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 Lauren M. Graham, Ph.D.

On March 29, 2017, the Urban Air Initiative (UAI) released a statement claiming that the Coordinating Research Council’s (CRC) study on fuel emissions was biased and flawed.  According to UAI, the match blending of test fuels in the study fails to recognize the performance of ethanol in real world fuels, including improving fuel quality and reducing toxic tailpipe emissions.  UAI stated that performing match blending in a lab using a custom test fuel rather than real world fuel discredits the study, and the inaccurate data would likely lead EPA to continue to limit the use of higher ethanol blends.  To encourage the development of more accurate information, UAI is working on a guidance document to assist researchers to better understand the changes in fuel properties when evaluating ethanol and emissions to ensure that lab test fuels match the fuels in use.


By Lauren M. Graham, Ph.D.

On March 23, 2017, the California Environmental Protection Agency’s Air Resources Board (ARB) announced the release of new carbon intensity pathways for fuels certified under the low carbon fuel standard (LCFS) using the CA-GREET 2.0 model.  Of the 18 pathways approved in March, eight are first generation biodiesel carbon intensity pathways and four are second generation renewable diesel carbon intensity pathways.  A pathway for biodiesel produced from used cooking oil has been provisionally certified, as well.  The approved pathways can be used for credit reporting purposes beginning with reports for Q1 2017.  The LCFS regulation aims to reduce the carbon intensity of fuels sold in California by 10 percent by 2020 in line with the California Health and Safety Code mandate to reduce greenhouse gases in California.


On March 24, 2017, Neste, a member of BRAG®, announced its approval of draft proposals by the Swedish government regarding mandated reductions in traffic fuel emissions and the continued tax exemption for high-blended biofuels.  By 2030, the government aims to reduce carbon emissions from transportation by 70 percent.  In addition to reducing carbon emissions, the ambitious targets and long-term perspective will help support innovation and investments in biofuels.  Neste, which has a strong focus on developing cost-efficient technologies to convert forest residues into biofuels, stated that the substantial amount of forest-based raw materials in the country will likely play a key role in achieving the proposed goals.

On March 15, 2017, the National Aeronautics and Space Administration (NASA) published the results of a joint study with German and Canadian agencies on the impact of biofuels on jet engine pollution, including emissions and contrail formation.  The results demonstrate that the use of a 50-50 blend of aviation fuel and fuel of hydro processed esters and fatty acids from camelina plant oil reduced particle emissions by 50-70 percent.  Since soot emissions are a major driver of contrail formation, the particle reductions observed with the use of biofuel are expected to result in a reduced concentration of ice crystals in the contrails, thus, minimizing the impact of the contrails on the environment.  NASA plans to continue to study and demonstrate the potential benefits of biofuels, particularly on their proposed supersonic X-plane.

■  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 December 1, 2016, the Government Accountability Office (GAO) testified at a hearing before the U.S. Senate Subcommittee on Regulatory Affairs and Federal Management, Committee on Homeland Security and Governmental Affairs regarding the feasibility of the Renewable Fuel Standard (RFS) program .  GAO stated that the goals of the program, to reduce greenhouse gas (GHG) emissions and expand the nation’s renewable fuels sector, were unlikely to be met as envisioned due to the limited production of advanced biofuels.  Despite the ability of advanced biofuels to achieve greater GHG reductions, conventional biofuels account for the majority of biofuel blended into domestic transportation fuels under the RFS.  According to experts interviewed by GAO, the limited use of advanced biofuels is due to high production costs.  The testimony was based on two reports that GAO published on November 28, 2016, which reviewed the federal effort that supported research and development into advanced biofuels and the management of the RFS program by the U.S. Environmental Protection Agency (EPA).  During the hearing, GAO highlighted the suggestions made by experts in its November reports regarding federal actions that could improve the RFS framework and policy alternatives that could more efficiently reduce GHG emissions.



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.


On September 14-15, 2016, the U.S. Department of Energy (DOE) hosted a two-day workshop with lead experts on aviation biofuels exploring opportunities to increase competitiveness of alternative jet fuels. The Alternative Aviation Fuel Workshop was organized in four parallel breakout sessions covering the economic and technical competitiveness, fuel conversion and scale-up, environmental sustainability and life-cycle benefits, and feedstock and product supply chains of lignocellulosic biomass based aviation biofuels. During the workshop, Wally Tyner, a professor of Agricultural Economics from Purdue University, presented preliminary results from his team's research into greenhouse gas (GHG) emissions from the production of soybean based biodiesel. The study focuses on biofuels-induced land use change (LUC) emissions, critically finding that emissions could be as much as 70 percent lower than previously thought (based on induced land use change emissions recently adopted by the California Air Resources Board). Tyner's team used the most recent version of the Global Trade Analysis Project model that reflects changes in agriculture and biofuel that occurred between 2004 and 2011. This model includes expanded biofuel policies as well as improvements in agriculture efficiency such as double cropping. The combination of advancing LUC emissions science and improved agricultural practices are continually increasing confidence in the real environmental benefits of biobased fuels.


On August 25, 2016, researchers at the University of Michigan, led by research professor John M. DeCicco, Ph.D., published "Carbon balance effects of U.S. biofuel production and use," a study examining the impact of biofuel production on carbon dioxide (CO2) emissions. The study, funded in part by the American Petroleum Institute, examined USDA crop-production data and determined that the increasing use of biofuels has resulted in a net increase of CO2 emissions, with only 37 percent of CO2 emissions from biofuel combustion offset by the increased CO2 uptake from biofuel crops. Biofuels have generally been assumed to be inherently carbon neutral because the CO2 released by combustion is equal to the CO2 that was originally pulled from the atmosphere through photosynthesis. In this study, Dr. DeCicco did not assume that biofuels were carbon neutral, going through crop, biofuel, and fossil fuel production data, as well as vehicle emissions, to determine that biofuels produce more CO2 emissions than gasoline.

MichBio, Michigan's biosciences industry association, issued a strong condemnation of the study, calling it "flawed" and based on inappropriate modeling assumptions. The lifecycle analysis used by Dr. DeCicco provides a carbon storage credit to fossil fuels from existing forests and agriculture that MichBio argues is wholly inappropriate due to the lack of an economic relationship between the petroleum industry and agriculture and forestry. MichBio concedes that biofuels are not carbon neutral, but states that the issue is more complex than Dr. DeCicco implies: "No competent life cycle assessment assumes that biofuels are carbon neutral, only that the actual carbon content of the fuels came from the atmosphere in the first place and returns to the atmosphere when it is combusted. That much is simple chemistry, and without argument. For the rest of the biofuel life cycle, the question of carbon neutrality is very much a research question, not a decided issue as DeCicco would have one believe." MichBio goes on to reference an independently funded study by the U.S. Department of Energy (DOE) Argonne National Laboratory that showed "conventional biofuels reduce greenhouse gas emissions by an average of 34 percent over their lifecycle, while advanced biofuels can reduce emissions by 100 percent or more over conventional gasoline."

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