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 December 6, 2016, EPA held a hearing on its proposed Renewables Enhancement and Growth Support rule.  The proposed rule would update the regulatory structure to allow biofuel producers to process and convert biomass at different facilities, update fuel regulations to allow for more high-ethanol fuel blends in flex fuel vehicles, and permit cellulosic biofuels to be produced from new feedstock sources.  Testimony provided by Growth Energy and the Renewable Fuels Association (RFA) focused on the impact of the proposed rule on the development of the E15 market and strengthening ethanol flex-fuel provisions.  Geoff Cooper, the senior vice president of RFA, stated that RFA was opposed to EPA establishing a quality survey program to collect and analyze ethanol flex-fuel samples, and highlighted the different treatment between E10 and E15 regarding volatility. Chris Bliley, the director of regulatory affairs for Growth Energy, also pushed EPA to resolve the vapor pressure relief issue, stating that the proposal would isolate E15 as the only ethanol-blended fuel without Reid Vapor Pressure (RVP) relief in conventional areas.  Bliley supported the development of cellulosic biofuels through the use of biointermediates and new pathways, as well.  More information on the proposed rule is available in the BRAG blog post EPA Announces Public Hearing For Proposed Renewables Enhancement and Growth Support Rule.   The proposed rule was published in the Federal Register on November 16, 2016.  Comments are due by January 17, 2017, at 5:00 p.m. (EST).


 

As previously reported in the Biobased and Renewable Products Advocacy Group’s (BRAG®) Biobased and Renewable Products Update of November 11, 2016, the U.S. Environmental Protection Agency (EPA) has issued a notice in the Federal Register of a public hearing for the proposed “Renewables Enhancement and Growth Support Rule.”  The proposed rule updates the regulatory structure to allow biofuel producers to process and convert biomass at different facilities, update fuel regulations to allow for more high-ethanol fuel blends in flex fuel vehicles (FFV), and permit cellulosic biofuels to be produced from new feedstock sources.  EPA is seeking comment on the programs covered in the proposal, as well as renewable identification number (RIN) generation for renewable transport fuels and regulatory requirements for facilities that could use carbon capture and storage (CCS) in the future production of renewable fuels.  More information about the proposed rule is available in the BRAG blog post “ EPA Announces Public Hearing For Proposed Renewables Enhancement and Growth Support Rule. ”   The proposed rule was published in the Federal Register on November 16, 2016.  Comments are due by January 17, 2017, at 5:00 p.m. (EST).


 

Bergeson & Campbell, P.C. (B&C®) is pleased to offer a complimentary webinar that will include a review of the Chemical Data Reporting (CDR) rule elements, a highlight of changes that will come into play for 2016, and some helpful hints on how to get prepared. Kathleen M. Roberts, Senior Regulatory Consultant at B&C; and Executive Director of the Biobased and Renewable Products Advocacy Group (BRAG®), and Richard E. Engler, Ph.D., Senior Chemist at B&C, will discuss the basic requirements of CDR reporting that apply to manufacturers and importers of chemical substances subject to the Toxic Substances Control Act (TSCA), as well as new changes, which include:

  • Expansion of years to report on production volume information;
     
  • Varied reporting thresholds for subject chemicals;
     
  • Potential exclusion of reporting exemptions; and
     
  • Utility of CDR data for Next Generation Compliance initiatives.

The webinar will be presented on May 3, 2016, from 1:00 p.m. - 2:00 p.m. (EDT), and will consist of 45 minutes of presentation, followed by a 15 minute Q&A period. Registration is available online. Please contact .(JavaScript must be enabled to view this email address) with any questions.