The distributed control system (DCS) is the brain of any manufacturing plant, providing the intricate knowledge and responsiveness needed to keep production running smoothly. For many plants, the decision to upgrade a DCS is often made well beyond the life of the system, when operations are starting to fail or falling behind current technology. So how do plant managers know when it&rsquo;s time to upgrade? Here are some key points to consider. Success with Partners: The best DCS upgrades are done through planning ahead with both the manufacturer and a solution partner&mdash;an integrator with a long-standing relationship with manufacturers, in product availability and the latest technology. Knowing the direction a DCS manufacturer is moving and the technology it provides is critical. It&rsquo;s not wise to invest in a control system manufacturer that has no long-term strategy. It&rsquo;s important to build a relationship with the manufacturer to know its long-term product strategy and how it plans to get the most updated hardware and software for a facility. Try to stay ahead of obsolescence and systems that have high cost of ownership.&nbsp; Solution partners typically have lower overhead than the manufacturer and will offer options in product integration rather than representing only one product line. Security Concerns: Viruses and ransomware have become a real concern for every business. Having a secure network, anti-virus servers, latest security patches and flash-able DCS hardware can secure plant operations. Many manufacturers offer software subscription services for annual fees that keep systems secure with updated software patches. Plant managers might be tempted to avoid these fees, but they could be the difference between secure systems and hackable software. New Technology: Newer doesn&rsquo;t always mean better, but in control system technology, even a few years of innovation can provide enhancements and improvements for plant operation. Most manufacturers now include multivariable predictive control (MPC) and advanced regulatory control (ARC) as part of the controllers. The human-machine interface (HMI) will allow team members to visualize sequences and interlocks right on the operators&rsquo; screens. Often, several old controllers might be replaced with one new, more powerful controller. Having an OPC-compliant system allows for flexible interfacing to any third-party data analysis package and historian servers. It is now easier than ever to have a read-only web interface view of process graphics available anywhere online. Cost and Maintenance: As a DCS matures or is slated for obsolescence, cost for those products tends to rise at an alarming rate. Delaying an upgrade can lead to increases in both cost and deliverability of a product. With an outdated DCS, downtime is further complicated by waiting for replacement parts that might no longer be available through the manufacturer. Finding parts from third parties is challenging and the reliability of the parts is often questionable. Obsolescence of Current DCS: If a plant&rsquo;s operating system is obsolete, what are the next steps? First, don&rsquo;t panic. Chances are the current vendor has a product solution or competitors have a product strategy to upgrade an old system. Start asking questions of vendors or a solution partner, but make sure the current system is factually represented, and itemize performance issues. The more information provided up front, the better manufacturers and integrators can help design a DCS strategy for a specific plant. Approach Options Two common approaches exist for upgrading a DCS: &bull; Phased-in The phased approach spreads the upgrade out over several years. The first step is usually the HMI. The servers and operator interface are changed, leaving the main control system and inputs and outputs in place.&nbsp; Later, the controllers and inputs and outputs are replaced, resulting in an entirely new system. Advantages include lower process interruption risk, cost spread out over time and less interruption for operators. Disadvantages include delayed implementation of control technology, as well as 10 to 20 percent higher cost than a full DCS replacement because of multiple visits to a facility and possible manufacturing price increases. &bull; Full Replacement A full DCS replacement involves shutting off the current system and replacing it with a new one. This method requires extensive planning. In most cases, plants experience several days of downtime to make the full transition, followed by several days of onsite training for operators. Advantages include reduced cost, full access to the most updated technology and a robust, new platform. Disadvantages include operational disruption, and new vendor and integrator relationships. Most important in a DCS replacement is to do the research. Every ethanol plant will eventually need a new DCS and it&rsquo;s not wise to wait until a system is on life support. Small failures can roll into catastrophic failures, so developing an upgrade plan with foresight will help reduce downtime during a system migration and eliminate maintenance cost pile-ups. Work with a current manufacturer and find a trusted independent systems integrator to customize the best solution for any site. Being proactive with upgrading an operating system will keep business in business, continuing to meet the needs of customers. Author: Jason Hurst CEO, Trident Automation jhurst@tridentautomation.com

INNOVATIVE INTERFACE: New technologies in distributed control systems allow operators to visualize sequences and interlocks. Trident Automation provides a checklist of factors to consider when contemplating a new DCS. 

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FROM THE OCTOBER ISSUE: Distributed control systems continuously evolve. Trident Automation has tips for staying current and efficient. 

