The Biobased and Renewable Products Advocacy Group (BRAG) helps members develop and bring to market their innovative biobased and renewable chemical products through insightful policy and regulatory advocacy. BRAG is managed by B&C® Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C.

By Lynn L. Bergeson

On February 7, 2019, Representative Ocasio-Cortez (D-NY), in partnership with Senator Ed Markey (D- MA), released the outline for the Green New Deal, a policy package designed to reduce greenhouse gas (GHG) emissions through the transformation of the U.S. economy. The outline includes highlights on the systemic impact from climate change, particularly on women, indigenous populations, deindustrialized and migrant communities, the poor, communities of color, depopulated rural communities, low-income workers, the elderly, the unhoused, people with disabilities, and youth. Stating that climate change poses a direct threat to the U.S. national security, the outline of the Deal makes it the federal government’s duty to pass its measures. These duties include transitioning to 100 percent renewable energy; creating millions of high-wage jobs; ensuring economic security for everyone; investing in infrastructure and industry; ensuring clean air and water, climate and community resiliency, access to healthy food, and a sustainable environment; and promoting justice and equity that currently prevent oppression repair.  According to Ocasio-Cortez’s outline, all Green New Deal goals should be addressed in ten years through:

  • Resiliency building against climate change-related disasters;
  • Pollution elimination;
  • Expansion of renewable and zero-emission energy sources;
  • Spurring growth in clean manufacturing;
  • Promoting sustainable farming;
  • Building a sustainable food system;
  • Provision of resources, training, and education; and
  • Public investment in research and development (R&D), among other measures.

 

By Lynn L. Bergeson

On January 28, 2019, Growth Energy, an ethanol supporters group, submitted joint comments with the U.S. Grains Council (USGC) to the Government of Ontario, Canada, in support of the Made-in-Ontario Environment Plan (Plan). The Plan outlines the government’s commitment to addressing climate change through the protection of land, air, water, and reduction of waste and greenhouse gas (GHG) emissions. Posted by the Ontario Ministry of the Environment, Conservation and Parks, the Plan would increase ethanol use in gasoline by 15 percent in 2025, increase the use of renewable gas and fuels, establish emission performance standards for large emitters, and provide financial assistance for emissions reduction initiatives.  Pleased with the Ontario Government’s proposal to increase the ethanol content of gasoline, Growth Energy and USGC highlight the “tremendous benefits to the public” it will provide through lower GHG emissions and levels of other pollutants, better fuel properties, and economic benefits to Canada’s agricultural economy. The letter also reassures Ontario that the increase in demand from a move to 15 percent ethanol (E15) will be met. The two organizations provide additional information on the approval and use of E15 in the U.S., with a note that since the U.S. Environmental Protection Agency’s (EPA) approval of this rule in 2011, retail and wholesale of E15 continues to grow. The letter concludes by emphasizing once more the substantial advances to Ontario’s goals should the proposed Plan be implemented. According to the letter, the goals and promises of the Plan are not only achievable, but also would still support consumer choice and ensure compliance flexibility and transparency.


 

By Lynn L. Bergeson

On December 6, 2018, U.S. Senator Charles E. Schumer (D-NY) wrote a letter to President Donald Trump requesting that, in 2019, any infrastructure package to be considered include a focus on the clean energy economy to address climate change. Emphasizing that climate change is, in fact, real and caused by humans, Senator Schumer refers to the Administration’s recent National Climate Assessment report and the drastic need to reduce emissions. In the letter, Senator Schumer outlines a number of policies that must be included in an infrastructure package in the next Congress. Among these policies are the need to:

  • Invest in research, development, and deployment of clean energy, energy efficiency, carbon reduction, and energy storage technologies;
  • Provide permanent tax incentives and investments for domestic production of clean energy and renewable power; and
  • Invest in upgrades in clean energy for public schools, buildings, and other infrastructure.

Senator Schumer concludes his letter to President Trump highlighting that “[t]he challenge is immense, but so is the opportunity to revitalize and modernize our infrastructure, create new jobs and economic opportunities, and position the United States as a leader in clean energy innovation.”


 

By Lynn L. Bergeson

On November 28, 2018, the European Commission (EC) published a document called “A Clean Planet for all: A European strategic long-term vision for a prosperous, modern, competitive and climate neutral economy.”  Due to EC’s expressed concerns about climate change, part of this new long-term vision includes new rulings that facilitate the production of bio-fertilizers, encourage the production of biogas from manure treatment, and increase biomass imports.  Emphasizing the crucial role of biomass in a world with a 30 percent higher population in 2050, the report states that “biomass can directly supply heat.  It can be transformed into biofuels and biogas and when cleaned can be transported through the gas grid substituting natural gas … And it can substitute for carbon intensive materials, particularly in the building sector but also through new and sustainable bio-based products such as biochemicals.”  The report also analyzes the economic and social impacts of these new rulings, and highlights the critical role of the European Union (EU) in leading a low-carbon transition at the global level.


