MEMORANDUM

TO: EPA Air and Radiation Docket EPA

- HQ

- OAR

- 2015

- 0111 FROM: Dallas Burkholder, Office of Transportation and Air Quality, US EPA DATE: November 2015 SUBJECT: Cellulosic Biofuel Producer Company Descriptions (November 2015)

The following contains a brief description of each of the companies that EPA believes may produce commercial scale volumes of RIN generating cellulosic biofuel by the end of 2016. These descriptions are based on a review of the publicly available information and informa tion provided to EPA in conversation s with company representatives.

Abengoa

Abengoa, a large international biofuels company, has developed an enzymatic hydrolysis technology to convert corn stover and other agricultural waste feedstocks into ethanol. Aft er successfully testing and refining their technology at a pilot

- scale facility in York, Nebraska as well as in a demonstration

- scale facility in Salamanca, Spain, Abengoa successfully constructed their first commercial

- scale cellulosic ethanol facility in Hugoton, Kansas. This facility was partially funded by a $132 million Department of Energy (DOE) loan guarantee. Abengoa held a grand opening for this facility in October 2014 1 , and conducted commissioning and start

- up operations throughout 2015. Abengoa currently has contracts in place for the majority of feedstocks necessary for the Hugoton facility for the next 10 years and successfully completed their first biomass harvest in the fall of 2011. The Hugoton plant is capable of processing up to 1,000 dry tons of corn stover per day, with an expected annual ethanol production capacity of approximately 25 million gallons. Abengoa plans to begin producing salable volumes of fuel at the facility in the fourth quarter of 2015.

Compressed Natural Gas (CNG) and Liquef ied Natural Gas (LNG) Producers

In July 2014 EPA approved, as part of the “Pathways II” rule, 2 a new cellulosic biofuel pathway for CNG and LNG derived from biogas produced at landfills, separated MSW digesters, municipal wastewater treatment facil ities, agricultural digesters, and biogas from the cellulosic components of biomass processed in other waste digesters. The production potential for this type of cellulosic biofuel is large and is expected to increase at a rapid pace due to the fact that m any U.S.

- based entities currently capture or produce biogas. This means that in many cases the construction of new facilities will not be required for facilities to begin generating cellulosic biofuel (D3) RINs. Instead, both new and existing facilities mu st register with the EPA under the RFS program and provide sufficient documentation to demonstrate that the CNG or LNG for which the RINs are being generated will be used exclusively as transportation fuel in the United States. This can be accomplished by fueling vehicles with CNG/LNG at the biogas production site or through the use of contractual mechanisms or appropriate affidavits, as prescribed in the

1 Abengoa. Abengoa Celebrates Grand Opening of Its First Commer cial

- Scale Next Generation Biofuels Plant

. N.p., 17 Oct. 2014. Web. 26 Mar. 2015.

2 79 FR 42128, July 18, 2014.RFS regulations. Additionally, to generate RINs for the CNG or LNG derived from biogas

companies must demonstrate that the biogas feedstock used was derived from a landfill, separated MSW digester, municipal wastewater treatment facility, agricultural digester or the cellulosic components of biomass processed in a waste digester.

The use of CNG and LNG a s a transportation fuel in 2016 is expected to be approximately 500 million ethanol

- equivalent gallons. 3 In projecting likely production volumes of RIN generating cellulosic CNG/LNG used in 2015 and 2016, EPA has reviewed the current rate of RIN generation for cellulosic CNG/LNG, the capacity and historic production rates of all facilities registered to produce renewable fuel from CNG/LNG, and company specific production projections provided to EPA by the industry. 4

Cool Planet Energy Systems

Cool Planet Energy Systems has developed a process to convert a variety of forms of cellulosic biomass into gasoline, diesel, or jet fuel blendstock as well as a bio

- carbon soil amendment co

product. Their proprietary process uses pressure and heat in a modified pyro lysis system to convert the cellulosic biomass to a hydrocarbon stream by passing the pyrolysis vapors across chemical catalysts. Cool Planet Energy Systems plans to deploy relatively small

- scale production units capable of producing between 5 and 10 milli on gallons of fuel and 25,000

- 50,000 metric tons of bio

- carbon per year that can be located near readily available sources of cellulosic biomass. Cool Planet Energy Systems’ first commercial

- scale facility will be built at the Port of Alexandria, Louisiana . The facility will be designed to produce at least 5 million gallons of cellulosic hydrocarbon blendstocks per year from wood residues. Cool Planet Energy Systems will likely not produce any cellulosic biofuel in 2015 or 2016.