DCS Upgrade Detailed

Most new trends in the ethanol industry come to roost in the ethanol lab, where process monitoring, product quality control and new technology assessments keep the small staff busy. Implementing new enzymes or yeasts means running baseline tests and then verifying relatively small changes in yield, requiring precise and accurate measurement. The Food Safety Modernization Act means new levels of monitoring for distillers grains. And, in many cases, the move toward exporting ethanol to new countries means new specifications. All the changes add up to increased pressure on the ethanol plant laboratory, says Kristy Moore, principal of KMoore Consulting. &ldquo;I&rsquo;m being asked by boards to give the perspective on what it&rsquo;s going to take to get into export markets,&rdquo; she says. &ldquo;They have to realize that for all these years we&rsquo;ve been making fuel ethanol with ASTM grade, and that&rsquo;s it. Now, we&rsquo;re going to add two, or even five, new product codes. We&rsquo;re going to have additional testing, education and training on new pieces of equipment and new expectations. And we&rsquo;re going to have to know how to anticipate new product influences.&rdquo; Moore says that while exporting ethanol is similar to loading unit trains in the Midwest bound for Canada or New York, the process utilizes many new steps. &ldquo;It&rsquo;s going to leave the Midwest ethanol plant, on a rail car to a port, offloaded into a storage tank, loaded into a vessel. And the vessel is going to travel 10,000 miles and go into a port in China, India, Malaysia or Indonesia. It&rsquo;s going to be tested on ship before it&rsquo;s offloaded, and that&rsquo;s where the money exchanges hands.&rdquo; Then there are additional miles as the product is moved to its final destination. &ldquo;We&rsquo;re going to have to make sure our plants are operating at a level of precision, that our testing and results are spot on and accurate, because you can&rsquo;t afford to bring that product back,&rdquo; Moore says. In many of the target export markets, brand new specifications are being written, Moore points out. &ldquo;We&rsquo;re going into markets where ethanol has never been used. Many countries are very excited about developing an ethanol market, as it&rsquo;s important to agriculture. But, a lot of times, they are starting from scratch and don&rsquo;t have any ideas about specifications or test methods.&rdquo; Some are using ASTM specifications as a guide, others looking to ISO or even Brazilian specs. &ldquo;What we find is there&rsquo;s different water specs or acidity specs, additional testing like conductivity or for higher alcohols or phosphorus. We&rsquo;re seeing all these different parameters, partly because they&rsquo;ve had no experts from the ethanol industry help them or educate them. They write these specifications as best they can, and it&rsquo;s become a melting pot.&rdquo;&nbsp; Not only is there no global ethanol standard, there&rsquo;s no global gasoline standard, she adds, and it&rsquo;s often complicated by differing approaches to how beverage alcohol is handled. In the case of Mexico, she points out, the country struggled over whether to allow a denaturant, but ultimately chose to. &ldquo;They understood our argument that allowing the same fuel ethanol as used in the U.S. would be very good for their gasoline markets and also protect their beverage alcohol market.&rdquo; With the additional liability in export shipments, Moore suggests plants consider reinvesting in their laboratories. &ldquo;I do think we&rsquo;re going to need to step up our game at the plant in laboratories. Think of the risk in sending our products 10,000 and 20,000 miles away. There&rsquo;s pressure to know that certificate of analysis has to be absolutely accurate.&rdquo; And plants need to understand some of the changes required for different markets, such as turning off the denaturant for product for Brazil. While that&rsquo;s simple enough, Brazil also has a lower water spec, which means tweaking distillation. Other countries have a different acidity specification, which might require running a degasser, or using a corrosion inhibitor with a different buffering agent for pH. &ldquo;There&rsquo;s all kinds of things that we may have to do in order to produce product on spec for these other countries,&rdquo; she says. And often, the laboratory is where work is done to understand and implement the new product specification. Third-Party Role Monthly certification of an ethanol lab&rsquo;s product tests is routine in the industry, and can even be done weekly in some cases, says Brent Pohlman, president of Midwest Laboratories. The company is seeing an uptick in ethanol plant clients, partly because demands are increasing as equipment is aging out. &ldquo;We&rsquo;re seeing increased volume right now because plants can&rsquo;t keep up with buying new equipment in their own labs,&rdquo; he says. &ldquo;We get more clients just because they are checking their equipment. We know that instrumentation over time sees wear and tear, and especially with samples of ethanol.&rdquo; Midwest Labs updated all its ethanol testing equipment in the past three years. &ldquo;The life span of equipment is five to 10 years. A lot of plants send more samples, thinking they can get a few more months out of their equipment. And, I think we&rsquo;re seeing it now because 10 years ago, everyone had new equipment.&rdquo; Plants can buy some time on purchasing a new piece of equipment that perhaps costs $70,000 by outsourcing tests at $50 or $60 each, he says. &ldquo;But only if the turnaround time works.&rdquo; Timeliness has been aided by a major change in shipping regulations. Until the past year, any amount of ethanol was considered a hazard material and required special training and paperwork to ship. Those rules have been relaxed, Pohlman says, meaning small quantities of ethanol are no longer considered hazmat. Speedy shipping for samples is critical when third-party analysis is needed to confirm a plant&rsquo;s results, he says. &ldquo;Most of the time there&rsquo;s ethanol waiting to be shipped or received.&rdquo; Pohlman notes two other trends in the ethanol industry. &ldquo;We are seeing an increase in research and development,&rdquo; he says. The plant&rsquo;s laboratory can remain focused on day-to-day production, &ldquo;and we can be that outsourced facility in research and development where they&rsquo;re trying to do new techniques or developments in their process. &ldquo;On the DDG side, one thing that&rsquo;s kind of new is nutritional labeling,&rdquo; Pohlman says. He suspects it&rsquo;s partly because customers start with an approximate fiber analysis, but ultimately decide the label needs upgrading. &ldquo;Nutritional labeling is not cheap. It can cost anywhere from $500 to $1,000 per test. But they&rsquo;ll do that for marketing, trying to get the most out of their coproduct.&rdquo; Besides the need for upgraded labeling when marketing low-oil or low-fiber DDGS to new customers, Moore explains that the U.S. Food and Drug Administration upgraded its regulations under FSMA. &ldquo;They now treat animal feed products as food,&rdquo; she says. &ldquo;Our plants are generating food products with food-grade analysis.&rdquo; FSMA, coproduct innovations and ethanol exports merge in the ethanol laboratory. &ldquo;The pressures on our laboratories are growing,&rdquo; Moore says. While lab managers are sometimes viewed as the &ldquo;police to find things out of spec, the lab is more of a tool. But just like all tools, you&rsquo;ve got to keep the technology current. You&rsquo;ve got to keep the training current.&rdquo; Author: Susanne Retka Schill Freelance journalist retkaschill@yahoo.com

INVESTMENT OR EXPERTS: Midwest Laboratories has seen an increase in ethanol clients, as plants turn to commercial labs for product testing in lieu of investing in updated lab equipment. Proper specs have become more crucial, as new export markets ope

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KNOWLEDGE AND KNOW-HOW: Lisa Avila, team leader for alternative fuels at Midwest Laboratories, conducts a product test, which is done at ethanol plants monthly or even weekly. With such a rigorous routine, many plants are turning to professional labs

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THE SCALE OF SPECS: Nutritional labeling on DDGS has become more popular, prompting more lab testing and accurate reads of contents.

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FROM THE OCTOBER ISSUE: Growing export markets and new coproduct lines are increasing demands on the ethanol laboratory.   

