax dollars, $2.50 is
created and put back into the American economy.
* Social: Cleaner air, new jobs and reduced cost for energy all
positively impact communities around the country and the world.
* Environment: We've already discussed the positive environmental
benefits of biodiesel. Imagine how much better it will be in 20 years.
* Security: By increasing the production and consumption of renewable
fuels made in America, we can begin to reduce our dependence on
petroleum oil - regardless of its origins. This increases our physical
security from the instability caused by being reliant on countries and
leaders hostile to our country and our way of life. It also protects us
from the onset of global warming which will create massive disruptions
to our coastlines, our mountains and our very future.
It's Time to Get Going
The debate is over. The status quo is not an option. We can sit back
and watch our planet be plunged into an irreversible decline, fueled
either by a global war for a dwindling supply of oil or by the melting
glaciers, rising sea levels and drought-fed wildfires that will forever
change the landscape of our country. Or we can do something about it.
We're not sitting on the sidelines. Are you?
________________________________________________
Battle lines drawn in House over palm
oil
By Steven Friederich - Daily World Writer Tuesday, March 6, 2007
OLYMPIA —
Coastal Caucus legislators are scrambling to remove a last-minute
amendment that would prevent biodiesel companies like Imperium
Renewables from using the most popular kinds of palm oil. ''It's very
difficult to say we're opposed to drilling in ANWR — the Arctic
National Wildlife Refuge — but we're OK with cutting down
rainforests,'' said state Rep. Doug Ericksen
John Plaza, the president of Imperium Renewables, said on Monday that
he thinks the Legislature should focus on the farmers and leave the
biodiesel industry to manage where it gets the palm oil being used to
create biodiesel, itself. ''All of the language in our palm oil
contracts state that our palm must come from sustainable sources,''
Plaza said. ''Yes, losing the rainforest, it's a problem but the way to
solve the problem is to create and force change like we're doing.'' ...
''It is inappropriate for Washington to put in state legislation that
affects what happens in another country,'' Plaza replied. ''I don't
think that's the right answer." ''I would rather see the Legislature
incentivize Washington farmers, to get them to produce canola oil that
we could purchase. That's where their attention should be focused.''
... ''The state does not have the right to be in other government's
policies,'' he said. ''We need the most competitive edge possible
against petroleum and getting the state to help us achieve that is the
right thing for the state to do, not to prevent businesses from being
free market capable.''
www.thedailyworld.com/articles/2007/03/06/local_news/01news.txt
Palm-oil frenzy
taking toll By Les Blumenthal Seattle
Times (Sunday, March 11, 2007)
Oil palm growers, processors, traders,
users and several environmental
groups have formed the Roundtable for Sustainable Palm Oil, which is
developing regulations to ensure an eco-friendly supply of palm oil.
Imperium and other U.S. biodiesel manufacturers have joined the
roundtable. But some remain wary of the roundtable, and even Plaza is
frustrated by how long it's taking to develop sustainable standards.
An earlier report prepared for Friends of the Earth, a member of the
roundtable, found that the "actual on-the-ground impact of these
private-sector initiatives remains negligible at present." The report
went on to warn that the palm-oil industry may be incapable of
self-regulation. ...
Existing biodiesel plants and those on the drawing boards will easily
"soak up" all of the palm oil currently available, according to a
January report from the financial company Credit Suisse.
More than 85 percent of the world's supply of palm oil comes from two
nations — Indonesia and Malaysia. The rainforests on the islands of
Borneo and Sumatra are ground zero in the dispute over expanding palm
plantations.
The forests are logged and burned to make way for the plantations, at
times producing a thick blanket of smog that can cover parts of
Southeast Asia for weeks and release millions of tons of greenhouse
gases. The plantations also are moving into peat swamps, which are
drained. As the peat dries, it also releases tons of carbon dioxide.
The trend is accelerating.
Indonesia is already the third-largest producer of carbon dioxide in
the world, behind the United States and China. By 2015, an area of
Indonesia the size of West Virginia is expected to be covered with palm
plantations.
"It's absolutely disingenuous to suggest that biodiesel made from palm
oil is green or sustainable," said David Waskow, international program
director for Friends of the Earth.
http://seattletimes.nwsource.com/html/nationworld/2003612448_palmoil11.html
Seattle Post-Intelligencer (Thursday,
February 22, 2007)
Imperium and others believe that they will have to import vegetable oil
from overseas. Imperium's Grays Harbor plant, for example, will use
palm oil from Malaysia for about 20 percent of its production. That's a
big reason why Imperium has secured sites near deep-water ports.
http://seattlepi.nwsource.com/business/304638_imperium22.html
--
Henry Curtis, Executive Director, Life of the Land, 76 N. King Street,
Suite 203, Honolulu, HI 96817. phone: 808-533-3454. cell:
808-927-0709. Web Site:
http://www.lifeofthelandhawaii.org/ email:henry.lifeoftheland@gmail.com
“Destroying rainforest for
economic gain is like burning a Renaissance
painting to cook a meal.” Edward O. Wilson
Life of the Land is a
Hawaii-based, Hawaii-focused
environmental and community action group. Founded in 1970, the mission
of Life of the Land is to preserve and protect the life of the land
through sustainable land use and energy policies and to promote open
government through research, education, advocacy and, when necessary,
litigation. We believe that people are part of the environment. We are
known for research, research, research. We cover complex issues such as
genetic engineering, climate change, and quality of life issues. LOL is
a 501(c)3 charitable organization. We do not attend fundraisers,
testify for/against political and/or administrative candidates, nor do
we rank candidates. We work on issues not people.
Contact: Life of the Land, 76
North King Street, Suite 203, Honolulu, Hawaii 96817, Email:
henry.lifeoftheland@gmail.com Executive Director: Henry Curtis,
henry.lifeoftheland@gmail.com * Assistant Executive Director: Kat
Brady,
katbrady@hotmail.com