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California Biodiesel Alliance News

California's Biodiesel Industry Trade Association  

  

November 2016     

In This Issue
     

Responses to the election of Donald Trump varied greatly among those concerned about policies affecting biodiesel. Based on Trump's expressions of support for biofuels and the Renewable Fuel Standard (RFS)  during his campaign, National Biodiesel Board (NBB) CEO, Donnell Rehagen, and other biodiesel leaders issued hopeful statements the morning after the election

As this newsletter goes out, NBB members are gathering in DC to press the case for biodiesel on Capitol Hill. However, consideration of tax extenders, as noted by Jennifer Case in this recent article in the San Diego Union-Tribune, may have to wait for next year, given the likelihood that the lame duck Congress will pass a continuing resolution to temporarily fund the government, which precludes policy changes. However, the national biodiesel industry is pleased with the certainty provided by the recently released RFS volume increases, and we bring you Ron Kotrba's analysis of those numbers.
 
In California, Trump's election prompted serious concerns about safeguarding state policies, with much focus on the impact a climate-denying president might have on our world leadership on environmental and energy policies

So, this issue includes a link to the LA Times article in which Governor Jerry Brown said, "We will protect the precious rights of our people and continue to confront the existential threat of our time - devastating climate change." And we reprint Governor Brown's news release about the COP22, which discusses our state's success in taking action on climate change and how California, Oregon, Washington, and Canada stand with the international community on this issue

We include evidence of that success in articles on Canada's new clean fuel standard; California's moving ahead with aggressive post-2020 LCFS carbon reduction; positive results from the state's last Cap and Trade auction  . . . and more. 
 
The policy section has updates on state and federal issues, including information on the VW settlement in California and on our efforts to secure a portion of that funding for instate biodiesel. 
  

 
SAVE THE DATE!

"California's Thriving Low-Carbon Markets"

CBA Session at 2017 National Biodiesel Conference & Expo, San Diego
January 17th, 2:30 - 4:00 pm  
(In lieu of our regular semi-annual member meeting)

   
Note: You are receiving this newsletter because your company/organization or individual membership is current or you are a Partner Sponsor. We are also making this complete version of the newsletter available to state agency staff who have signed up to receive our newsletters. Our Members Only webpage is now available to you using the password 2006 - the year CBA was founded. 
  
 
Back Issues of this newsletter are available in the Archives on our Members Only webpage. 
    

Register Now for CBA's Sixth Annual 
  All New Conf Logo
T H R I V E !
 
March 1, 2017 -- Capitol Ballroom, Sacramento 
 

 -- CBA Corporate Members who join or renew membership in CBA for 2017 will receive the Comp Code for 1-3 free conference registrations (depending on their membership level benefit).
 
 -- CBA Individual Members who join or renew membership in CBA for 2017 will receive the Discount Code to attend the conference for $295.
   
See our Join Us page for details

Our 2017 conference focuses on how businesses can thrive in the state's growing biodiesel market. Biodiesel has been at the epicenter of our state's world-leading carbon transportation policy solution, the Low Carbon Fuel Standard, since its inception. And now an even greater boost is coming to the biofuels market with the passage of SB 32, which requires GHG emissions reductions of 40% below 1990 levels by 2030!
 
Learn about risk management strategies from the experts, see how low biodiesel's carbon intensity scores can go, join in conversation with the best writers in the business, and get critical updates on state, regional, and federal policy!


(Office of Governor Edmund G. Brown Jr.)
West Coast Leaders Reaffirm Commitment to Climate Action 
at Close of COP22

11-18-2016

SACRAMENTO - California Governor Edmund G. Brown Jr., Oregon Governor Kate Brown, Washington Governor Jay Inslee and British Columbia Premier Christy Clark today issued the following statement on the final day of the United Nations Climate Conference in Marrakech, Morocco (COP22):

"Today, as COP22 comes to a close - two weeks after the Paris Agreement came into force - leaders from across the globe have renewed their commitment to climate action. In California, Oregon, Washington and British Columbia - from the Mexican border to the edge of the Yukon Territory - we stand with the international community. Our success demonstrates that taking action on climate change goes hand-in-hand with robust job creation and a thriving clean energy economy.