Pressure to Perform

Plant morale is about making sure employees feel involved and ensuring management has a proper understanding of every employee in an ethanol facility, says Danielle McCormick, principal for K&middot;Coe Isom. If leaders are only looking to maintain morale, they&rsquo;ve already lost the battle, she says. &ldquo;It&rsquo;s important to focus on growing morale.&rdquo; A big part of plant morale is ensuring leaders are connected to their individual employees&mdash;the employees feeling they work for a specific person versus the plant itself, McCormick says. &ldquo;There&rsquo;s a few things I typically recommend to leaders, such as having regular check-ins with the team to ask them how they&rsquo;re doing and how they can help, or ensuring that recognition is based on the individual and it&rsquo;s personalized. It&rsquo;s about really understanding the team and understanding what will be the most meaningful to them.&rdquo; Jeff Zueger, CEO at Midwest AgEnergy Group LLC in Bismarck, North Dakota, would add that pride in the product and awareness of the company&rsquo;s financial standing provide a crucial morale boost, too. &nbsp; Creating Value Plant morale begins with outlining goals and strategic direction. &ldquo;We look at if they have a clearly defined strategic plan,&rdquo; McCormick says. &ldquo;With that, we want to make sure they have the right people in place to accomplish their goal or we&rsquo;ll help them with a different kind of recruiting strategy.&rdquo; Richard Hanson, plant manager at Arkalon Ethanol LLC in Liberal, Kansas, which is part of Conestoga Energy Partners LLC, says hiring great candidates is a good place to start. Finding better candidates and keeping them involved helps morale, he adds. K&middot;Coe helps to ensure facilities&rsquo; training and talent development systems are well in place so their leaders are trained to be effective and employees have the proper opportunities to advance their skills. K&middot;Coe even provides training for employees on site, McCormick says. &ldquo;We also do a lot of executive coaching for leaders who might have been solid technical experts as they came up through the plant, but they didn&rsquo;t necessarily know how to grow their people.&rdquo; Arkalon emphasizes additional training for its employees, sending operators to outside training provided by Lallemand, Novozymes and other vendors, Hanson says. &ldquo;They come back with a lot of good ideas and they pass what they learned at the conferences along to the other operators. It helps by saying we&rsquo;re reinvesting in them to get them more knowledge. &ldquo;We also have a full-time employee who does training,&rdquo; Hanson adds. &ldquo;So, a new person coming into the plant will spend seven to eight weeks with this operator going through the plant at a high level and then digging down into other areas to give them the knowledge and expertise to perform that job up to the expectation everyone has. That helps that employee not feel like they&rsquo;ve just been thrown to the wolves.&rdquo; Zueger says Midwest AgEnergy handles employee advancement in a similar manner, creating growth opportunities. The program allows employees to advance in their field without attrition of coworkers, through multiple levels of qualifications, including operations, maintenance, yard operations or accounting. &ldquo;Our viewpoint is, if everybody gets to the highest level in any of these areas, it&rsquo;s good for our company,&rdquo; he says. &ldquo;We have higher-performing folks that are adding value so we&rsquo;re compensating them for that.&rdquo; Midwest AgEnergy, the parent company of Dakota Spirit AgEnergy in Spiritwood, North Dakota, and Blue Flint Ethanol in Underwood, North Dakota, won Workplace of the Year in Ethanol Producer Magazine&rsquo;s 2018 Ethanol Producer Awards. Pillar of Positivity For Zueger, creating a positive culture and work environment for employees is the pillar of plant morale. Midwest AgEnergy encourages employees to be &ldquo;active participants in continuous improvement&rdquo; via Kaizen team events, Zueger says. &ldquo;We empower our employees and we hold them accountable. They&rsquo;re able to make real-time work decisions around their area of influence and if they have an idea they think would improve what they&rsquo;re doing, we want them to submit a Kaizen or escalate one so we can evaluate that opportunity and implement it.&rdquo; Kaizen events are short-duration projects with a specific aim for improvement. Typically, they last a week and are led by an outside facilitator with the implementation team being predominantly members of the area in which the Kaizen event is being conducted, plus a few additional people from support areas and even management. Midwest AgEnergy encourages point-to-point communication between employees and supervisors, Zueger says. &ldquo;We want folks interacting directly with each other, giving each other both coaching and positive feedback on how they can get better and we can get better as a company. We want our employees to be empowered to be a part of our success.&rdquo; K&middot;Coe can provide a consultation for a facility on how to improve morale, using specific tools and methods. One such tool is a behavioral assessment called DiSC, McCormick says. &ldquo;It involves coming in and getting their leadership team and employees together to get a better understanding of their unique behavioral styles, so they can communicate more effectively with one another, which will help minimize conflict and speed everything up in building trust.&rdquo; DiSC stands for dominance, influence, steadiness and conscientiousness, which represent the four different dimensions of behavior. It involves an individual assessment of employees that K&middot;Coe then interprets in a group setting, McCormick says. &ldquo;We use it as a coaching tool for people to become more self-aware of their natural tendencies.&rdquo; Another crucial part of creating a positive culture is ensuring morale is effectively managed from a labor perspective, including a safe work environment and appropriate staffing and shift lengths, McCormick says. &ldquo;If people are constantly working overtime or they&rsquo;re working six days in a row, they&rsquo;re more likely to have fatigue or injuries, or just grow tired of what they&rsquo;re doing.&rdquo; &lsquo;Spokespeople of Our Industry&rsquo; Zueger says ethanol plant employees might experience low morale for any number of reasons, including criticisms of the industry or the fuel itself. &ldquo;Some of the press and opposition the ethanol industry faces is different than other industries. If you go to your family reunion and your uncle is badmouthing ethanol, that takes the pride out of it. We need to inform our employees, so they can talk with those family members and others in their community about the benefits of ethanol and not be afraid to speak up. We have to give them the tools to be spokespeople of our industry.&rdquo; If employees don&rsquo;t understand how their goals and daily contributions can help drive the business, morale can sink quickly, Zueger says. &ldquo;Having folks be proud of what they&rsquo;re doing and talking a lot about the products we produce keeps them informed so they know we&rsquo;re not standing still and we&rsquo;re focusing on growth and diversification. &ldquo;We share all of our financials, forward business objectives, strategies, goals, company KPI&rsquo;s (key performance indicators) with our employees directly,&rdquo; he says. &ldquo;They know our profitability levels, profitability objectives, all of our metrics that are important to our organization. We keep those in front of everybody. Having folks know what our objective was for today, tomorrow, next week and yesterday is very important to us.&rdquo; Sharing financials with employees does carry some potential pitfalls, though. During down times, the employees can see those declining numbers and they don&rsquo;t have as much influence on the market opportunities the company is presented with, Zueger says. &ldquo;So, they&rsquo;re working just as hard and from a financial perspective, the company isn&rsquo;t seeing the rewards of that effort. During those times, you need to do more work to ensure your employees are engaged, they know your strategy and they don&rsquo;t feel threatened by a compression of margins, so they know we&rsquo;re in this for the long haul.&rdquo; McCormick says culture is the critical component of morale during a down time. If leaders are in a space where they&rsquo;re focused on positive culture, not just profits, morale will benefit, she says. &ldquo;In a downturn, it comes down to a leadership commitment to always making sure culture is top of mind. Culture and morale need to be looked at just as heavily in order to maintain a good culture in good times and tough times.&rdquo; &nbsp; Author: Tim Albrecht Associate Editor, Ethanol Producer Magazine

CONSCIOUS OF CULTURE: Recognizing employees regularly for their contributions helps improve plant morale. The maintenance department at Blue Flint Ethanol in Underwood, North Dakota, was recently given an award for being safety role models. Front, fr

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SWEET TREAT: Blue Flint Ethanol employees enjoy banana splits in March during employee appreciation week at the Underwood, North Dakota, facility.

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WORTHY OF PRAISE: Employees at Blue Flint Ethanol, Underwood, North Dakota, gather for 
lunch as a reward for hard work and long hours put in during the June 2018 shutdown.

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TWO-TIME WINNERS: Adam Dunlop (left), regulatory and technical services director, and Dave Miller, yard operations coordinator, accept the Canadian Pacific Safe Shipper Awards for 2016 and 2017 at Blue Flint Ethanol in Underwood, North Dakota.

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FROM THE OCTOBER ISSUE: Managing employee morale requires offering opportunities for advancement and keeping employees informed about the companies' successes.   

