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Biobased Products News and Policy Report
May 7, 2015
Biofuels Digest Series On TSCA And The Bioeconomy
Biofuels Digest is running a "Thought Leadership" series of articles highlighting some of the ways the Toxic Substances Control Act (TSCA) applies to biobased products. The articles, written by Biobased and Renewable Products Advocacy Group (BRAG®) Senior Policy Advisor and former head of the U.S. Environmental Protection Agency's (EPA) Green Chemistry program, Richard E. Engler, Ph.D., cover key points throughout the manufacturing and commercialization process at which biobased companies need to be aware of TSCA requirements.
"The Toxic Substances Control Act and the Bioeconomy: Part 1, The Impact of Nomenclature on the Commercialization of Biobased Chemicals," published April 26, 2015, begins with some common misconceptions about TSCA:
When I meet people from bioeconomy companies, I ask them about their products' status under the Toxic Substances Control Act (TSCA). The most common answers I receive are: "TSCA doesn't apply because our product is not toxic," "TSCA doesn't apply because our product is naturally occurring," and "We are compliant with TSCA because we're making something that's already in commerce." This usually leads to a more in-depth discussion of how TSCA works and its idiosyncrasies with respect to biobased products. I do not ask this to be accusatory, rather I want to be sure that companies understand their obligations so that they do not run afoul of the law. TSCA penalties can add up quickly (maximum $37,500 per violation per day) and can threaten nascent companies if they are not diligent.
The article continues by detailing how the Chemical Abstracts Index name and identity of a substance is determined, how feedstock and production processes can affect identity, and the impact the name has on commercialization prospects since all chemicals in production must be listed on the TSCA Inventory.
"The Toxic Substances Control Act and the Bioeconomy: Part 2, Reportable Substances across the Manufacturing Process," published May 3, 2015, details when feedstocks, intermediates, and catalysts may be reportable under TSCA.
Importantly, in addition to final chemical products, TSCA also applies to the other chemicals used in the manufacturing process. Looking at the various stages of a typical manufacturing process allows us to examine how TSCA applies at each stage.
The article then discusses feedstocks, such as plants, sugars, and municipal wastes; isolated and non-isolated intermediates; and catalysts, such as metals, enzymes, and microoganisms; and how each of those is treated under TSCA.
The final article in the series will be published in Biofuels Digest on May 10, 2015, and we will feature excerpts in next week's BRAG Report.
BIO Assesses Impact Of EPA Delays On RFS Investment
On May 4, 2015, the Biotechnology Industry Organization (BIO) released a new white paper on "Estimating Chilled Investment for Advanced Biofuels Due to RFS Uncertainty," along with an accompanying press release.
BIO examined the impact of EPA's recent inability in administering the federal Renewable Fuel Standard (RFS) on investment in advanced and cellulosic biofuels. It has found that EPA's delay in issuing the final 2013 and 2014 RFS rules, among other delays in RFS administration, is responsible for most of the "$13.7 billion shortfall in necessary investments for capacity to meet the RFS goals." According to the white paper, the delays have "undercut the industry's ability to create new employment opportunities by more than 80,000 direct jobs."
This white paper is released as RFS stakeholders are eagerly awaiting EPA's expected release of the final 2014 RFS rule later this year. Biofuels stakeholders would like to see the Agency withdraw and re-issue EPA's proposed 2014 RFS rule with stronger volumetric requirements and a different methodology, while oil and gas industry stakeholders are pressing EPA to issue the final 2014 RFS in line with the volume requirements and methodology contained in the proposed rule.
Biomass Technical Advisory Committee Announces Public Meeting
The U.S. Department of Energy's (DOE) Biomass Research and Development Technical Advisory Committee published a notice in the April 30, 2015, Federal Register announcing an open meeting that will provide advice and guidance on promoting research and development leading to the production of biobased fuels and biobased products. The meeting will include updates on U.S. Department of Agriculture (USDA) and DOE biomass activities, updates on the Biomass Research and Development Initiative, an overview of the Biomass Interagency Working Groups, and a panel on international bioenergy activities. The meeting is scheduled to be held on May 20, 2015, from 8:30 a.m. - 5:30 p.m.; May 21, 2015, from 8:30 a.m. - 5:30 p.m.; and May 22, 2015, from 8:30 a.m. - 1:00 p.m. To attend the meeting or to make oral statements regarding any of the items on the agenda, you must contact Elliott Levine at (202) 586-1476/e-mail: Elliott.Levine@ee.doe.gov or Roy Tiley at (410) 997-7778 ext. 220/e-mail: Rtiley@bcs-hq.com by May 13, 2015.
Call For Applications For Sofinnova Partners Renewable Chemistry Start-Up Award
Sofinnova Partners has announced an award for renewable chemistry start-up companies to be presented at the 2015 Bio World Congress on Industrial Biotechnology. The winner will be able to pitch its project at the conference. Companies must have revenue below $5 million and be active in renewable chemistry, industrial biotechnology, or renewable fuels in order to be eligible for the award. There will be an online vote for the top five companies, and an industry jury will select the winning company. Applications may be submitted online through May 30, 2015.
Roundtable On Sustainable Biomaterials Proposes Low Risk ILUC Standard
On April 29, 2015, the Roundtable on Sustainable Biomaterials (RSB) released a draft standard titled "Low iLUC Risk Biomass Criteria and Compliance Indicators" that will allow producers to show that they generate biofuels crops with a low-risk of indirect land use change (ILUC). The standards take into account yield increase, unused or degraded land, use of waste or residues, and integrated sugarcane and cattle production. The RSB standard is intended to be used in conjunction with the new European Union (EU) ILUC amendment that has provisions for low-ILUC biofuels. The standard will be released in final at the RSB general assembly meeting June 1, 2015, in Geneva, Switzerland, and is currently open to public comments.
Parliament Finalizes EU Biofuels Reform Rule
On April 28, 2015, the European Parliament approved a draft law restricting crop-based biofuels in order to encourage production of advanced biofuels with low-risk ILUC and cut greenhouse gas (GHG) emissions. The law, that was discussed in the April 23, 2015, Biobased and Renewable Products Update, applies to legislation requiring EU Member States ensure that at least 10 percent of energy used in transport by 2020 is renewable. Under the new law, no more than 7 percent of energy consumption by 2020 can be first-generation biofuels, resulting in at least 3 percent of energy consumption coming from advanced biofuel. The law also requires the reporting of GHG emissions caused by ILUC and the publication of data on ILUC-related emissions. Member States have until 2017 to enact the legislation.
Commercialization Association (NanoBCA) D.C. Roundtable 2015,
2015, co-located with American Industrial Hygiene Association Conference & Expo,
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The Biobased and Renewable Products Advocacy Group (BRAG®) helps members develop and bring to market their innovative biobased 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.
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