By Lynn L. Bergeson
On April 17, 2019, the Iowa Renewable Fuels Association (IRFA), a Biobased and Renewable Products Advocacy Group (BRAG®) member, spoke at a press conference alongside Iowa Secretary of Agriculture, Mike Naig, on how the approval of small-refinery exemptions (SRE) for the 2018 Renewable Fuel Standard (RFS) blend levels would undermine RFS in an irreversible way. IRFA’s Executive Director, Monte Shaw, pointed out that under current conditions all a refinery needs to show significant disproportionate economic harm to be granted an SRE is to purchase Renewable Identification Numbers (RIN). RINs, also known as compliance credits, can be purchased for as little as eight cents, which undermines RFS and breaks President Trump’s promise to protect the 15-billion-gallon RFS. Shaw concludes: “[t]he bottom line is this: If you grant SREs under these circumstances with eight-cent RINs, then what EPA is really saying is that they will always grant SREs and the hope of a true 15-billion-gallon RFS is dead.”
By Kathleen M. Roberts
On November 14, 2017, the Governors' Biofuels Coalition announced that grain and ethanol industry stakeholders, including the U.S. Grains Council, the Renewable Fuels Association (RFA), and Growth Energy, sent a letter to U.S. Trade Representative Robert E. Lighthizer to request that the U.S. suspend Brazil’s designated country status as a result of a 20 percent tariff on ethanol exports to Brazil. The tariff is to be assessed on all current and future imports of ethanol exceeding a 159-million-gallon quota. Since the U.S. exports nearly 500 million gallons of ethanol to Brazil, the tariff would apply to imports of U.S. ethanol despite an agreement between Brazil and the U.S. regarding zero-duty tariffs for ethanol. In the letter, industry representatives indicate their intent to file a petition for a suspension of Brazil’s status in the Generalized System of Preferences (GSP), which requires WTO member countries to treat imports from all other WTO member countries as those countries would treat their most-favored trading partners. The letter states that given “their protectionist and market distorting actions in implementing a tariff rate quota that affects imports of U.S. ethanol, and pursuant to their obligations under 19 U.S. Code 2462, we believe that Brazil is no longer eligible for GSP trade benefits.”
By Lauren M. Graham, Ph.D.
On August 1, 2017, the U.S. Environmental Protection Agency (EPA) held a public hearing to hear from all segments of the fuel industry on the proposed rule to set the 2018 renewable volume obligations (RVO) under the Renewable Fuel Standard (RFS) program. Among the nearly 150 individuals and organizations scheduled to testify at the hearing were numerous biofuel industry stakeholders who praised EPA for issuing the proposed rule on time and for maintaining the statutory 15 billion gallon volume requirement for conventional renewable fuels, but urged the agency to increase the proposed requirements for advanced and cellulosic fuels.
During its testimony, the Renewable Fuels Association (RFA) stated that it believes that EPA “erred on the side of pessimism with regard to the potential for significant growth in cellulosic ethanol commercialization.” According to Bob Dinneen, Chief Executive Officer (CEO) of the RFA, many plants are in the process of adding bolt-on fiber conversion technology to their existing facilities, which could dramatically increase cellulosic ethanol production next year. RFA intends to provide EPA with updated projections for cellulosic fuel before the comment period ends. Dinneen also highlighted concerns with Renewable Identification Number (RIN) market manipulation and suggested that EPA continue to allow imported biofuels to help comply with the RFS program.
With a group of approximately 20 speakers, the National Biodiesel Board (NBB) highlighted key data and information regarding market realities and underutilized capacity, and the impacts on small businesses and manufacturing, feedstock availability, and consumer choice. Donnell Rehagen, NBB CEO, stated that the “current numbers shortchange the progress we have made. They are a step back for the RFS, job creation, small businesses and rural economies.” Rehagen clarified that “these steps backwards are not about paper but people.”
The Renewable Energy Group (REG) informed EPA that ample feedstocks, technology and quality advances, and subsidized imported biofuel are three reasons why the agency should increase the biomass-based diesel and advanced biofuel minimum volumes. Derek Winkel, Executive Director of Manufacturing, stated that “investments [into the biofuel sector] would not have been made without increasing demand for biodiesel and renewable diesel. This demand, in part, is supported by a strong, growing and consistent RVO and RFS.” Paul Nees, Executive Director of REG’s Operations Control Team, testified that “[t]he domestic biodiesel industry is ready and able to fulfill demand gaps with low-cost, high-quality fuel with no market disruption.”