Pride in Product and Profits

Automation experts estimate perhaps half the ethanol industry has migrated to newer, more powerful distributed control systems (DCS). Many of the older systems remaining are getting extended lives, however, through targeted advanced regulatory controls. DCS migration is a big project&mdash;financially and systematically&mdash;comprised not only of computer upgrades but new sensors and software. &ldquo;It&rsquo;s a large system connected to 3,000 individual sensors that have to be replaced,&rdquo; says Carson Merkwan, business development manager for Direct Automation. &ldquo;We do it in two days and check it out and they&rsquo;re ready to go.&rdquo; Advanced control systems forestall the need for the big migration project, reducing cost and targeting the application. &ldquo;Advanced process control is a very powerful tool that&rsquo;s been around a while,&rdquo; Merkwan says. &ldquo;And it&rsquo;s a lot less expensive than it used to be. It used to cost $1 million and now is about $50,000 for targeted areas.&rdquo; &ldquo;What we&rsquo;ve seen as a trend in recent years is plants utilizing existing control architecture more, without resorting to third-party controls, but pulling some of that advanced control into the DCS controller,&rdquo; explains Rick Tenor, product management lead at Trident Automation. While 10 years ago, the advanced controls were considered mostly for the larger, 100 MMgy plants, the development of a modular approach has made it technically and financially feasible for midsize plants, says Gary Jubien, senior product marketing manager at Honeywell. &ldquo;There&rsquo;s a minimum level where you have to be able to write from a computer and control a set point. If that can&rsquo;t be done, you can&rsquo;t implement, but a lot of systems will support that.&rdquo; Basics to Advanced Every plant has basic automation with multiple proportional integral derivative (PID) loops. Jubien likens a PID loop to cruise control in a car. The basic automation offered by single PID loops are often linked in cascade loops where one PID controls a second loop. PIDs are reactive, however, compared to advanced controls that learn key upstream indicators and respond more quickly. Tenor explains the difference using the example of dryer temperature control. &ldquo;As long as everything is stable and you have a steady flow coming in and there&rsquo;s nothing disturbing your system, it&rsquo;s pretty easy to control the temperature in the dryer with a simple control loop. But let&rsquo;s say, for some reason, the flow going through centrifuges increases 20 percent, introducing more cold product into the dryers. It&rsquo;s going to drop the temperature, which the loop is going to see. It will crank up the natural gas to increase the temperature, probably overshoot and get things a little too hot for a while before coming back down.&rdquo; That sort of temperature variability can make it difficult to maintain consistent moisture in the DDGS, he says. &ldquo;But if you knew that change in flow was coming before it happened, then you can compensate by increasing temperature a little bit in advance and try to keep up as it happens. You can keep the temperature in the dryer nice and even and your product moisture isn&rsquo;t going to change all that much. That&rsquo;s what we can do with advanced regulatory control&mdash;use that feed coming out of the centrifuge as an indicator that something&rsquo;s going to change and react before it happens.&rdquo; Besides the dryers, two other areas that are good targets for advanced controls include slurry to maintain the optimal ground corn-to-water ratio, and in distillation to maintain temperature differentials.&nbsp;&nbsp; Honeywell documented the benefits of advanced controls installed at one 50 MMgy plant. Energy savings in distillation improved profits by $71,000 annually and better 200 proof control improved them by $80,000. Fermentation yield improvements added $188,000 to the bottom line and the incremental increase in throughput of 0.6 percent brought in $126,000.&nbsp;&nbsp; Integrated management Management of the data being recorded by the control system is also getting more sophisticated. &ldquo;Data is flowing in like mad and getting processed automatically, coming out in meaningful format for decision-making,&rdquo; Merkwan says. More plants are making use of predictive analytics, he adds, plugging historical data into an Aspen model to see whether a proposed change, such as adding a molecular sieve, would deliver the desired results or whether other tweaks are needed to capture the full benefits. Data integration is big, Merkwan says. Direct Automation has implemented its tool, Pi in the Sky, at a number of plants, making the data available in the cloud to those with proper access. &ldquo;It takes data from their automation system and from the lab, the maintenance management software and commodities and internet data like weather forecasts and aggregates it in one master database. From that, we can generate any report they want.&rdquo; The reports are available in the control room, the office, or even on managers&rsquo; cell phones. &ldquo;The average user is on the site 1.5 hours a day,&rdquo; he adds. Honeywell is also putting more solutions in the cloud. &ldquo;The buzzword is IIOT&mdash;the industrial internet of things,&rdquo; Jubien says. &ldquo;Honeywell is adding analytic capabilities to our products. The data on the cloud is available not only to the plant operators, but to Honeywell. We can detect when something is going wrong&mdash;maybe the board operator isn&rsquo;t using the application as well as it could be or maybe the application isn&rsquo;t matching the plant as well as it can. We use analytics that look at data and automatically generate an alert that is sent to the customer. Then we can jointly work to solve it.&rdquo; Another trend Honeywell is working with taps into the capabilities of artificial intelligence. &ldquo;We found a lot of applications were turned off because the operator didn&rsquo;t understand what it was doing,&rdquo; Jubien explains. &ldquo;Being able to answer that is key to addressing the comfort level of operators.&rdquo; Even as the industry continues to install new and more powerful DCS and advanced controls, attention to the basics is important. Merkwan recommends just cleaning up existing systems. &ldquo;There&rsquo;s been so many things coming out that people need to clean it up and get it working well,&rdquo; he says. &ldquo;There are so many systems where cable management is bad, alarm management is bad, the sequencing and coding needs to be cleaned up. A lot of times, if they have an engineer there for a month or two cleaning the system up and restoring the old system, it will make a difference.&rdquo; Another opportunity for improvement is in implementing sequences, Tenor says, pointing to 10 sequences Trident Automation has implemented at various plants.&nbsp; &ldquo;An example is shifting from one mash train to another, which is a series of opening and closing valves. If you do it by hand, it could be 30 mouse clicks to get it done. If you build a sequence, it just does it with one click.&rdquo; Hands-On Vs. Automation While it can be helpful to automate sequences whose repetition can be mind-numbing, balance is needed, Tenor says. &ldquo;You want human interaction and operators with their eyes on everything.&rdquo; That said, it can be beneficial to automate critical sequences so the procedure is done the same way every time, regardless of shift changes or new or experienced operators. Experience will outweigh automation in some cases where plant managers and operators turn off automation. &ldquo;Some don&rsquo;t use them because they like to have their fingers on the system instead of doing it with automation,&rdquo; Merkwan says. &ldquo;Stereotypically, the guys that have been around a while, that have been in the system for 20 years, they know what a good-sounding plant sounds like. They can walk into a place and hear the motors running and know if everything is running right. They do a good job. And if it works, it works. As the newer guys come in, we&rsquo;re starting to see movement towards automation.&rdquo; Built upon the historical data of a plant, advanced process controls essentially are replicating what the best operators do. &ldquo;Advanced control is just trying to do slightly better than what the operator does,&rdquo; Jubien says. &ldquo;Over a day, [the advanced controller] is making 1,000 small adjustments. Even the most patient, dedicated operator can&rsquo;t apply that level of focus. That&rsquo;s why the advance control can do a little better in most cases. I&rsquo;ll use the cruise control analogy. I know my cruise control can hold the 65 miles per hour a little more steadily than I can. But it&rsquo;s not necessarily a better driver.&rdquo; Author: Susanne Retka Schill Freelance Journalist retkaschill@yahoo.com

WIRING UP: Alex Schuh, Trident Automation, is installing a Trident TermPac product in an ethanol plantâ€™s motor control center room. 

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AUTOMATED ARRAY: Alex Nelson, Trident Automation, installs multiple monitors in an ethanol plantâ€™s control room as part of a system upgrade. 

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INTEGRATED AND AUTOMATED: New automation and software tools are integrating plant data with lab and accounting data to deliver customized reports to plant managers. 

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POWER TO COMPUTE: Working for Trident Automation, Adam Hynnek is landing power to a Siemens rack and cards in an ethanol plantâ€™s motor control center room.  

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FROM THE OCTOBER ISSUE: Plants large and small, with new or old control systems, tap into advanced controls and innovative data management solutions.  

