MEMORANDUM

TO: EPA Air and Radiation Docket EPA-HQ-OAR-2015-0111

FROM: Dallas Burkholder, Office of Transportation and Air Quality, US EPA

DATE: April 15, 2015

SUBJECT: Cellulosic Biofuel Producer Company Descriptions

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 information 

provided to EPA in conversations 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. After 

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 20141, and conducted commissioning and start-up 

operations throughout the winter of 2014/2015. 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 spring of 2015.

Compressed Natural Gas (CNG) and Liquefied Natural Gas (LNG) Producers

In July 2014 EPA approved, as part of the “Pathways II” rule,2a new cellulosic biofuel 

pathway for CNG and LNG from biogas produced at landfills, separated MSW digesters, 

municipal wastewater treatment facilities, 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 many 

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 must 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 Commercial-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 as a transportation fuel in 2016 is expected to be approximately 500 

million ethanol-equivalent gallons.3In 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/LNG4, and company specific production 

projections provided to EPA by the industry.5

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 pyrolysis 

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 million 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 anticipates beginning construction on the first module of this facility in 2015 and 

producing a small volume of fuel at the facility in the second half of 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 addition 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, transportation, 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 For a list of all facilities registered to generate cellulosic biofuel RINs using biogas as a feedstock see “List of 

Registered Cellulosic Biofuel Producers in March 2015”, memorandum from Dallas Burkholder to EPA Air Docket 

EPA-HQ-OAR-2015-0111.

5 Further detail on our projection of cellulosic biogas in 2015 and 2016 can be found in “Assessment of Cellulosic 

Biofuel Production from Biogas (2015-2016)”, memorandum from Dallas Burkholder to EPA Air Docket EPA-HQOAR-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 production capacity of 30 million gallons of cellulosic ethanol per 

year. Mechanical completion of the facility is expected to be achieved in the spring of 2015, 

followed by a period of commissioning. Based on conversations with DuPont representatives, 

EPA expects commercial-scale production to commence sometime in the third 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 proprietary 

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 are 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.6 Edeniq anticipates their technology will be used to produce 

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 2016.7

Ensyn

Ensyn owns and operates a technology known as Rapid 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 

commercially 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. Ensyn 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 

 

6 79 FR 42128, July 18, 2014

7 More information on Edeniq’s commercialization plans has been placed in the docket at “Email from 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 volume of RFO from Ensyn’s Ontario facility that is

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

INEOS Bio

INEOS Bio has developed a process for producing cellulosic ethanol by first gasifying 

cellulosic feedstocks into a synthesis 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 productivity.8 INEOS Bio has completed 

construction on the required syngas clean-up modules and expects to begin producing 

commercial-scale volumes of ethanol in the second quarter of 2015.

POET-DSM Advanced Biofuels

POET-DSM Advanced Biofuels uses an enzymatic hydrolysis process 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 pilot 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 their cellulosic ethanol technology. The joint venture’s 

first 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 

cellulosic 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.9 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 third quarter of 2015.

Quad County Corn Processors

 

8

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/>

9

“Construction remains on schedule for Poet-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.
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 content 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 broke 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.10 The facility is 

designed to be capable of producing approximately 2 million gallons of cellulosic ethanol per 

year.11

 

10 “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-cellulosicethanol-production>

11 Ibid.