Int. 194, sponsored by Environment Committee Chairman Jim Gennaro, would require a small amount biodiesel to be blended into all oil used to provide heat and hot water in the city’s buildings by October 2011 and would cap the sulfur level of No. 4 residual oil at 1500 parts-per-million (ppm), cutting sulfur levels in half from than today’s sky-high sulfur levels.
Int. 194 is a critically important step towards solving the city’s longstanding heating oil pollution problem.
As I’ll testify today, heating oil is a critical component of our city’s multi-fuel strategy for ensuring the New Yorkers have reliable, affordable heat and hot water in the winter. Unfortunately, heating oil is also a significant contributor to our local, chronic particulate air pollution problems.
Particulate pollution is a one-stop shop for many health impacts. Studies show that it is linked with increased asthma emergencies, bronchitis, lower birth weights, heart disease and tens of thousands of premature deaths every year across the nation. And, it poses a particular threat to children, the elderly and anybody with heart or lung ailments. Millions of New Yorkers live in communities with some of the highest asthma levels in the nation.
Heating oil from the city’s roughly 800,000 buildings contribute 14 percent of the city’s local soot pollution. 86 percent of this heating-related soot pollution comes from the roughly 1 percent of the buildings that still use residual fuel oil, alternatively known as No. 4 or No. 6 oil.
These grades of heating oil typically contain about 175 times as much sulfur as the diesel fuel used in the city's trucks and buses, along with metals like nickel that worsen heart disease and other ailments.
Just yesterday, the city’s latest Community Air Survey report showed that nickel levels are highest during heating season. The survey found that airborne nickel levels were nearly four times as high in neighborhoods with large numbers of buildings that burn residual fuel oil than in neighborhoods with fewer such buildings.
As Dr. Thomas Farley, the city’s health commissioner said in the city's press release, “The time has come to phase out residual oil.”
Passing Int. 194 would be an important step towards reducing the impacts of this oil while it is still used.
The bill requires 2 percent of all heating oil to be biodiesel (i.e, B2, as its termed in the industry), so it would help reduce our dependence on oil, help support a growing local biodiesel industry, and reduce greenhouse and health-related emissions.
By lowering sulfur levels in all No. 4 heating oil, it would reduce the particulate matter emissions that are at the core of our concerns about the heating oil status quo.
The bill isn’t perfect, and I’ll be asking for three key changes before the bill is finalized, as follows:
First, we will ask that the city add a strong commitment to ensuring that only advanced biodiesel is used to heat the city’s buildings. More specifically, we will strongly urge the Council to amend the current draft of Int. 194 to require that all biodiesel used in the city’s heating oil will meet EPA’s recent RFS-2 definition for “biomass-based diesel” as a base line performance standard.
In its March 26, 2010 Renewable Fuel Standard rule (the “RFS-2” rule), EPA defined “biomass-based diesel” as biodiesel that reduces greenhouse gas emissions by at least 50 percent, compared to conventional diesel, based on a lifecycle assessment.
The EPA RFS-2 definition for biomass-based diesel is not a mandatory certification program - it's entirely voluntary. So, by requiring this type of biodiesel as a baseline, the city would be helping steer the market towards this fuel, rather than a sub-RFS-2 version of biodiesel.
Second, we will strongly urge the Council to add a requirement that at least 75 percent of the biodiesel used to meet the requirements of Int. 194 be derived from Waste Vegetable Oil (WVO). It has been widely reported that the local biodiesel industry could provide 50-75% of a B2 mandate, mostly from used restaurant grease.
This assessment of the local market for WVO should be compelling as the Council considers what level of WVO is appropriate for Int. 194. We will ask the Council to adopt a WVO content requirement at the high end of the projected WVO availability, because we understand that the city cannot limit the bill to locally-sourced WVO only.
Last, NRDC will urge the Council to tighten its sulfur provisions in Int. 194.
Rather than a range of sulfur levels, NRDC strongly urges the Council to cap sulfur in the city’s No. 4 residual fuel oil at 1500 parts-per-million. Further, we will ask the Council to implement this provision at the same time as it implements the 2% biodiesel provision, i.e., in October 2011.
As I have written before, we still need the state legislature to adopt S. 1145-C (Perkins), a bill to lower sulfur levels in No. 2 oil, the most commonly used heating oil, and we are waiting for the city to publish regulatory steps that will modernize the old boilers and burners that are still used in many buildings.
But in the meantime, Int. 194 is an important step that will help reduce greenhouse and particulate emissions from heating oil, reduce our dependence on oil, and help spur the arket for advanced biodiesel fuels.
This post originally appeared on NRDC's Switchboard blog.