DuPont

DuPont has developed an enzymatic process to convert corn stover into cellulosic ethanol. DuPont has invested hundreds of millions of dollars to develop this technology and since 2009 has operated a demonstration

- scale facility in Vonore, Tennessee. In add ition to developing technology for converting cellulosic biomass to ethanol, DuPont has been working with corn producers, equipment manufacturers, the U.S. Department of Agriculture, and Iowa State University to develop expertise in the collection, transpo rtation, and storage of the biomass

3 EIA Short Term Energy Outlook (STEO) April 2015. Natural Gas Vehicle Use from the Custom Table Builder (0.10 billion cubic feet/day in 2016). This projection includes all CNG/LNG used as transportation fuel from both renewable and non

- renewable sources. EIA does not project the amount of CNG/LNG from biogas used as transportation fuel.

4 Further detail on our projection of cellulosic biogas in 2 015 and 2016 can be found in “ November 2015 Assessment of Cellulosic Biofuel Production from Biogas (2015

- 2016)”, memorandum from Dallas Burkholder to EPA Air Docket EPA

- HQ

- OAR

- 2015

- 0111.feedstock for their cellulosic ethanol facility. On November 30, 2012, DuPont began the

construction of their first commercial

- scale cellulosic ethanol facility in Nevada, Iowa. This facility is designed with a producti on capacity of 30 million gallons of cellulosic ethanol per
year. A grand opening of this facility was held on October 30, 2015 . EPA expects commercial

scale production to commence sometim e in the fourth quarter of 2015.

Edeniq

Edeniq has developed a proprietary process that would allow corn ethanol producers to generate cellulosic ethanol from corn kernel fiber at the corn ethanol producers’ existing production facilities. Their process involves the addition of the CellunatorTM, a prop rietary milling technology designed to increase the uniformity of the feedstock particles, along with a combination of enzymes to convert the cellulosic material in the corn kernel into sugars and ultimately cellulosic ethanol. Several commercial plants ar e currently using the Cellunator technology to increase their yields of ethanol from starch. Edeniq has been testing their technology, including both the Cellunator and the additional enzymes, at a demonstration

- scale facility in Visalia, California since June 2012 and announced in May 2013 that they had successfully completed a trial run at this facility with a continuous run time of greater than 1,000 hours. Edeniq has also run successful short term trials at commercial corn ethanol production facilities. In the July 2014 “Pathways II” rule EPA clarified that processes, such as the one developed by Edeniq, that convert corn kernel fiber into transportation fuel are approved to generate cellulosic RINs. 5 Edeniq anticipates their technology will be used to p roduce commercial scale volumes of cellulosic ethanol at existing corn ethanol facilities beginning in the second half of 2015 and at an increasing number of facilities through the end of 2016. 6

Ensyn

Ensyn owns and operates a technology known as Rapi d Thermal Processing that involves the

non

- catalytic thermal conversion of carbon

- based solid feedstocks to liquid products. Ensyn’s technology has successfully operated commercially for over 25 years. It is currently deployed in five commercial facilities in Wisconsin for the production of specialty chemicals and heating fuels, and Ensyn recently expanded their production capacity with the opening of a new facility in Ontario, Canada. Ensyn’s primary fuel product, renewable fuel oil (RFO), is sold commerci ally in the US as a replacement for heating oil. Ensyn registered its Ontario facility under the RFS program in 2014 and has generated cellulosic diesel (D7) RINs related to sales of RFO as a replacement for heating oil to clients in the United States. Ens yn is currently acquiring additional customers for RFO and plans to increase the volume of RFO exported to the United States. For the purposes of projecting a volume of cellulosic biofuel produced by Ensyn in 2015

5 79 FR 42128, July 18, 2014

6 More information on Edeniq’s commercialization plans has been placed in the docket at “ September 14 Email from Jim Kacmar, Edeniq containing projected cellulosic biofuel production for 2015 and 2016 (CBI)”, memorandum from Dallas Burkholder to EPA Air Docket EPA

- HQ

- OAR

- 2015

- 0111.and 2016 EPA is only considering the volum e of RFO from Ensyn’s Ontario facility that is

eligible to generate RINs, not the full expected production volume of Ensyn’s facilities.

