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 June 27, 2019, the California Air Resources Board (CARB) approved a rule requiring the gradual transition of fixed-route airport shuttles into 100 percent zero-emission vehicles (ZEV) by 2035. Applied to public and private shuttles that serve the state’s 13 largest airports, including rental car agencies, hotels, and parking facilities, the regulation was approved with an expectation to reduce greenhouse gas (GHG) emissions by at least 500,000 metric tons. According to CARB, the regulation will also benefit shuttle fleet owners through an estimated $30 million in reduced fuel and maintenance costs. Currently, six airports and private businesses serving nine airports already have zero-emission shuttles operating in the state. This new rule presents “a great opportunity for showcasing this process,” stated CARB Executive Officer, Richard Corey. CARB states that airport shuttles are well-suited to zero-emission technology because they operate on short, fixed routes up to 200 miles per day with low average speeds in a stop/go pattern. When operating in this manner, ZEVs are advantageous from an energy and fuel efficiency perspective. The rule will require annual reporting of vehicles to CARB in 2022, and end in 2035 with full compliance of ZEV airport shuttles.


 

By Lynn L. Bergeson

On June 3, 2019, the U.S. Government Accountability Office (GAO) released a report to the U.S. Senate on the Renewable Fuel Standard’s (RFS) program effects on gas prices and greenhouse gas (GHG) emissions. Titled Renewable Fuel Standard: Information on Likely Program Effects on Gasoline Prices and Greenhouse Gas Emissions, the report suggests that increases in gas prices outside of the Midwest (which have now diminished) were associated with the nationwide RFS, and that variations in gas prices likely depended on state-by-state transport and storage of ethanol costs. In addition, price increases occurred in states that did not have the initial infrastructure to blend and store ethanol. Regarding GHG emissions, the report states that RFS has had a limited effect, if any. GAO provided two reasons for this limited effect: (1) RFS relies on conventional corn-starch ethanol, which has smaller potential to reduce GHG emissions; and (2) most corn-starch ethanol has been produced in plants that are exempt from emission reduction requirements. In addition, GAO reports concerns that RFS will not meet the GHG emissions reduction goals that it envisioned by 2020. Lastly, GAO reports that the renewable identification numbers (RIN) had a small effect on prices. EPA analysis identified areas of concern within RINs, which included possible fraud in the market, price volatility, and concerns about the impact they have on small refiners.

Tags: RFS, GHG

 

By Lynn L. Bergeson and Ligia Duarte Botelho, M.A.

Recently, the State of New Jersey released its draft 2019 Environmental Management Plan (EMP), which aims to achieve 100 percent carbon neutral electricity generation and maximum transition to electrification of the building and transportation sectors by 2050. In addition to these goals, New Jersey also intends to reduce GHG emissions to meet the New Jersey Global Warming Response Act (GWRA) GHG limits. GWRA’s 2050 target requires that New Jersey reduce GHG emissions by 80 percent from 2006, which is equivalent to 25.4 million metric tons (MMT) of carbon dioxide. Doing so in the most cost effective and beneficially economic way is critical to the state, which will be considering the entirety of its energy demand. Part of New Jersey’s plan is to reduce carbon by incentivizing:

  • The deployment of renewable generation;
     
  • Carbon neutral distributed energy resources;
     
  • Upgrades to the grid that handles variable electricity loads; and
     
  • Decreased energy demand through efficiency and conservation measure.
The full draft 2019 EMP can be accessed here.
Tags: GHG

 

By Lynn L. Bergeson

On June 2, 2019, the International Air Transport Association (IATA) announced the approval, by the IATA 75th Annual General Meeting (AGM), of the United Nations’ (UN) International Civil Aviation Organization (ICAO) resolution, which calls governments to continue work on the implementation of the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). The first global carbon pricing instrument for an industry sector, CORSIA will cap carbon dioxide emissions from international aviation at 2020 levels (carbon-neutral growth (CNG)). Between 2020 and 2035, CORSIA aims to mitigate over 2.5 billion tonnes of carbon dioxide generating at least $40 billion in finance for carbon reduction initiatives. AGM urged ICAO member states to take a number of measures:

  • Consider participation in CORSIA in the pilot phase;
     
  • Align domestic regulations on the monitoring, verification, and reporting of emissions with CORSIA’s standards, preventing market distortions through its requirements;
     
  • Implement CORSIA as the single global market-based mechanism for climate change mitigation; and
     
  • Avoid the implementation of overlapping/duplicate measures such as unilateral carbon taxes.