Advanced and  Enhanced

In 2016, California's greenhouse gas (GHG) levels were below 1990 levels for the first time since emissions peaked in 2004. That's equivalent to taking about 12 million cars off the road or saving 6 billion gallons of gasoline a year. The figures were released in July of this year and show promise for the state's maturing emissions goals.&nbsp; In the transportation sector, the main reason for that decline was California&rsquo;s Low Carbon Fuel Standard. The LCFS is administered by the California Air Resources Board and uses a market-based cap-and-trade approach to ultimately lower GHG emissions, says Jessica Buckley, senior environmental scientist for RTP Environmental Associates Inc. &ldquo;California essentially created this program to create a market for low-carbon fuels and hopefully stimulate further production. Sort of like what the Renewable Fuel Standard did federally.&rdquo; California is pushing its GHG reduction goals even further than the original 2020 goal. The original provision under Assembly Bill 32, the California Global Warming Solutions Act of 2006, required California to reduce its GHG emissions to 1990 levels by 2020. Senate Bill 32 increased that goal to 40 percent below 1990 levels by 2030, which is the most ambitious GHG reductions emissions goal in the U.S., says Graham Noyes, executive director of the Low Carbon Fuels Coalition and managing attorney of Noyes Law Corp. Within the statutory framework of AB 32 and SB 32, CARB has broad authority to design specific programs. The LCFS is a key additional program in the transportation sector, requiring a reduction of the carbon intensity of transportation fuels by 10 percent between 2011 and 2020. CARB is poised to extend the program to 2030, and require that a 20 percent reduction be achieved.
Spread of LCFS The success of the LCFS has led to many states and even other countries looking to adopt similar programs, namely, the Pacific Coast Collaborative, an international government agency consisting of Oregon, Washington, California and British Columbia, Canada, Buckley says. &ldquo;Oregon has a program,&rdquo; she says. &ldquo;British Columbia has their own program that&rsquo;s part of the Pacific Coast Collaborative; Alaska is observing right now, but I wouldn&rsquo;t be surprised to see them try and join in the next five years or so; and Washington State is still working through their legislature. They&rsquo;ve had some hiccups to the process, but my understanding is they&rsquo;re still very interested in joining.&rdquo; Oregon&rsquo;s Clean Fuels Program is most comparable to California&rsquo;s LCFS. In some respects, it doesn&rsquo;t have as many regulations as California&rsquo;s program does, but it also has a 10 percent carbon intensity reduction, Noyes says. &ldquo;The Oregon program started five years after California&rsquo;s program so they&rsquo;re a little behind in terms of carbon intensity reductions and market pricing.&rdquo; Other regions of the U.S. are considering legislation, too. Buckley says the Midwest has shown interest several times in creating its own LCFS program. &ldquo;It&rsquo;s mostly a grassroots type thing. Most of the biofuels in the U.S. are produced in the Midwest and, due to the shortfalls in transporting fuels to California, they&rsquo;ve talked about creating their own standard and going to their legislatures to propose that. It would make it a lot easier to transport and sell their fuel within the Midwest.&rdquo; Some might worry that an increase in similar programs in other states could affect the import of fuels into the California market. But Noyes says that isn&rsquo;t the case. Credits under the LCFS provide increased value for producers to continue selling into California, he says.
 &ldquo;We&rsquo;re seeing a lot of product being sold into the California market because there&rsquo;s a premium attached. You can get your RINs and get credit value on top of that. Some product is going into Oregon for the same reason. You don&rsquo;t get quite as much premium there right now, but if we saw more similar programs in other states, hopefully it would be increasing demand for low-carbon fuels. That might compete with California&rsquo;s market, but they&rsquo;re very focused on spreading GHG reductions policies so they would welcome more policy structures like the LCFS.&rdquo; Buckley agrees that similar LCFS programs wouldn&rsquo;t hurt California&rsquo;s market. &ldquo;There would still be a desire to sell fuels in California. It&rsquo;s not just biofuels. There are a bunch of fuels in the California market, such as different biomethane and other low-carbon fuels. Anything that takes the majority of GHGs away from the petroleum fuels is the overall desire of the LCFS.&rdquo; A variety of fuels are being sold into California, but the main product is ethanol. &ldquo;That ethanol is coming mostly from the Midwest, such as Minnesota, Iowa, Kansas, Nebraska, Illinois, Indiana,&rdquo; Buckley says. &ldquo;Ethanol is being sold into California from all over the U.S., but most of it is coming from where there is corn.&rdquo; The lowest carbon intensity ethanol is the most likely product to be sold into the California market, as it has more credit value for the producer, Noyes says. &ldquo;The most efficient plants from a production standpoint, and ones using alternative feedstocks or who have very good energy profiles, are the producers servicing the California market. Geography matters, as well, so how far they have to travel to market dictates a lot.&rdquo; CARB Amendments Even though the LCFS is seeing success in reaching California&rsquo;s emissions goals, CARB isn&rsquo;t slowing down. The organization is working on a handful of refinements and updates to the LCFS program. The main update was to the California Greenhouse Gases, Regulated Emissions and Energy Use in Transportation (GREET) model, specifically to ethanol, with some more favorable calculations. The amendments are intended to create more credit generation, Noyes says. &ldquo;CARB added additional crediting mechanisms so there are some new ways to make credits, one of those is through the use of alternative jet fuel,&rdquo; he says. &ldquo;One additional new upgrade that could be very beneficial for the ethanol industry is carbon capture and sequestration (CCS). CARB is proposing a protocol that would enable CCS to be recognized and generate credits, which is something Archer Daniels Midland is already doing and other producers are looking at. CCS could provide a new source of revenue, a lot of GHG reduction and a whole new area of credit generation.&rdquo; A proposed simplified starch calculator for certain tier 1 fuels includes starch corn-based ethanol, as well as corn-fiber ethanol, Buckley says. &ldquo;Some updates are going to be a little more paperwork, but will ultimately continue to move the market forward to create a very stable market for these fuels.
 &ldquo;One of the other changes is third-party verification,&rdquo; she says. &ldquo;This is a whole ball of wax, so to speak. They haven&rsquo;t ironed out the final details with that, but they&rsquo;re going to require facilities to contract a third party who is independent from creating the pathway, or from doing any kind of consulting work or compliance documents, to come in and verify the pathway is indeed valid.&rdquo; Kari Buttenhoff, compliance manager for Christianson PLLP, has been reviewing certain pieces of CARB&rsquo;s amendments to the LCFS and discussing them with the organization. Christianson has been mainly focused on the verification piece of CARB&rsquo;s proposal, she says. &ldquo;We&rsquo;ve been attending workshops and submitting public comments, as well as having private phone calls, to try and educate them more about renewable fuel and the transportation piece of the industry. So, we&rsquo;re trying to help give them some education, while also explaining our concerns about the amendments to get them changed before they&rsquo;re finalized.&rdquo; The goal is for most of the amendments to take effect January 1, 2019, but some will be phased in over time, particularly verification, Noyes says. Verification Proposal Verification is one of the most important amendments being proposed by CARB. It&rsquo;s a way for CARB to have better visibility into how the plants are operating. Traditionally, custom pathways were outlined for plants based on the CI score of a facility. Many factors determine the CI of a plant, such as how much energy it&rsquo;s using, what kind of energy it&rsquo;s using, yield, coproducts and more. The challenge for CARB is keeping track of all the information, Noyes says. Because of the amount of data that needs to be tracked, CARB is stretched a little thin, so it has requested third parties act as verifiers once they&rsquo;ve gone through training programs and been certified by CARB, Buckley says. &ldquo;My understanding is facilities will no longer be submitting their applications directly to CARB, but will submit those applications to their third-party verifier before sending to CARB. That&rsquo;s in addition to the third-party verifier doing periodic validation and verification work on the pathways.&rdquo; Third-party verification will become mandatory for any LCFS participants in 2019. It&rsquo;s currently voluntary, Buckley says. Much of what will be involved with third-party verification is still being determined, so it&rsquo;s unclear what the process could look like, Buttenhoff says. &ldquo;What we&rsquo;re seeing right now is there will be a simplified calculator that producers fill out to establish a pathway and get their CI. So they&rsquo;ll have to report two months of data in that CI calculator each year and we&rsquo;ll end up verifying that. The data is similar to the efficient producer pathways we&rsquo;re reviewing, but it&rsquo;s more detailed. The main engagement I would compare it to is a financial statement audit. So the verifications are going to require site visits, risk assessments, interviews of personnel and understanding of data management systems. It won&rsquo;t go to the full extent of a financial audit, but the steps to get there will look very similar.&rdquo; Third-party verification isn&rsquo;t a completely foreign concept for producers. RINs have third-party requirements, including engineering reports every three years, or when a new pathway is implemented. The LCFS third-party verification program is slightly different than RIN verification, though, Buckley says. &ldquo;There is a little bit more involved in selecting a vendor for third-party verification in that there is a conflict of interest clause, so your vendor can&rsquo;t be involved in any of the consulting or application preparation. There is also a five-year lookback on that, so if you&rsquo;ve used that vendor for anything in the last five years, you won&rsquo;t be able to use them for third-party verification. &ldquo;Right now, there is a rotation clause in the verification process where every six years a firm will need to be put on a three-year hiatus,&rdquo; Buckley says. &ldquo;So, every six years a facility needs to contract a new firm for a time period of three years.&rdquo; The conflict of interest rules and the firm rotation CARB is looking at putting in place are probably the biggest hurdles right now to finding a third party, Buttenhoff says. &ldquo;Those are the main issues with the verification program at this time. With the scope of services that we provide for ethanol producers, the conflict of interest rules have been a real struggle.&rdquo; &ldquo;I haven&rsquo;t heard of anyone who is particularly happy about this system,&rdquo; Buckley says. &ldquo;From a compliance standpoint, to have someone who isn&rsquo;t familiar with your facility come in may be a bit of a quagmire. I can see the rationale that CARB doesn&rsquo;t want complacency in the system where things could be missed, though.&rdquo; As organizations like Christianson familiarize themselves with the potential changes to verification, California&rsquo;s LCFS still serves as a model for other states and regions aiming for emissions reductions. At a displacement of 6 billion gallons of gasoline per year, and counting, experts seem to agree that it&rsquo;s likely more states with progressive GHG goals will get onboard. ---------------------------- SIDE BAR ----------------------------------------------------- Low Carbon Fuel Standard The LCFS requires producers of petroleum-based fuels to reduce the carbon intensity of their products. The original plan under the program was a quarter of a percent carbon-intensity reduction in 2011 and would culminate in a 10 percent total reduction by 2020. The California Air Resources Board has proposed increasing the carbon intensity reduction goal to 20 percent below 2010 levels by 2030. ---------------------------- SIDE BAR ----------------------------------------------------- Author: Tim Albrecht Associate Editor, Ethanol Producer Magazine