We know what's at stake because we have seen the destruction firsthand - from year-round wildfires and historic drought to devastating sea-level rise. These impacts don't respect borders or wait for the next election.

Our resolve is strong. We will continue to take bold action to achieve the targets set in the Paris agreement. We will mobilize our resources and our people. We will join with other like-minded cities, states and regions committed to action and lead this global fight."

California's Leadership on Climate Change

California is playing a world-leading role in setting aggressive climate goals, broadening collaboration among subnational leaders and taking action to reduce climate pollutants.

Last year, California and Baden-Württemberg, Germany formed the  Under2 Coalition  - an international pact among cities, states and countries to limit the increase in global average temperature to below 2 degrees Celsius, the level of potentially catastrophic consequences. With the addition of  29 new members  earlier this week following a signing ceremony at COP22, a total of 165 jurisdictions have joined the coalition representing more than a billion people and $25.7 trillion in combined GDP - more than one-third of the global economy. 

In September, California took bold action to advance its climate goals,  establishing the most ambitious greenhouse gas emission reduction targets in North America  and  the nation's toughest restrictions on destructive super pollutants . The Governor also signed  legislation that directs cap-and-trade funds  to greenhouse gas reducing programs which benefit disadvantaged communities, support clean transportation and protect natural ecosystems.

This action builds on  landmark legislation  the Governor signed in October 2015 to generate half of the state's electricity from renewable sources by 2030 and double the rate of energy efficiency savings in California buildings. Governor Brown has also committed to reducing today's petroleum use in cars and trucks by up to 50 percent within the next 15 years; make heating fuels cleaner; and manage farm and rangelands, forests and wetlands so they can store carbon.

Over the past year and a half, the Governor has traveled to the United Nations headquarters in  New York , the United Nations Climate Change Conference in  Paris , France, the  Vatican  in Italy and the Climate Summit of the Americas in  Toronto , Canada to call on other leaders to join California in the fight against climate change. Governor Brown also joined an  unprecedented alliance  of heads of state, city and state leaders - convened by the World Bank Group and International Monetary Fund - to urge countries and companies around the globe to put a price on carbon. 

These efforts to broaden collaboration among subnational leaders build on a number of other international climate change agreements with leaders from the  Czech Republic , the  Netherlands Mexico China North America Japan Israel Peru  and  Chile  and Governor Brown's efforts to gather hundreds of world-renowned researchers and scientists around a  groundbreaking call to action  - called the consensus statement - which translates key scientific climate findings from disparate fields into one unified document.

The impacts of climate change are already being felt in California and will disproportionately impact the state's most vulnerable populations.
 
ARB Proposes LCFS CI Reductions of 18% - 25% by 2030
 
Sets Dates for Several Fuel Type Meetings under Verification Rulemaking

 
Cal/EPa Building
At the California Air Resources Board's (ARB) November 7th public workshop on the "2030 Target Scoping Plan Update: GHG Policy Scenarios, Natural & Working Lands, and Public Health Analysis," ARB staff discussed a range of issues. Key for the biodiesel industry was a proposal of an 18%, and possibly as high as a 25%, reduction in the carbon intensity of the state's transportation fuels by 2030 under the Low Carbon Fuel Standard (LCFS). By contrast, the current regulation, which has a goal of a 10% CI reduction by 2020 is set at 2% this year.
 
For more information on the  Scoping Plan, the Biofuel Supply Module, meetings and to get future workshop announcements on ARB's Climate Change Email Listserver: https://www.arb.ca.gov/cc/scopingplan/meetings/meetings.htm.

LCFS Verification Rulemaking
 
On November 23rd, ARB announced the first several in a series of LCFS rulemaking public working meetings that will begin this December and end in the second quarter of 2017. The meeting on biodiesel has not yet been scheduled, but is expected to take place in early 2017. A meeting on the rulemaking proposal for Verification Bodies will take place on the morning of Monday, December 19th. Other meetings are: Dec. 2, Electricity and Natural Gas; Dec. 5, Hydrogen; Dec. 13, Refinery Co-processing.
 
For each of the fuels types, the meetings will discuss "(1) changes to the pathway carbon intensity application and evaluation process, (2) improvements to reporting and credit generation processes, and (3) the integration of third-party verification requirements."

