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.


 

 

On May 18, 2015, the American Council On Renewable Energy (ACORE) issued a white paper arguing that "Co-location Requirements under the RFS Impede Advanced Biofuels Development." The paper was sent to EPA. It requests that EPA clarify its definition of feedstock material under the federal Renewable Fuel Standard (RFS) so that biofuels producers that pre-process their feedstocks away from final refineries are no longer prohibited from generating renewable identification numbers (RIN) under the RFS, and therefore contributing to the volumetric goals of the statute. Senior staff from several such producers contributed to the white paper, including Algenol Biofuels, Cortus Energy, Fulcrum Bioenergy, LanzaTech, and Solena Fuels.


 
(BIO) released a new white paper on "Estimating Chilled Investment for Advanced Biofuels Due to RFS Uncertainty," along with an accompanying press release.

BIO examined the impact of EPA's recent inability in administering the federal Renewable Fuel Standard (RFS) on investment in advanced and cellulosic biofuels. It has found that EPA's delay in issuing the final 2013 and 2014 RFS rules, among other delays in RFS administration, is responsible for most of the "$13.7 billion shortfall in necessary investments for capacity to meet the RFS goals." According to the white paper, the delays have "undercut the industry's ability to create new employment opportunities by more than 80,000 direct jobs."

This white paper is released as RFS stakeholders are eagerly awaiting EPA's expected release of the final 2014 RFS rule later this year. Biofuels stakeholders would like to see the Agency withdraw and re-issue EPA's proposed 2014 RFS rule with stronger volumetric requirements and a different methodology, while oil and gas industry stakeholders are pressing EPA to issue the final 2014 RFS in line with the volume requirements and methodology contained in the proposed rule.

Tags: RFS, biofuels, EPA

 

On April 28, 2015, the European Parliament approved a draft law restricting crop-based biofuels in order to encourage production of advanced biofuels with low-risk ILUC and cut greenhouse gas (GHG) emissions. The law, that was discussed in the April 23, 2015, Biobased and Renewable Products Update, applies to legislation requiring EU Member States ensure that at least 10 percent of energy used in transport by 2020 is renewable. Under the new law, no more than 7 percent of energy consumption by 2020 can be first-generation biofuels, resulting in at least 3 percent of energy consumption coming from advanced biofuel. The law also requires the reporting of GHG emissions caused by ILUC and the publication of data on ILUC-related emissions. Member States have until 2017 to enact the legislation.


 

On April 24, 2015, EPA released a Federal Register notice inviting comment on analysis of the greenhouse gas (GHG) emissions produced during the production and transport of Brassica carinata (carinata) oil feedstock for use in the production of biofuels. The plant is not used for food in the U.S., and has high concentrations of erucic acid, making it attractive for use in biolubricants and biopolymers, as well as biofuels. EPA anticipates that biofuels produced using carinata oil will qualify as advanced biofuels, and the analysis will be used to determine if the biofuels will meet necessary GHG reductions required for qualification as renewable fuel under the RFS program. The notice is open for comment until May 26, 2015.


 

The Oil Price Information Network (OPIS) spoke with BRAG's Richard E. Engler, Ph.D., Senior Policy Advisor with B&C, regarding the application of the Toxic Substances Control Act (TSCA) to oils made from algae feedstocks and other non-traditional bio-materials. The resulting article, "TSCA Nomenclature May Be Barrier for Advanced Biofuels," from the OPIS Ethanol & Biodiesel Newsletter is excerpted below, and reprinted in full at the link with permission from OPIS.


Any number of complications could trip up the commercial use of an advanced biofuel, but one that should attract attention is the requirement that all fuels be listed on Toxic Substances Control Act (TSCA) Inventory of Chemical Substances.
 
This requirement has the potential to raise reporting requirements that could be a barrier to sales of oils made from algae feedstocks, as well as other non- traditional biomaterials, said Richard Engler, Ph.D., with Bergeson & Campbell, PC.
 