GranBio

GranBio uses an enzymatic hydrolysis process to convert cellulosic biomass into ethanol using the PROESA pre

- treatment technology developed by Beta Renewables

. Construction of their first cellulosic ethanol production facility was announced in mid

- 2012 POET, and financing was completed in May 2013. In September 2014 the facility announced that they had begun
pr oducing cellulosic ethanol at this facility. The facility uses sugarcane basgasse as a feedstock and produces both ethanol and electricity. The facility is located in Sao Miguel dos Campos

, Alagoas, Brazil and has a production capacity of 82 million lite rs of ethanol per year

. Company representatives indicated that GranBio plans to begin exporting cellulosic ethanol to the United States in the second half of 2016. GranBio’s facility is currently registered as a cellulosic biofuel producer under the RFS program, and any cellulosic ethanol exported to the United States would be eligible to generate cellulosic biofuel (D3) RINs.

INEOS Bio

INEOS Bio has developed a process for producing cellulosic ethanol by first gasifying cellulosic feedstocks into a s ynthesis gas (syngas) and then using naturally occurring bacteria to ferment the syngas into ethanol. On February 9, 2011, INEOS Bio broke ground on their first commercial

- scale facility in Vero Beach, Florida. The facility is designed to produce 8 million gallons of cellulosic ethanol per year. INEOS Bio announced that they had completed construction on this facility in June 2012 and began full commissioning of the facility. On July 31, 2013, INEOS Bio announced they had begun producing cellulosic ethanol at commercial scale from their Vero Beach facility. In September 2014 it was reported that INEOS Bio was producing very little ethanol at their facility and planned to undertake efforts to increase the quality of the syngas in order to increase the plant p roductivity. 7 INEOS Bio has completed construction on the required syngas clean

- up modules and expects to begin producing commercial

- scale volumes of ethanol in 2016

.

POET

- DSM Advanced Biofuels

POET

- DSM Advanced Biofuels uses an enzymatic hydrolysis p rocess to convert cellulosic biomass into ethanol. POET, one of the largest ethanol producers in the U.S., has invested in the development of cellulosic ethanol technology for more than a decade and began producing small volumes of cellulosic ethanol at pi lot scale at their plant in Scotland, South Dakota in late 2008. In January 2012, a joint venture was formed between POET and the international biotech company Royal DSM of the Netherlands, called POET

- DSM Advanced Biofuels, to commercialize and license th eir cellulosic ethanol technology. The joint venture’s first

7 INEOS Bio Making Little Cellulosic Ethanol at US Plant. ICIC News. September 5, 2014. Accessed online <http://www.icis.com/resources/news/2014/09/05/9818462/ineos

- bio

- making

- little

- cellulosic

- ethanol

- at

- us

- plant/>commercial

- scale facility, called Project LIBERTY, is located in Emmetsburg, Iowa. This

facility is designed to process 770 dry tons of corn cobs, leaves, husks, and stalks per day into cellulosi c ethanol. The facility is projected to have an annual production of approximately 20 million gallons per year, later ramping up to 25 million gallons per year. 8 Construction of the facility began in March 2012. On September 3, 2014, POET

- DSM held a grand opening for Project Liberty to mark the commencement of the start

- up of the facility. Based on conversations with representatives of POET

- DSM, EPA expects production of commercial scale quantities of cellulosic ethanol from Project LIBERTY to begin in the fourth quarter of 2015.

Quad County Corn Processors

Quad County Corn Processors (QCCP) have developed a bolt

- on technology called Adding Cellulosic Ethanol or ACE for existing dry grind corn ethanol plants to enable them to produce cellulosic ethanol from corn kernel fiber. QCCP claims that their technology can increase ethanol yields by 6% through the conversion of the cellulose, hemicellulose, and lignin present in the corn kernel fiber. They also expect that their process will result in significantly increased corn oil yields and increase the protein cont ent of the distillers grains coproduct. The ACE technology uses a post

- processing approach, first fermenting the starch present in the corn kernel, and then using their proprietary technology to process and ferment the remaining cellulosic portions. QCCP b roke ground on the bolt

- on ACE process in the summer of 2013. On July 2, 2014, QCCP announced that they had completed construction and begun producing cellulosic ethanol from their Galva, Iowa facility using the ACE technology. 9 The facility is designed to be capable of producing approximately 2 million gallons of cellulosic ethanol per year. 10

8 “Construction remains on schedule for P oet

- DSM’s first commercial cellulosic bio

- ethanol plant.” December 23, 2013. Article available online at http://www.poet.com/pr/construction

- remains

- on

- schedule

- for

- project

- liberty. Accessed May 1, 2014.

9 “Quad County begins cellulosic ethanol production” Ethanol Producer Magazine, July 2, 2014. Accessed online on August 5, 2014. Available at <http://www.ethanolproducer.com/articles/11212/quad

- county

- begins

- cellulosic

ethanol

- production>

10 Ibid