Meeting details, webinar instructions, and meeting presentations can be found here:  http://www.arb.ca.gov/fuels/lcfs/lcfs_meetings/lcfs_meetings.htm .

CBA is coordinating closely and supporting the comments of the National Biodiesel Board as we engage with ARB on these issues.  View the latest public comments from July 29, 2016 at: http://www.arb.ca.gov/fuels/lcfs/workshops/feedback.htm#06022016.
   
 
(E&E)
Demand for Carbon Allowances Rebounds in Latest Auction 

Debra Kahn, E&E News reporter

Published: Wednesday, November 23, 2016

California's latest auction of greenhouse gas permits saw improved demand, likely due to increased confidence in the state's emissions market.

The Nov. 15 auction sold 88 percent of the allowances put up for sale to cover businesses' current emissions, at the state-set minimum price of $12.73 per ton, the California Air Resources Board announced yesterday. The previous auction, in August, sold 35 percent of the current-year allowances, and May's auction saw even lower demand, throwing state revenues into uncertainty ( ClimateWire, May 27).

Observers had been expecting demand to recover, based on the fact that the minimum price is set to increase next year to $13.37 per ton. As well, state lawmakers passed a bill in September extending the state's emissions targets past 2020 to 40 percent below 1990 levels by 2030.
Ten percent of allowances that were available for future-year emissions sold, in line with previous auctions. Overall, the auction raised roughly $360 million for the state, a quarter of which Gov. Jerry Brown (D) has earmarked for use on California's high-speed rail project.

"It seems like a bit of a stabilization," said Chris Busch, director of research at the consulting firm Energy Innovation. "Hopefully, that will reverberate positively in Sacramento."

Policymakers have been debating whether to extend the cap-and-trade program past 2020 or to use some other mechanism like a carbon tax or direct regulations ( ClimateWire, Nov. 8). The program also still faces a legal challenge by industry groups arguing that the auctions are an illegal tax; that lawsuit is set for oral arguments in January.

"I think it's a vote of confidence in this system," Busch said. "It's sort of industry acknowledging that the lawsuit currently being litigated is probably not going to come out against CARB's auctioning through 2020."

Another observer said the auction cements California's status after the presidential election as a "beacon of hope for climate action." 

"While we hope President-elect Trump will listen to the almost unanimous global voice of governments and business leaders who all understand that we must act to avert catastrophic climate change, it's indisputable that leadership from U.S. states will be of paramount importance," wrote Erica Morehouse, an attorney with the Environmental Defense Fund.

(BIODIESEL MAGAZINE)
2017-'18 RFS Rule: Advanced Biofuel RVO Grows at 19 Percent

Posted November 23, 2016 by Ron Kotrba

The U.S. EPA released its final rule for renewable volume obligations (RVO) under the renewable fuel standard (RFS) Nov. 23, and the figures for the 2018 biomass-based diesel category are what was proposed in May at 2.1 billion gallons, up 100 million gallons from 2017.

The agency also issued its advanced biofuel RVO for 2017, which was higher than the proposal of 4 billion ethanol-equivalent gallons (2.67 billion biodiesel-equivalent gallons) at 4.28 billion ethanol-equivalent gallons (2.85 billion biodiesel gallons). The 2016 advanced biofuel RVO was 3.61 billion ethanol-equivalent gallons (2.41 billion biodiesel gallons).

The 2017 advanced biofuel RVO represents nearly a 19 percent growth in one year, and a 7 percent increase from the 2017 proposal issued in May. Biomass-based diesels such as biodiesel and renewable diesel will continue filling most of the advanced biofuel volumes, as biomass-based diesel is a subset of the overall advanced biofuel category.

"We think it's very encouraging movement overall, particularly on the advanced biofuel part of the program," Gene Gebolys, founder, president and CEO of World Energy, a major U.S. biodiesel producer with four production facilities, told Biodiesel Magazine. Gebolys is also chair of the National Biodiesel Board's RFS Working Group, which helps supply EPA with suggested volumes the industry can achieve, and data to buttress its positions. "Clearly it's nowhere near what we as an industry have for capacity," Gebolys added, "but the fact that EPA moved the advanced biofuel RVO from 4 billion in the proposal to 4.28 billion gallons in the final rule, well, it's heartening they listened to us. But there's a lot more room for growth."