IATA’s Director General and Chief Executive Officer (CEO) stated: “CORSIA is a landmark accomplishment. It is a concrete, well-defined way forward to cap global emissions from international aviation. States must not compromise it with inconsistent implementation or by adding a patchwork of taxes on top of it. Its vital mission is to stop growth in net emissions from aviation.” AGM also discussed steps beyond CORSIA, setting the goal to cut net emissions by half of 2005 levels by 2050. Focused on a long-term strategy, IATA calls for investments in better efficiency measures such as sustainable aviation fuels, new aircrafts, and better procedures.


 

By Lynn L. Bergeson

In April 2019, Navius Research Inc. (Navius Research) published a report titled “Biofuels in Canada 2019: Tracking biofuel consumption, feedstocks and avoided greenhouse gas emissions.” Using public data, the report analyzes the volume of transportation biofuels consumed in each Canadian province and estimates the impact of this consumption on greenhouse gas (GHG) emissions and transportation energy costs. An increase in both ethanol and renewable fuel consumption is noted in the report, which has led to reduced fuel expenditures in Canada by 0.42 percent from 2010 through 2017. This decreased expenditure is relative to a counterfactual scenario without biofuel consumption. Relative to this counterfactual scenario, differences in fuel energy density and fuel costs, Canada has ended up paying more taxes due to biofuel blending and consumption.


 

By Lynn L. Bergeson

On March 13, 2019, the European Commission (EC) published a fact sheet on the sustainability for biofuels specified.  EC adopted a delegated act that sets out the criteria for determining high low indirect land-use change (ILUC) risk feedstock for biofuels and the criteria for certifying ILUC-risk biofuels, bioliquids, and biomass fuels.  ILUC-risk fuels consist of fuels produced from food and feed crops that significantly expand globally into land with high carbon stock (high ILUC-risk fuels).  The consequences of creating high ILUC-risk fuels relate to the release of greenhouse gas (GHG) emissions, which negates the emissions savings from the use of biofuels rather than fossil fuels.  ILUC is addressed in the delegated act through two measures:   one measure sets national limits for the total contribution towards the renewable energy targets for biofuels, bioliquids, and biomass fuels from food or feed crops; and the other measure sets national limits as Member States’ 2019 level for the period 2021-2023.

Tags: EC, Biofuels, ILUC, GHG

 

By Lynn L. Bergeson

On February 12, 2019, the U.S. Environmental Protection Agency (EPA) published its draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2017 (Emissions Inventory) for public review. EPA is requesting recommendations on how to improve the overall quality of the Emissions Inventory, which is expected to be issued in final in April 2019. The Emissions Inventory tracks U.S. greenhouse gas emissions and sinks by man-made source and economic sector since 1990. Once it is prepared in final, the Emissions Inventory will then be submitted to the United Nations in accordance with the Framework Convention on Climate Change. The deadline for comment submission is March 14, 2019; the full Emissions Inventory can be accessed here. In addition, EPA has also developed an interactive tool for interested parties to access the data from the national greenhouse gas inventory. Users can create customized graphs, download data, and analyze trends over time. Once the Emissions Inventory is published in April, the national greenhouse gas inventory will be updated accordingly.

Tags: EPA, GHG

 

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 April 13, 2018, Neste, a Biobased and Renewable Products Advocacy Group (BRAG®) member, announced that Red and White Fleet cruise company is committing to switch its entire fleet of vessels from conventional diesel to 100 percent Neste MY Renewable Diesel. This drop-in low-carbon biofuel cuts greenhouse gas (GHG) emissions by up to 80 percent and allows for reductions in engine-out emissions while enhancing fleet performance. Switching to renewable diesel has not impacted the Fleet’s fueling procedures or maintenance intervals while resulting in longer fuel filter life and a reduction of soot. "We are excited to partner with Red and White Fleet by providing them with a fuel that is clean, safe, renewable and odor free,” stated Jeremy Baines, Vice President of Sales, Neste US, Inc. “Their decision places them amongst a growing list of progressive and forward-thinking San Francisco companies that want to ensure a better world through sustainable solutions.”

Tags: Neste, GHG, Biofuel

 
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