During its testimony, the Iowa Renewable Fuels Association (IRFA) suggested that the recent verdict in Americans for Clean Energy v. EPA should radically alter the factors EPA considers when determining RFS levels this year and going forward. “The Court clearly affirmed that Congress’ intent for the RFS from the very beginning was to crack the petroleum monopoly and to push biofuels into the marketplace,” stated Monte Shaw, IRFA Executive Director. “Whether in a reset discussion or in setting biodiesel and ethanol levels, the EPA must act according to the clear directive from the Court.”
The American Coalition for Ethanol's (ACE) testimony highlighted its view on conventional biofuel levels, the general waiver authority as it relates to inadequate domestic supply, the use of the reset provisions, and updating the greenhouse gas modeling for corn ethanol as it relates to Brazilian sugarcane ethanol. The Coalition intends to detail its position on these topics in written comments. Jonathon Lehman, ACE legislative counsel, also praised Nebraska Governor Pete Ricketts and Iowa Governor Kim Reynolds for their strong public support for keeping the RFS on track.
Stakeholders representing the oil industry were also present to testify to the problems they see with the RFS program, including the representatives from the American Petroleum Institute (API), the American Fuel and Petrochemical Manufacturers (AFPM), and Valero.
Written statements and supporting information concerning the proposed rule are available under Docket ID No. EPA-HQ-OAR-2017-0091. As stated in the Federal Register notice, EPA will consider the written comments with the same weight as any oral comments presented at the public hearing.
On June 9, 2017, the U.S. Environmental Protection Agency (EPA) announced the winners of the 2017 Green Chemistry Challenge Award (GCCA). We applaud this year’s winners. This is EPA’s 22nd year of using the GCCA to honor green chemistry technologies that spur economic growth, reduce costs, and decrease waste. We are saddened that this very successful voluntary program is slated to be defunded in the President's Fiscal Year (FY) 2018 budget, which, of course, must be approved by Congress and is unlikely to be in its current form. Those who value the green chemistry program may wish to consider contacting their Senators and Representatives to encourage continued support of this highly successful and important program. It has had outsized benefits for such a modestly funded program.
This year's winners and technologies are:
- Merck & Co., Inc. in Greener Synthetic Pathways - Letermovir: A Case Study in State-of-the-Art Approaches to Sustainable Commercial Manufacturing Processes in the Pharmaceutical Industry
Merck’s approach was to design an efficient synthesis as early as possible in the drug Letermovir’s process development. Using “high-throughput” techniques, Merck was able to find a low-cost, stable, and easily recyclable catalyst along with other process improvements that increase the yield, and reduce the raw material costs by 93 percent, the water usage by 90 percent, and the carbon footprint by 89 percent.
- Amgen Inc. and Bachem in Greener Reaction Conditions - Green Process for Commercial Manufacture of Etelcalcetide Enabled by Improved Technology for Solid Phase Peptide Synthesis
Amgen Inc. worked with Bachem to improve the manufacturing process for the active ingredient in ParsabivTM, a drug that treats secondary hyperparathyroidism in adult patients with chronic kidney disease. By redesigning the peptide manufacturing process to use four optimized stages rather than the original five stages, Amgen and Bachem were able to achieve a 500 percent increase in manufacturing capacity while reducing chemical solvent use by 71 percent, manufacturing operating time by 56 percent, and manufacturing cost by 76 percent.
- The Dow Chemical Company and Papierfabrik August Koehler SE in Designing Greener Chemicals - Breakthrough Sustainable Imaging Technology for Thermal Paper
While there is still not a definitive answer as to whether the use of bisphenol A (BPA) in thermal paper may present risk, Dow and Koehler sought an innovative alternative that not only avoids the need for BPA (or analogs that have similar toxicological properties), but also eliminates some of the drawbacks of thermal paper, notably that exposure to sunlight or other heat sources often destroys the image. Together they developed a three-layer paper. The top layer is an opaque, light-color.When heat is applied in the printing head, the hollow particles that make up that opaque layer collapse and become transparent, showing an underlying dark layer only at those points. The paper is designed to work in existing equipment, so there is no need for retailers to replace equipment.