NEW LOW: In July, California fell below 1990 greenhouse gas levels for the first time since emissions peaked in 2004. The stateâ€™s emissions goals specified 1990 levels by 2020. With the initial goal met, the state is looking to increase it to 20 pe

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FROM THE OCTOBER ISSUE: Amendments to California's Low Carbon Fuel Standard could lead to favorable changes for the ethanol industry.   

LCFS Matures

Red River Biorefinery breaks ground in North Dakota An ethanol plant that will process sugar beet tailings, as well as potato and pasta processing waste held a groundbreaking ceremony in Grand Forks, North Dakota, on Aug. 22. Construction already has begun on the 11-acre site. BioMass Solution&rsquo;s plant will use up to 500,000 tons annually of the process wastes, producing 16.5 MMgy of ethanol and generating D3 and D5 renewable identification numbers (RINs). The plant will use sugar beet processing technology developed by Biotechnika, which has one sugar beet ethanol plant operating in Poland. The process is much like the corn-to-ethanol process, once the feedstock hits the fermentation step. The feedstock has a higher water content than corn, so hydrolysis and pasteurization are different, including new enzymes for hydrolysis. The excess water in the thin stillage is put through anaerobic and aerobic processes to generate more energy for the plant. The temperatures and other process conditions vary a bit, too, said Tomasz Kapela, owner of Biotechnika.
The plant is expected to be operational at the beginning of 2020. BioMass Solution has a long-term contract with area sugar beet cooperative American Crystal Sugar Co., as well as with partners Simplot, a potato processor in Grand Forks, and Philadelphia Macaroni Co. The ethanol will be sent to California to take advantage of the state&rsquo;s Low Carbon Fuel Standard. The process does create a wet animal feed byproduct with higher protein than traditional DDGS. The feed will be sold locally. ACE announces 2018 award winners&nbsp; The American Coalition for Ethanol honored a select group of advocates for their contributions to the ethanol industry during its 31st annual conference in August in Minneapolis. The most prestigious award, the Merle Anderson Award, is named after the organization&rsquo;s founder, who passed away in August at the age of 96. The award is given to individuals who display unmatched dedication to ACE and the domestic ethanol industry. This year&rsquo;s award winner was Owen Jones, long time ACE board member representing Full Circle Ag of Britton, South Dakota. &ldquo;I am truly humbled by receiving this award after his passing,&rdquo; Jones said. &ldquo;Merle not only provided leadership in the ethanol industry, but he was my mentor because he came from the same roots as I did.&rdquo; The Grassroots Award is given to an individual who often performs behind the scenes to advance the cause of ethanol. Dale Tolifson of Benson, Minnesota, was presented with this year&rsquo;s award for nearly 10 years of service on the ACE board of directors representing the Minnesota Corn Growers Association and Chippewa Valley Ethanol Co. &ldquo;I started farming in 1963 after I graduated from high school and got involved with the ethanol industry around 1990 when we decided to put an ethanol plant in our town,&rdquo; Tolifson said. &ldquo;The ethanol industry is the biggest thing that&rsquo;s happened in my farming career and it still has a lot of potential. I never thought it&rsquo;d go this far.&rdquo; Jetz Convenience Centers of Milwaukee, Wisconsin, is the recipient of the Paul Dana Marketing Vision award. The award is presented to a company that has exhibited leadership in ethanol marketing. Jetz owner Bob O'Connor accepted the award. Ken Anderson of Brownfield Ag News was given the Media Excellence Award, which goes to those in the media who demonstrate excellence in covering news and issues important to the U.S. ethanol industry. &ldquo;I&rsquo;m honored to receive this award from ACE, which is a great resource for ethanol-related information,&rdquo; Anderson said. &ldquo;Ethanol is very important to our listeners and readers across the Midwest and keeping them up to date on the latest industry developments is one of our top priorities at Brownfield.&rdquo;

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Jacek Chmielewski, principal of BioMass Solution, speaks at Red River Biorefineryâ€™s groundbreaking ceremony Aug. 22 in Grand Forks, North Dakota.

