“Scope” Phillips 66’s Renewable Diesel Proposal, January 27

We cannot delay a massive transition to a just and sustainable economy fueled by renewable energy.  As concerned Bay Area citizens, as sky and water protectors, we know—as the old slogan goes—that we must think globally and act locally.  And now, at the volatile start of 2021, we have some important local decisions to make that will have long-lasting impact both on our own region and the world.

The oil industry is jumping en masse on the “renewable” bandwagon.  But do we all mean the same thing by renewable?

A few months ago, the Phillips 66 refinery in Rodeo announced its “bold commitment to the dual challenge of providing affordable energy and addressing environmental risks.”  According to its Rodeo Renewed website, the refinery intends to become the world’s largest provider of renewable fuels by pivoting to the manufacture of renewable diesel (while continuing to blend, store and ship fossil fuels).  This would, it claims, significantly cut its greenhouse gas emissions and reduce toxic pollution.  Two days before Christmas, Contra Costa County sent out formal notice of this apparent gift to environmental progress, calling for public input on the project proposal in order to determine the scope and content of the county’s environmental review.

The deadline for written scoping comment is January 27th.

Given the unprecedented scope and technological challenges of the project, we urge you to set aside some time to read the proposal, ponder, and then jump right in.  The more comments and questions we can raise, the better.  Take the broad kitchen sink approach and include questions about every possible environmental impact of this project.  Ask for specifics and demand missing detail.  Our input can help to ensure the greenest, least-impact project possible—which may not be the one Phillips 66 plans to give us.

First, take a look at the claims made and description provided on the Rodeo Renewed website.  In some ways, it’s far more informative (identifying project feedstock as “used cooking oils, fats, greases, soybean, and other vegetable oils”) than the formal project application, which is full of defining moments like this:  ” The objective is . . . to convert renewable feedstocks into renewable diesel, renewable components of other transportation fuels, and renewable fuel gas.”  It’s renewable, okay?  And take a look at our biofuels post, which raises basic questions about the efficacy of continuing to use agricultural land and agricultural products to fuel our trucks and planes.  Some sample questions and approaches can be found at the end of this post.

• The four-page Notice of Preparation / Notice of Scoping Meeting for a Draft Environmental Impact Report for the Proposed Phillips 66 Rodeo Renewed Project (County File# LP20-2040) is here.

• The longer Project Application can be requested from Contra Costa County Senior Planner Gary Kupp at Gary.Kupp@dcd.cccounty.us .  Or email action@sunflower-alliance.org and we’ll happily forward the PDF.

Email comments by 5 PM on Wednesday, January 27 to gary.kupp@dcd.cccounty.us .  Or mail them to Contra Costa County, Department of Conservation & Development, Community Development Division, 30 Muir Road, Martinez, CA 94533, Attention:  Gary Kupp.

 

Here are some questions and comments to help get the juices flowing. 

• Recent press reports suggest that the supply of waste oil is diminishing, given restaurant closures and the increasing demand from refiners.  Won’t P66 and other refiners have to turn to virgin oils instead?  And where will that oil feedstock come from?  What will the impact be on US soy production?
• In 2017 the U.S. placed tariffs on Argentine biodiesel, which had been 15% of the biodiesel consumed here in the U.S.  That source is now gone.  We know the cost to Argentina was pretty severe in terms of deforestation, as they cleared forests to raise soy.  What will be the impacts on the US agriculture if Phillips 66 uses virgin oils?  On global agriculture?
• Even if it’s just food waste that’s used, this already has other existing markets, so we can expect increased prices of a whole set of commodities.  This also increases the global pressure to produce, leading to deforestation and biodiversity loss.  (For these reasons, European governments and the EU have banned the use of palm oil in biofuel, finding it actually worse than carbon fuel use.)
• Is the demand really there for the prodigious amount of renewable diesel Phillips 66 intends to produce?  Is there overbuild in this project?  Will it lock us into combusting liquid transportation fuels over the next few decades when we should be electrifying transportation instead?
• Phillips 66 will continue to transport, blend, store, and export fossil fuel products under Rodeo Renewed.  This indefinitely delays decommissioning and full remediation of its site as it maneuvers to prevent stranded assets.  And what is to prevent a return to crude refining if its equipment remains in place?
• Is it accurate for the refiner to state that this project will slash GHG pollution by 50%?  What is the past amount being comparing to?
• The amount of hydrogen and natural gas required by the proposed project is, per barrel, about the same for heavy crude processing.  Using soybean oil would not actually be any less GHG intensive.
• What about the use of natural gas to produce hydrogen feedstock?  Couldn’t another method be employed to manufacture green hydrogen?  Isn’t electrolysis standard now in European processing?  Why not adopt the very best available technology in this new project?  (Especially given how heavily subsidized this project is under state LCFS and federal RFS programs, and how high the profit even before the product goes to market.)
• Use of all that hydrogen is extremely hazardous.  What about the high heats needed to break down down fatty acids?  What about the expected flaring?  The real possibility of explosions? What about the increased fire risk and the difficulties of fighting hydrogen fires?  What safety measures will be necessary to protect the surrounding community?
• If the quantity of some toxic pollutants decrease under Rodeo Renewed, as Phillips 66 claims (and the basis of that claim needs to be established), will others actually increase?  Have these been thoroughly identified?
• What are the impacts on water quality from initially bringing in increased amounts of petroleum crude, and of the quantities of fats and grease they can’t bring in by rail or truck?
• Why does Phillips 66 intend to increase the amount of crude oil it brings over its wharf for processing before it makes the transition to biofuel manufacture?  This “renewable” project actually includes two feedstock switches, not just one:  the increase in quantity of imported petroleum crude, followed by the switch to new bio feedstock.  Is the increase in crude imports, even if it’s temporary, at all warranted?