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.

■  Biotechnology Innovation Organization, “BIO Submits Comments on EPA Renewables Enhancement and Growth Support Rule
 
■  EPA, “Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015
 
■  International Energy Agency, “New Bioenergy Roadmap Guide Released Jointly by IEA and FAO

 

On January 25, 2017, the Urban Air Initiative (UAI), along with the Energy Future Coalition and the states of Kansas and Nebraska, filed a request for correction of information petitioning EPA to correct its models on motor vehicle fuel emissions that limit the use of higher blends of ethanol.  In the petition, UAI claims that EPA continues to publish inaccurate data regarding ethanol emissions that originated with its fuel effects study and vehicular emissions computer model, MOVES2014, and describes the fundamental flaws in the design of the study.  UAI relied on peer reviewed scientific studies to refute EPA’s ethanol emissions estimates, and called on EPA to respond to the request within 90 days.


 

On January 17, 2017, Neste, a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced the rebranding of its “Neste Renewable Diesel” to “Neste MY Renewable Diesel,” and the updating of other names within the renewable products family to “Neste MY” brand names.  Neste MY Renewable Diesel is a low-carbon drop-in renewable fuel that does not require vehicle modifications, and can be refueled into any blending ratio due to its compatibility with existing diesel fuels.  Compared to conventional petroleum diesel, Neste MY Renewable Diesel enables up to 80 percent lower greenhouse gas (GHG) emissions throughout the lifecycle.


 

 

On January 18, 2017, Christopher Grundler, the Director of the Office of Transportation and Air Quality for the U.S. Environmental Protection Agency (EPA), signed a notice inviting comment on its analysis of the upstream greenhouse gas (GHG) emissions from the production of sugar beets for use as biofuel feedstock.  The notice describes the analysis performed, which considers the extraction of non-cellulosic beet sugar for conversion to biofuel and the use of the remaining beet pulp for animal feed, and how EPA may use the analysis to determine whether biofuels from sugar beets qualify as renewable fuels under the Renewable Fuel Standard (RFS) program based on the GHG emission threshold requirement.  The notice states that biofuels from sugar beets could qualify as renewable fuel or advanced biofuel, depending on the type and efficiency of the fuel production process technology used.  A prepublication version of the report is available now, with a final publication date to be announced.  A 30 day public comment period will begin after the formal proposal is published in the Federal Register.


 

On January 12, 2017, USDA released a report on the lifecycle greenhouse gas (GHG) balance of corn ethanol, titled “A Life-Cycle Analysis of the Greenhouse Gas Emissions of Corn-Based Ethanol.”  The study reviewed industry and farm sector performance over the past decade and found that in the United States corn-based ethanol generates 43 percent less GHG emissions than gasoline.  Compared to previous studies, the lifecycle GHG benefits were greater due to improvements in corn production efficiency, conservation practices, and ethanol production technologies.  The report also presented two projected GHG emissions profiles for corn ethanol in 2022, with one assuming a continuation of observable trends and the other analyzing additional improvements that could further reduce the GHG emissions.


 

On November 16, 2016, the White House filed the Mid-Century Strategy for Deep Decarbonization with the United Nations Framework Convention on Climate Change under the Paris climate deal. The strategy highlights the role that U.S. government-funded research, development, and demonstration (RD&D) had on the technological advances of the last century, and the potential to increase the pace and reduce the costs of decarbonization using the full power of U.S. RD&D efforts focused on clean energy technologies.
 
The strategy states that potentially high impact technologies in early stages of development or commercial deployment, such as carbon capture, utilization, and storage (CCUS), advanced nuclear, and second generation biofuels, can benefit from support programs that drive cost reductions through learning and economies-of-scale. The strategy also states that the cost of decarbonization can likely be lowered by public and private RD&D that covers a wide range of technologies as it is unclear how the technologies will progress over time. 

Regarding biofuels, the strategy identified opportunities for RD&D investments to:


 
Reduce biofuel production costs;
 

 
Improve production efficiency;
 

 
Develop “drop-in” fuels that require no changes to existing fuel infrastructure;
 


 
Co-optimize engines with low-carbon fuel to maximize performance and greenhouse gas reductions; and
 
Ensure biomass production and use methods are carbon beneficial.

 

On November 8, 2016, the Roundtable on Sustainable Biomaterials (RSB) announced its members voted unanimously to publish revised Principles & Criteria that streamline the requirements and make them more user-friendly. The decision was announced at the Annual Assembly of Delegates meeting in Hanoi, Vietnam.
 
RSB stated the amendments will offer:
 


 
A new user-friendly format, enabling easy understanding of how to apply the standard; 
 

 
Streamlined and clear impact assessment requirements;
 

 
Integration of the GHG calculation requirement with other available measurement tools;
 

 
A new approach to measure GHG emissions from forestry operations;
 

 
A new requirement that provides a grievance mechanism for workers and local communities; and
 
The addition of an integrated pest management requirement.
 
The RSB Standard is considered a trusted certification by many U.S. and European regulatory agencies, as it verifies that biomaterials are ethical, sustainable, and credibly-sourced.  As a result, the independent multi-stakeholder collective claims, RSC-certified products receive swift product approval and market access.

 

On November 3, 2016, the United Nations Environment Programme (UNEP) released the seventh UNEP Environment Emissions Gap Report, presenting a scientific assessment of global progress towards emissions reductions created by the United Nations Framework Convention on Climate Change (UNFCCC).  The report found that if all Paris Agreement pledges to reduce emissions global temperature are achieved, global temperatures will still rise to more than 2°C over preindustrial levels.  UNEP chief Erik Solheim stated that we need to move faster to mitigate our impact on climate change, with the report calling for strong clean energy and emissions reducing policies before the 2020 tipping point when the warming trajectory will become more difficult to reverse.  The report identifies carbon capture and storage coupled with the use of bio-energy as a key factor to limit warming, but mentions the need to produce sufficient quantities of biomass without harming biodiversity.


 

On October 12, 2016, EPA convened a public advisory committee teleconference of the Biogenic Carbon Emissions Panel.  This advisory meeting discussed comments from chartered Science Advisory Board (SAB) members from the draft report on EPA’s Framework for Assessing Biogenic CO2 Emissions from Stationary Sources.  The SAB panel announced plans to overhaul the current draft report to provide emission examples at various time scales.  This change, to include longer time spans, is supported by industry professionals who believe it better represents the full carbon sequestration benefits created through regrowth of biomass.  Inside EPA (subscription required) quoted the Environmental Defense Fund’s Steven Hamburg, noting that the SAB should “make clear the implications of picking different time horizons, as opposed to a priori picking a time horizon.”  There is not yet a schedule for when the next draft report will be released for review by the full SAB.


 
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