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FROM THE OCTOBER ISSUE: A new ethanol plant breaks ground and the American Coalition for Ethanol announces award winners. 

Business Briefs

With the clock ticking on the Renewable Fuel Standard and demand being destroyed through bureaucratic action, the ethanol industry seems to once again be at a crossroads. Do we accept being under the thumb of big oil and the U.S. EPA or do we demand that Washington, D.C., allow rural America to do what it does: help feed and fuel the world in an environmentally responsible way and leave behind a better opportunity for the next generation? Reports of nearly 300,000 comments filed on EPA&rsquo;s annual volume obligation proposal illustrate how we are captive to a government program that would be obsolete and unnecessary if we had true competition on the fuel market. How much taxpayer money is spent to simply read those 300,000 comments, never mind take any action? How much time, effort and resources went into preparing comments to ask for the bread crumbs of the gasoline market that we should have access to? Cronyism in Washington, D.C., has resulted in consumers, taxpayers, and all of rural America being held hostage. In 2016, our industry supported 360,000 jobs, contributed $44 billion toward the U.S. gross domestic product, and another $23 billion in household income, all without being free to compete. The rural economy has been slower than any other sector to recover from the last recession. With looming trade wars and depressed commodity prices, it is only getting worse. Ethanol offers us a chance to change our destiny. The 15.8 billion gallons of ethanol we produce and the economic benefits it provides represent a lifeline to rural America. Imagine a doubling of the ethanol industry by moving from 10 percent blends to an average of 20 percent, contributing nearly $90 billion annually with more than 717,000 jobs. We ran the numbers in Iowa as an example, a state that produces 4 billion gallons of ethanol and only keeps 3.5 percent of that amount in the state, while importing 1.5 billion gallons of gasoline. Doubling the state average would keep $100 million in Iowa. A similar scenario for prosperity exists in Nebraska, South Dakota, Minnesota, Illinois and Kansas. But EPA is stalling progress. Artificial fuels, misleading test procedures and oil-influenced data produce inaccurate results and paint a distorted and false picture of ethanol. At the Urban Air Initiative, we have used Freedom of Information Requests to access thousands of emails and internal EPA documents that clearly show collusion between the oil industry and EPA. The result has been a nearly 30-year history of unfair treatment of ethanol and a failure to recognize its ability to protect public health while meeting a range of public policy objectives. Every Midwest state has a governor elected by the people. Why aren&rsquo;t these elected leaders demanding their people have the choice to use their products? They have spent the past 10 years passively waiting for permission, when they could have been demonstrating leadership. If they prefer to be glad-handing politicians, states should replace them with leaders. Our Midwest states should demand the right to market their own fuel blends in their states without federal roadblocks. We have identified those roadblocks and offered practical, common sense solutions: Fix the emission and carbon models, allow higher blends year-round, stop any limits on ethanol volumes, support a new certification fuel for higher blends, and enforce toxics controls. Let the free market work for the producer, the retailer and the consumer. Let us prove to the American consumer we really are cheaper, better and cleaner. Author: Dave VanderGriend President, Urban Air Initiative CEO, ICM Inc. 316.796.0900 davev@icminc.com

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FROM THE OCTOBER ISSUE: Dave VanderGriend, president of Urban Air Initiative, doesn't mince words in his column this month, calling out EPA for what he says is collusion with the oil industry. 

Making America Great Again Starts with the States

Back in April, China notified the World Trade Organization it is suspending trade concessions to the U.S. on products including ethanol, in response to U.S. duties on aluminum and steel. China said it would increase tariffs by 15 percent on 128 U.S. products, intensifying a dispute between the world&rsquo;s biggest economies. The previous duty was 30 percent.&nbsp; Further escalating the trade war, at the beginning of August, the U.S. announced it would slap tariffs of 25 percent on another $16 billion of exports from China. This announcement rippled through the market almost immediately with the Shanghai Composite index falling 2 percent the next day. The tariffs will neutralize cost savings of importing cheaper U.S. ethanol versus purchasing domestic supply. Chinese oil refineries will have to consider turning to domestic suppliers or elsewhere for ethanol. This is great for domestic producers, but analysts say China will probably need to resume imports to meet the government target of 10 percent ethanol content in all petrol nationwide by 2020. What does that mean for international trade? Take pork for example&mdash;if China slaps a tariff on American pork, Canadian pork will replace American pork in the Chinese market, with American pork taking up the slack left over by Canada in the South Korean market. Commodity markets like pork work on the balloon principle&mdash;squeeze them somewhere and the supply just goes somewhere else. In the short term, consumers will most likely see rising prices in the commodity market (fruits, vegetables, pork) and with end products (gas) until the countries can find alternative importers. However, if those higher prices translate into lower sales, that will mean fewer jobs in the longer run. This is counterproductive for U.S. and Chinese ethanol producers. It is best to have free and fair trade for U.S., Chinese and international producers. Generally, nobody wins when countries erect tariffs and anti-trade policies. Such barriers lead to fewer jobs and weaken the economy. Tariffs are regressive, leaving consumers, workers and businesses bearing the costs of higher prices. Acting as a tax on both consumers and businesses, trade wars raise the costs of trading, weighing on asset values, weakening consumers&rsquo; ability to spend and reduce incentives for businesses to invest by creating uncertainty. It is not a zero-sum game. Closer to home, as trade war talks resume with the renegotiation of the North American Free Trade Agreement, the market takes a hit. The share prices of U.S. ethanol producers tumbled at the end of July after Canada announced a new wave of retaliatory import tariffs against American products. Biomass-based diesel producers also felt the drop, but ethanol producers were hit the hardest. &nbsp; Author: Bliss Baker President, Global Renewable Fuels Alliance 647.309.0058 info@globalrfa.org

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FROM THE OCTOBER ISSUE: Bliss Baker, president of the Global Renewable Fuels Alliance, recaps recent trade barriers and explains their implications. 

