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 February 23, 2017, the Sierra Club filed a notice of intent to sue EPA for failure to conduct the required environmental impact analysis on the RFS program.  The notice states that EPA failed to assess and report to Congress on the environmental and resource conservation impacts of the RFS program and failed to complete the required anti-backsliding study to determine whether the renewable fuel volumes adversely impacted air quality.  According to the notice, EPA has issued only one triennial report on the environmental impact of the program despite the requirement under the Energy Independence and Security Act of 2007 (EISA) that EPA report to Congress every three years.  EISA also mandates that EPA complete an anti-backsliding study within 18 months of the law’s passage, which EPA has failed to conduct.  Although EPA has made commitments to complete the second triennial report by December 31, 2017, and the anti-backsliding study by September 30, 2024, the Sierra Club stated that such a delay disregards the purpose of the reporting requirements, which is to inform EPA’s annual RFS volume developments and inform Congress of the program’s impacts.