Janet McCabe, the EPA's acting assistant administrator for the office of air and radiation, said, "Renewable fuel volumes continue to increase across the board compared to 2016 levels. These final standards will boost production, providing for ambitious yet achievable growth of biofuels in the transportation sector. By implementing the program enacted by Congress, we are expanding the nation's renewable fuels sector while reducing our reliance on imported oil."

The National Biodiesel Board welcomed the release of the new standards and said the final rule strengthens America's energy security.

"The real winners with this announcement are American consumers who will now have access to even more cleaner-burning, advanced biofuel," said NBB CEO Donnell Rehagen. "These benefits extend far beyond the biodiesel industry, supporting high-paying jobs and clean air across the nation. Though we are poised to top these numbers this year, growth in advanced biofuels still sends positive signals to the marketplace."

NBB said while the new standards reflect modest growth, they remain below the more than 2.6 billion gallons of biodiesel and renewable diesel expected in 2016.

"While NBB applauds the increased volumes, there is room for more aggressive growth," Rehagen said. "The U.S. biodiesel industry can do more. The production capacity and feedstock are clearly available as the market is already topping these levels. We will work with the incoming administration to help them understand the benefits provided by our growing domestic biodiesel industry and the potential to support additional jobs and investment in rural economies."
Gebolys said what has been gleaned from this past election and Trump's victory is that rural America was a huge player in this election cycle, which he said bodes well for conversion of the $1 per gallon biodiesel blenders credit to a domestic producers credit. "While I don't think it's likely to pass before Jan. 1, I do think it is likely to pass as a producers credit retroactively to Jan. 1," he said. "After talking with high-level officials on both sides of the aisle, I feel good about that happening."

The cellulosic biofuel RVO for 2017, at 311 million gallons, is 35 percent higher than the 2016 standard.

Total renewable fuels under the RFS for 2017 comes in at 19.28 billion gallons, up from the 2016 standards of 18.11 billion gallons. 

View the original article here

Read Ron's article "How a 19% higher advanced biofuel RVO is an 83% growth opportunity for biodiesel" for a deeper analysis of the numbers.

                                                                      
(Advanced Biofuels Canada)
Canada to Act on Transportation Greenhouse Gas Emissions and Cleantech Growth
 
Canada to Provide Leadership with National Clean Fuel Standard to 2030
 
VANCOUVER  November 25, 2016 - The announcement today by Minister Catherine McKenna that Canada will adopt a national clean fuels standard is an important step for climate action and the growth of our cleantech economy and green jobs. This federal leadership builds on the early actions of British Columbia, Oregon and California, and will greatly improve availability of low carbon fuel choices and competition at the pump.
 
A national clean fuels standard will require fuel suppliers to progressively reduce the carbon pollution in their fuels, with annual reduction requirements within a specified overall timeframe. Environment and Climate Change Canada will consult with stakeholders to establish the reduction levels and timeframes.
 
"Canada has within its borders a complete set of time-tested approaches for reducing the carbon pollution in fuels", stated Ian Thomson, President of Advanced Biofuels Canada. "From this experience of over a decade, the Government of Canada has zeroed in on a proven, flexible regulatory tool. We believe they've made a smart choice, and set a goal - 30 million tonnes of reduction by 2030 - that will spur all parties to action."
 
The decision to adopt the first national clean fuels standard in the world is consistent with the guidance offered recently by Canadian and US non-governmental and industry organizations. British Columbia has already demonstrated that leadership in clean and renewable fuels can go hand in hand with economic growth. And a clean fuels standard complements the recent announcement by the US EPA that it is strengthening the US renewable fuel standard.
 
Fuel suppliers have an array of options for meeting the clean fuel standard. They can employ lower carbon fuels blended into, or replacing, gasoline and diesel, or improve the emissions associated with upstream oil and gas extraction and refining. The new standard will also promote fuel switching to electric mobility and hydrogen fuel cells. This flexible, market-based approach will ensure a smoother transition from the starting point of today's existing vehicles and fuels infrastructure.
 
"Most Canadians do not know that we already produce at commercial scale the low carbon fuels and transportation technologies that are needed to take us well towards our climate goals. The technologies are proven, and many petroleum companies are making investments in them around the globe. In Canada, there is much more that we can do to participate in the global clean fuels economy. A Canadian standard will attract investment to scale up clean fuels growth and help make these fuels more available and drive down costs."
 