Nobody Wins When Countries Erect Trade Barriers 

The U.S. EPA remains committed to meeting the statutory deadline for finalizing the 2019 Renewable Fuel Standard renewable volume obligations (RVOs) by Nov. 30. While that&rsquo;s good news, we hope the final rule accounts for the significant damage the small refiner exemptions have caused to the ethanol industry and farmers across the country. Otherwise, the annual requirement for conventional renewable fuels like ethanol will be rendered meaningless and will stand in opposition of President Donald Trump&rsquo;s support of a strong RFS. In late June, EPA proposed a total renewable fuel volume of 19.88 billion gallons, of which 4.88 billion are advanced biofuel, including 381 million gallons of cellulosic biofuel. That leaves, on paper, a 15 billion-gallon requirement for conventional renewable fuels like corn ethanol. But issuing small refiner exemptions after the RVO rule is finalized&mdash;which EPA did for the 2016 and 2017 RVO rules and what the agency could do for the 2018 rule&mdash;essentially reduces the actual required blending volumes to levels below those specified in the final rule. We explained that in comments to the agency on the 2019 RVO proposal. &ldquo;Thus, we do not consider the volumes that appear in the proposed rule to be authentic, meaning the preamble&rsquo;s analyses of the impacts of the 2019 proposed volumes are flawed and indefensible,&rdquo; RFA wrote to EPA in comments on the proposal. Specifically, EPA has acknowledged granting 49 retroactive exemptions from the RFS program to small refineries in 2016 and 2017 without adjusting the applicable percentage obligation to shift those volume obligations to nonexempt obligated parties. &ldquo;The agency&rsquo;s clandestine use of small refinery exemptions and its refusal to account for them reveals that its proposed RVOs for 2019 are neither reliable nor trustworthy. However EPA justifies its reduction of cellulosic and advanced volumes, EPA&rsquo;s ostrich-like approach to retroactive small refinery exemptions all but ensures&mdash;in direct contravention of the statute&mdash;that the required volumes for 2019 will not be met,&rdquo; RFA wrote. The small refiner waivers have collectively resulted in a significant decline in demand for biofuels and have cost U.S. corn growers, ethanol producers and ethanol blenders more than $5 billion in economic losses, according to recent RFA calculations. These waivers are not only creating demand destruction, but are in direct conflict with the assurances of Trump. While campaigning for president, he said EPA should ensure that biofuel blend levels match the statutory level set by Congress, and has since repeatedly stressed his support for a strong RFS. Additionally, during an Aug. 1 hearing by the Senate Environment and Public Works Committee, EPA Acting Administrator Andrew Wheeler said he does believe the RFS should be implemented in a manner consistent with the original intent of Congress. Clearly, lowering the conventional ethanol RVO below the statutory level through illegal waivers is not consistent with Congressional intent. What can be done? We are asking EPA to &ldquo;ensure that the RVOs are administered in a manner that is consistent with the statutory purpose of the program&rdquo; by accounting for the small refiner waivers prospectively, RFA noted in its comments to EPA. In fact, EPA acknowledged it has the authority and obligation to do so. &ldquo;In a draft of the proposed rule that was submitted to the White House Office of Management and Budget for interagency review, EPA properly included projections of exempted volumes of gasoline and diesel from small refineries. The effect of including these exemptions in the RVO calculation is to increase the RVO percentage for remaining obligated parties, ensuring that the statutorily specified volumes of renewable fuel are in fact blended with gasoline and diesel. However, the administrative record shows that just days before the proposed rule was made public, EPA inexplicably deleted the provisions that would have effectively reallocated the projected small refiner exemptions,&rdquo; RFA noted. The RFA will continue to work with EPA to ensure the final 2019 RFS RVO reflects the statutory intent of the rule. Consumers will only see the full economic, energy-security and environmental benefits of the RFS when it is implemented as Congress intended. Author: Geoff Cooper Incoming President and CEO Renewable Fuels Association 202.289.3835 gcooper@ethanolrfa.org

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FROM THE OCTOBER ISSUE: Incoming RFA President and CEO Geoff Cooper addresses the small refiner exemptions issued by the U.S. EPA last year, and how they affect the ethanol market. 

EPA Needs to Reallocate Gallons from RFS Waivers

Just before writing this ed note, I attended a groundbreaking ceremony for a brand new ethanol plant right here in Grand Forks, North Dakota. It&rsquo;s noteworthy for a few reasons: The plant&rsquo;s feedstock is comprised of waste streams from local sugar beet, potato and pasta processors; it&rsquo;s one of only three greenfield ethanol plants under construction in the country; and, as Ethanol Producer Magazine is an international publication, I rarely get to cover things in my own backyard. That last one&rsquo;s personal, but still relevant. There&rsquo;s so much to be excited about. You can find more details on the plant itself in the Business Briefs on page 12, but I think one of the most interesting facets of the project ties in with our cover story: Red River Biorefinery will sell its ethanol in California because the benefits of the state&rsquo;s Low Carbon Fuel Standard outweigh the costs to get it there. California has created a model policy and, as you might be aware, has already met its 2020 emissions reduction targets. Now, the state legislature is moving forward with an even more aggressive plan to further reduce emissions. There&rsquo;s talk of such programs in states and regions all over the country, and even into Canada. The developers of Red River Biorefinery would be onboard for a similar goal here in the Midwest, representing a closer market. Find out more about the LCFS and how revamping it could affect ethanol markets, starting on page 14. We&rsquo;re in an age of increased automation, and ethanol plants certainly aren&rsquo;t falling behind. The feature starting on page 20 explores some of the new distributed control system technologies out there and how the half of our industry without completely replaced DCSs are targeting specific areas and extending the lives of their systems. One source notes that skilled operators still are key, using a dynamite cruise control analogy. On page 30, we tackle plant morale. I&rsquo;m told morale can be tough to maintain in an ethanol plant, but a few are doing something right. We draw on the expertise of Midwest AgEnergy LLC&mdash;the Workplace of the Year winner in Ethanol Producer Magazine&rsquo;s 2018 Ethanol Producer Awards&mdash;in keeping employees happy and engaged. It seems rewards, inclusion, education and opportunities for advancement are common tools. Finally, the laboratory feature at the end of this issue addresses the increasing pressure on ethanol plant labs, as the industry strives for more efficiency. Commercial labs say business is booming because plants are outsourcing sample testing to preserve their own equipment. It&rsquo;s an interesting topic that resulted from interviews conducted for a different purpose and a different hook. So, we changed course to report it. Follow ethanol labs&rsquo; efficiency trajectory on page 38. Efficiency, of course, is vital and even the technology developer for Red River Biorefinery says the plant will showcase the most efficient setup for his sugar beet-waste-to-ethanol system. It&rsquo;s in use in Poland now, but he hopes the Grand Forks plant will serve as a model for more installations in the U.S. I hope so, too. Ethanol plants are a boon to local and regional economies. And it might mean more on-site, backyard coverage for quick-turnaround web stories here at EPM. Author: Lisa Gibson Editor lgibson@bbiinternational.com

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FROM THE OCTOBER ISSUE: Editor Lisa Gibson previews the magazine, including feature articles about California's Low Carbon Fuel Standard, automation, plant morale and more. 

October 2018

Business Briefs

Business Briefs

Columns

Making America Great Again Starts with the States

Nobody Wins When Countries Erect Trade Barriers

EPA Needs to Reallocate Gallons from RFS Waivers

On-Site, Automated and Efficient

Featured

Pressure to Perform

Pride in Product and Profits

Advanced and Enhanced

LCFS Matures

Contributions

DCS Upgrade Detailed

October 2018.css-7jxktu{position:absolute;bottom:0px;left:0px;right:0px;height:3px;border-radius:3px;background-color:var(--chakra-colors-brandBlack);}

Business Briefs

Business Briefs

Columns

Making America Great Again Starts with the States

Nobody Wins When Countries Erect Trade Barriers

EPA Needs to Reallocate Gallons from RFS Waivers

On-Site, Automated and Efficient

Featured

Pressure to Perform

Pride in Product and Profits

Advanced and Enhanced

LCFS Matures

Contributions

DCS Upgrade Detailed

October 2018