"TSCA is based on identification of what you are making. So if you have a single, defined molecule, like ethanol, it's simple," he told OPIS in a follow- up to his presentation at last month's Advanced Bioeconomy Leadership Conference.
 
Ethanol is a Class 1 chemical on the TSCA list. Its identity does not depend on how it is made. And since one ethanol is chemically the same as another, Engler explained that a new producer of ethanol can use the existing TSCA Inventory registration.
 
But most hydrocarbon-based and bio-based fuels are Class 2 chemicals, which are identified differently, Engler said. Class 2 compounds are defined as having unknown or variable composition, complex reaction products, and biological materials.

The article goes on to explain how Class 2 compounds are named, where there is flexibility in naming plant, animal, and marine sourced oils and where there is not, and solutions for which the advanced biofuels industry should petition EPA.

Tags: biofuels, TSCA

 

On April 21, 2015, the U.S. Department of Energy (DOE) released the initial installment of its Quadrennial Energy Review (QER). This first installment focuses on ways to modernize the U.S. energy infrastructure to increase the country's energy competitiveness and security. In its QER, DOE points out that while U.S. biofuel production has increased significantly over the past decade -- due largely to the federal Renewable Fuel Standard (RFS) --"[c]ontinued growth in ethanol use will depend in part on investment in additional distribution capacity; growth in the use of other biofuels, such as 'drop-in' fuels, will depend on continued investment in research, development, demonstration, and deployment." In its fact sheet accompanying the QER, the DOE states that it, along with the U.S. Department of Defense, should continue efforts to help facilitate the production and use of advanced, drop-in biofuels for use in aviation and large vehicles. Moreover, DOE should provide technical support to help investment in infrastructure to dispense higher-level ethanol blends.

The QER, and its recommendations with respect to infrastructure to support the distribution of ethanol, comes at a time when RFS stakeholders are eagerly awaiting the U.S. Environmental Protection Agency's (EPA) release of its final 2014 RFS renewable volume obligations (RVO), or volume requirements. Several biofuels groups expressed opposition to EPA's proposed 2014 RVOs because the proposed reduced RVOs for corn ethanol were based partly on EPA's determination of currently insufficient distribution infrastructure. The biofuels groups opposed to this analysis argued that infrastructure considerations should not go into EPA's calculation of its annual RFS requirements.


 

On April 14, 2015, Members of the European Parliament and certain ministers agreed to limit how biofuels derived from agricultural crops would be accounted for in the European Union's (EU) goal to increase the use of renewable energy. The new law caps the use of first generation biofuels to seven percent of the total energy use being counted towards the EU's renewable energy goal of ten percent. Member States will have the opportunity to reduce the cap of crop-based biofuels at their discretion. The law came about in part from fears about food security and negative indirect land use change (ILUC) occurring due to widespread crop-based biofuels. The EU has used ILUC to calculate the net greenhouse gas (GHG) production of biofuels, despite concerns that it is scientifically flawed. The agreement reached will eliminate the ILUC factor as a way to judge the benefits of fuels in the EU, but will still need to be reported by fuel suppliers. The agreement will be voted on during the April 27-30, 2015, plenary session. Member States will have until 2017 to enact the legislation.


 

On April 9, 2015, the Pentagon released the Rocky Mountain/West Coast/Offshore Bulk Fuels Annual Buy (RMW) solicitation for biofuels on the FedBizOpps website. This purchase program supports the goal set by the Secretary of the Navy to have half of the Department of the Navy's energy come from alternative sources by 2020. Funding to defray additional biofuel costs for the RMW program is provided by the U.S. Department of Agriculture through the Commodity Credit Corporation. Vendors can submit bids with at least 10 percent of alternative fuel up to the maximum allowed by JP-5 and F-76 specifications. The solicitation is for fuel deliveries from October 1, 2015, to September 30, 2016, and proposals must be submitted by May 8, 2015, at 3:00 p.m. (EDT).

Tags: Navy, biofuels

 
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