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 October 11, 2016, the Biofrontiers platform, a group of industry and civil society stakeholders brought together by the European Climate Foundation, released policy recommendations for the European Union’s (EU) 2030 climate policy.  The group stated that the transport sector has become the largest source of carbon emissions in the EU, and is therefore an urgent area to tackle following the Paris climate change agreement.  Policy recommendations put forth by the Biofrontiers platform, as stated in the Biofrontiers report, include:
 




 
Energy and climate policy for 2030 should ensure deep cuts to lifecycle emissions and safeguard food, soil, water and biodiversity. Incentives should be linked to the availability of sustainable feedstocks.  Site-specific assessments are needed to create confidence in feedstock supply chains.
 


 
Within [current EU energy policy focusing on fuels with low carbon intensity], support for advanced alternative fuels should be prioritised.
 


 
A realistic and responsible binding target for fuel suppliers for advanced alternative fuels in 2025, with a higher target range set for 2030.
 



 
Policymakers should have regard to other objectives in forestry, climate, agriculture and waste management.  Where there may be competition between liquid transport fuel production from wastes and other waste management options, policy should “encourage the options that deliver the best overall environmental outcome,” as required by the Waste Framework Directive.
 

 
Any 2030 policy framework should be designed with flexibility to allow novel fuel technologies and different feedstocks to be eligible for support as they arrive on the market, subject to life cycle analysis and sustainability assessment.

 

On March 30, 2015, the National Biodiesel Board (NBB) submitted a petition to EPA seeking reconsideration and a request for stay of EPA's approval of the Argentinian Camara Argentina de Biocombustibles (CARBIO) Alternative Biomass Tracking Program. According to the NBB press release, EPA failed to provide an opportunity for public comment on the EPA decision and a lack of transparency as to how the Argentinian biodiesel producers will demonstrate compliance with the Renewable Fuel Standard (RFS). NBB notes that EPA's delay in establishing RFS volumes has destabilized the U.S. biodiesel industry and the anticipated influx of biodiesel, as a result of the CARBIO program approval, will only make the U.S. situation worse. NBB separately filed a lawsuit challenging EPA's alternate renewable biomass tracking requirements. Nat'l Biodiesel Bd. v. EPA, D.C. Cir. No. 15-1073 (Mar. 30, 2015). NBB asserts that EPA's approval of the CARBIO plan provides a new opportunity to review the tracking provisions that were included in a 2010 rulemaking.

 

 

During a summit in Brussels on October 23-24, 2014, European Union (EU) leaders agreed to a blueprint to guide climate and energy policy through 2030. The overall goals of the blueprint are to achieve a 40 percent emissions reduction by 2030, relative to 1990 emissions levels, as well as a target of 27 percent for total energy consumption in the EU being provided by renewable sources by 2030. The EU already has a 20 percent emissions reduction target for 2020. The target is expected to help build and maintain momentum for the larger 2030 emissions goal. Individual countries will not be responsible for the 27 percent renewable energy goal, rather, the EU as a whole wants to reach that level of renewable energy. In order to assist countries in achieving this goal, the EU is increasing the current 300 million Emissions Trading System (ETS) allowances to 400 million to help fund low-carbon innovation. More information about the 2030 Climate and Energy Policy Framework can be found in the EU's post-summit communique.