- UniEnergy Technologies LLC in Small Business - The UniSystemTM: An Advanced Vanadium Redox Flow Battery for Grid-Scale Energy Storage
UniEnergy Technologies, LLC (UET) and the Pacific Northwest National Laboratory (PNNL) developed and commercialized an advanced vanadium redox flow battery that allows cities and businesses more access to stored energy. The vanadium electrolyte has double the energy density of prior chemistries, and a much broader operating temperature, allowing for a longer lasting battery that can be deployed in nearly any ambient environment on earth. Additionally, the electrolyte, with a chloride-based chemistry complex, is more stable than traditional sulfate-based chemistries, and because it is water-based and does not degrade, the batteries are non-flammable and recyclable.
- Professor Eric J. Schelter of the University of Pennsylvania in Academic - Simple and Efficient Recycling of Rare Earth Elements from Consumer Materials Using Tailored Metal Complexes
Professor Eric Schelter developed a simple, fast, and low-cost technology to help recycle mixtures of rare earth elements (La-Lu, Sc, and Y). These elements are integral to modern technologies, but have a highly energy intensive and waste generating mining, refining, and purification process. Currently, only one percent of these materials are recycled, but Professor Schelter’s group has developed tailored organic compounds that can simply and effectively separate mixtures of these metals. A recent U.S. Department of Energy (DOE) grant will support further development of this technology to turn these into industrial viable recycling processes.
The GCCA winners were honored on June 12, 2017, at a ceremony in Washington, D.C. in conjunction with the 21st Annual Green Chemistry & Engineering Conference.
By Lauren M. Graham, Ph.D.
On April 24, 2017, Bob Dineen, President and CEO of the Renewable Fuels Association (RFA) sent a letter to EPA Administrator Scott Pruitt requesting that the 2018 Renewable Fuel Standard (RFS) Renewable Volume Obligations (RVO) rulemaking remain on schedule and maintain the conventional renewable fuel requirement at the statutory level of 15 billion gallons. According to the letter, regulatory certainty and sufficient lead time for planning are required to allow regulated parties to adapt and comply with the RFS.
The letter states that ethanol producers are set to produce a record supply of 16 billion gallons of conventional renewable fuel in 2017, which is well above the 15-billion-gallon conventional renewable fuel RVO, and refiners and blenders have increased the inclusion of ethanol in U.S. gasoline. Additionally, data from the Energy Information Administration (EIA) demonstrates that, on average, the ethanol content of gasoline consumed in the U.S. in 2016 was above the purported “blend wall.” Dinneen urged Pruitt to ensure a timely RVO rulemaking process to allow the evolution of the marketplace to continue.
By Lauren M. Graham, Ph.D.
On April 21, 2017, AkzoNobel announced the 20 finalists for its Imagine Chemistry initiative. The initiative, which was launched earlier this year as reported in the Biobased and Renewable Products Advocacy Group’s (BRAG®) blog post “AkzoNobel Launches Global Chemicals Start-Up Challenge,” aims to help solve real-life chemistry-related challenges and uncover sustainable opportunities for the Company's Specialty Chemicals business. Of the 20 projects selected, four focus on cellulose-based alternatives to synthetics, three focus on biobased and biodegradable surfactants and thickeners, and two focus on biobased sources of ethylene and ethylene oxides. All finalists will participate in a three-day event at AkzoNobel’s research facility to further develop their business ideas and concepts. A brief description of each project is available on AkzoNobel’s website.
On February 22, 2016, the Renewable Fuels Association (RFA) published the results of a study on the impact of the ethanol industry on the U.S. economy. The study, which was commissioned by ABF Economics, found that the U.S. ethanol industry contributed over $42 billion to the nation’s gross domestic product (GDP) and supported 340,000 jobs in 2016. Additionally, the report states that the ethanol industry provided significant contributions in terms of displacing imported crude oil and petroleum products, and generating tax revenue.
According to the report, the U.S. produced 15.2 billion gallons of ethanol in 2016, which resulted in:
||Nearly $14.5 billion to the U.S. economy from manufacturing;
||More than $22.5 billion in income for American households;
||An estimated $4.9 billion in federal tax revenue and $3.6 billion in revenue to state and local governments; and
||The displacement of 510 million barrels of imported oil.