 

By Lynn L. Bergeson

On November 29, 2018, the Government of Ontario, Canada, submitted for public comment the Made-in-Ontario Environment Plan (Plan).  The Plan outlines the government’s commitment to addressing climate change through the protection of land, air, water, and reduction of waste and greenhouse gas emissions.  Posted by the Ontario Ministry of the Environment, Conservation and Parks, the Plan would increase ethanol use in gasoline by 15 percent in 2025, increase the use of renewable gas and fuels, establish emission performance standards for large emitters, and provide financial assistance for emissions reduction initiatives.  As part of the work on the plan, the next steps to make the actions outlined final include continued engagement with Indigenous communities, the establishment of a climate change advisory panel, the implementation of priority initiatives, and monitoring progress.  The Plan is open for comment until January 28, 2019.


 

By Lynn L. Bergeson

Climate Transparency, a global partnership of international organizations to stimulate G20 climate action and empower zero carbon technologies through transparency, published in early November 2018 their annual “G20 Brown to Green -- The G20 Transition to A Low-Carbon Economy” report. The report summarizes carbon-reducing activities across all G20 countries, utilizing 80 indicators. In an assessment of the climate policy and efforts performance of each G20 country, the report identifies gaps and highlights the financial flow necessary for the renewable sector to succeed. The report demonstrates that the transition into low-emission has been particularly successful in Mexico and in France, while particularly lagging in Canada and Saudi Arabia.

Tags: Carbon

 

By Lynn L. Bergeson

On October 30, 2018, Earthjustice and the Clean Air Task Force submitted to the U.S. Environmental Protection Agency (EPA) a petition “to amend its ‘aggregate compliance’ approach to the definition of biomass under the Renewable Fuel Standard (RFS) … to prevent the conversion of native grasslands.”  The petition was filed on behalf of 11 organizations, including the National Wildlife Federation and the Sierra Club, and urges EPA’s Administrator Andrew Wheeler to amend regulations related to land permissibility for renewable biomass production.  Under the 2007 Energy Independence and Security Act’s (EISA) RFS, land conversion for the production of renewable fuel sources is restricted to agricultural land cultivated prior to the enactment of the ruling that is nonforested or uncultivated.  Meant to ensure that growing renewable fuel sources would not significantly increase greenhouse gas emissions, the petition claims that these requirements are not being implemented by EPA due to an aggregate compliance system for measuring land use.  Instead, green groups are requesting that EPA use an individualized compliance approach in evaluating biofuel producers to assure compliance with EISA’s land use restrictions.  The petition also requests that EPA require additional “proof that only EISA-compliant land is used to grow crops displaced by renewable biomass production.”


 

By Lynn L. Bergeson

On September 27, 2018, the California Air Resources Board (CARB) announced its approval of amendments to the Low Carbon Fuel Standard (LCFS). The LCFS has been in place since 2011, in an effort to reduce greenhouse gas (GHG) emissions. Under the original program, the standard required a ten percent reduction in the carbon intensity of transportation fuels in California by 2020. In 2017 only, the LCFS has successfully led to the replacement of billions of gallons of petroleum and natural gas with renewable and sustainable transportation fuels. Despite its success, however, the approved amendments to the LCFS aim to make the program more flexible and comprehensive. Under the new amendments, the LCFS sets new requirements to the reduction in carbon intensity and added credits for alternative aviation fuels. The LCFS now requires a 20 percent reduction in carbon intensity by 2030, parallel to California’s overall 2030 target in climate change reduction. Additional changes also include the restructuration of rebate programs for utility vehicles into one single pool and a new protocol for carbon capture and storage. For further details on the new LCFS, click here.


 

By Lynn L. Bergeson

Researchers in Lithuania and Egypt have discovered how to use N, N-dimethylcyclohexylamine (DMCHA) to break down multilayer flexible packaging (MFP) that pose a threat to the environment. MFP is used in making blister pill packages, candy wrappers, chip packets, and related products, and can contain aluminum, among other toxic substances, which when leaked or incinerated is hazardous to the environment. Although some practices exist to separate the multilayered packaging through recycling technologies, the European Union (EU), for example, limits practices based on energy consumption, carbon dioxide (CO2) emissions, recycling rate, and sustainability. Combined, these limitations allow for a rate of less than 66 percent of MFPs. This new method, however, allows for recycling rates above 99 percent.

The technology developed separates each layer from one another by using DMCHA and other switchable hydrophilicity solvents (SHS) in an ultrasonic treatment to accelerate the process. Once separation of the layers has occurred, the dissolved plastic materials can be recovered without heating, avoiding CO2 production. For further details on the study, click here.


 

By Lynn L. Bergeson

On July 19, 2018, the bipartisan Carbon Utilization Act was introduced by Representatives Scott Peters (D-CA) and David Young (R-IA) to promote biogas and carbon capture utilization and sequestration (CCUS) technologies. Biogas is produced by converting organic waste material into CO2, methane, and other carbon products that then are captured by CCUS technologies to use as energy or fuel. The newly introduced bill incentivizes the use of innovative technologies for farmers, biotech businesses, research programs, and rural development programs.


 
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