A clean fuels standard will achieve carbon reductions well beyond what can be achieved from a price on carbon alone. Unlike a price on carbon, which relies on making fuels more expensive to discourage their use, a clean fuel standard will stimulate direct investments in a variety of lower carbon fuel options. A clean fuels standard is particularly effective because all compliance costs are directed back into lower carbon solutions.
 
Clean fuels have other benefits. In polluted urban airsheds, they lead to better air quality by reducing emissions of the toxins found in gasoline and diesel. For consumers, new fuels in the market creates more choice and increases competition, leading to more innovation in the supply of fuels and in transportation options.
 
Canada's announcement is aligned with the global transition towards a low carbon economy. A stringent clean fuels standard will provide a predictable, longterm innovation signal for both clean fuels providers and fuel suppliers to reduce emissions. Advanced Biofuels Canada is committed to supporting our government as we develop an effective regulation that achieves our targeted greenhouse gas emissions reductions and captures the benefits of new cleantech growth.
 
For more information: Ian Thomson, President, Advanced Biofuels Canada +1 778 233 3889, [email protected]www.advancedbiofuels.ca.

CALIFORNIA INDUSTRY NEWS

Vials of Biodiesel Beautiful oil   Vials of Biodiesel

(Biodico)
 Biodico Completes Resource Assessment Of 'Zero Net Energy Farm' in California 

-Results Indicate Optimal Use of Solar, Wind and Biomass
To Support Energy Self-Reliant Farms throughout State

Fresno and Ventura Counties, Calif. - November 16, 2016

Biodico Inc. today said that it has completed its resource assessment to support the next stage of development for its "Zero Net Energy Farm" project, which is funded in part by the California Energy Commission to create environmentally sound energy solutions for the state's agricultural industry.
 
Based on the results, Biodico will proceed with the building of the first-of-its-kind Zero Net Energy Farm or "ZNEF" to generate all electrical and heating power needs from on-site renewable resources, including solar, wind and biomass.  The project will provide a template for introducing Biodico's ZNEF technology to other regions throughout the country and on a global scale.
 
"We are making excellent progress with the development of our ZNEF facility in the San Joaquin Valley. The goal is to use the site's design as a replicable model that would apply to a multitude of settings in need of a customizable yet practical solution for energy self-reliance," said Biodico Founder and President Russ Teall.  "The viability of our project is based on an economical solution that would improve energy security, decrease air pollutants and stimulate job creation."
 
Preliminary results of Biodico's resource assessment were recently presented to the San Joaquin Valley Clean Energy Cluster, a consortium of clean energy entrepreneurs based at California State University, Fresno.  Members of the Energy Cluster toured Biodico's ZNEF site, as well as participated in a poll that further validated the need and interest for technologies demonstrated by the ZNEF project.
 
"Fostering greater awareness of this project will take us to the next level of investing in California's renewable future, and projects such as Biodico's Zero Net Energy Farm is not only going to be great for California, but the country as a whole," said Nick Gera, project coordinator of the Clean Energy Cluster.  "The nation's eyes are on California, and we are very excited that the next energy revolution is happening right here in the Central Valley."     

_________________

(UC Berkeley & UCLA Law)

Posted on November 4, 2016 7:34 am by Ethan Elkind

To meet the challenge of climate change, California and other governments will need to adopt a suite of policies affecting multiple sectors. Reducing economy-wide greenhouse gas emissions will take reforms in energy, land use, transportation, and agriculture, to name just a few.

Since 2009, UC Berkeley and UCLA Schools of Law, with the generous support of Bank of America, have been developing policy recommendations for California and other jurisdictions to meet ambitious greenhouse gas reduction targets. In California and increasingly in other jurisdictions, these targets are legally mandated and based on what climate scientists tell us is needed to reduce the threat of catastrophic climate change.

All of the policy recommendations result from a series of workshops the law schools have convened since 2009. They included key stakeholders from the business, academic, and policy sectors of the affected industries. The recommendations are also contained in  reports accessible via CLEE  or the  UCLA Emmett Institute .

The website is now available at  www.climatepolicysolutions.org.

Note:  A free webinar was held on Wednesday, November 9th, from 2-3pm, to launch the two law schools' new  climate policy website . The site contains all the recommendations from our work since 2009 on reducing carbon emissions in multiple sectors of the economy. It features easy-to-navigate pages organized by issue topic (renewables, fuels, etc.). It also groups solutions around the specific challenges they address and lists them by the actors who can implement them (state officials, local representatives, businesses, etc.)

The webinar featured:
  • Mary Nichols, chair of the California Air Resources Board
  • Nancy Pfund, founder and managing partner, DBL Investors
  • Amanda Eaken, transportation & climate director, Natural Resources Defense Council


STATE AND FEDERAL
REGULATORY AND POLICY ISSUE UPDATES  


CALIFORNIA AIR RESOURCES BOARD (ARB)
 CAP & TRADE AUCTION PROCEEDS ALLOCATED THROUGH THE STATE'S GGRF
   

See article above on the most recent auction. CBA continues its leadership of the CA Cap and Trade Biofuels Initiative coalition effort to secure instate biofuels incentive funding from auction proceeds allocated through the state budget, specifically ARB's Greenhouse Gas Reduction Fund  (GGRF). We will provide updates as our efforts for the next legislative session develop

Note: California will receive about $1.2 billion from the approved Consent Decree for mitigation of the environmental damage caused by VW's deception, with  $800 million going to ZEVs . CBA has already begun to engage with ARB staff to try to influence the allocation of some of the remaining money for instate biofuels incentive funding and the acceleration of New Technology Diesel Engine (NTDE) adoption.
 
 
VW settlement implementation:  https://www.arb.ca.gov/msprog/vw_info/vsi/vsi.htm.



CALIFORNIA AIR RESOURCES BOARD (ARB) 
ALTERNATIVE DIESEL FUEL REGULATION (ADF)

The ADF regulation, which became effective January 1, 2016, includes reporting and recordkeeping requirements applicable to entities in the biodiesel industry. Biodiesel producers, importers and blenders must submit quarterly reports.  Biodiesel producers, importers and blenders are required to report and keep records concerning biodiesel production, sales, and blending. Biodiesel distributors and retailers are only required to keep records. 
 
Find the current FAQ and Reporting Forms at:
http://www.arb.ca.gov/fuels/adf/adfdocs.htm. 
T he presentation for the ARB May 23rd, 2016 public workshop, which has detailed diagrams, is here:  http://www.arb.ca.gov/fuels/diesel/altdiesel/meetings/meetings.htm. 


NOTE: Most in-state biodiesel fuel businesses are required to register under the Air Resources Board's Motor Vehicle Fuel Distributor program (MVDP). See the article on our Members Only page.
 
 
CALIFORNIA RESOURCES BOARD ( ARB)
LOW CARBON FUEL STANDARD (LCFS)

See article above.
   
 
CALIFORNIA ENERGY COMMISSION (CEC)
ALTERNATIVE AND RENEWABLE FUEL AND VEHICLE TECHNOLOGY PROGRAM (ARFVTP) 


This month, CBA submitted comments on the CEC's ARFVTP's proposed 2017-18 Investment Plan Update. T he comments included making another pitch for more funds (VW funds for distribution infrastructure); clarifying that several markets are using more than 5% biodiesel; correcting the number of plants that have been funded and are operational; and clarifying that instate biofuels incentives would level the playing field with out of state fuel.



CDFA'S DIVISION OF MEASUREMENT STANDARDS (DMS)

There is no update this month. See the Members Only webpage for background and information on compliance issues. 


STATE WATER RESOURCES CONTROL BOARD: UNDERGROUND STORAGE TANK ISSUES 
 
There is no update this month. See the Members Only webpage for background and information on compliance issues.   

__________

FEDERAL UPDATES 

Please contact the Washington office of the National Biodiesel Board (NBB) at 
202-737-8801  for questions on federal policy issues. Click on the NBB  Fueling Action
 logo for detailed information. 
 
NBB Fueling Action Logo
 
 
Federal Tax Incentive
See Greeting section above.

US EPA: Renewable Fuel Standard (RFS): Volumes
See article above.

US EPA: Renewable Fuel Standard (RFS): Point of Obligation

EPA's "Notice of Opportunity to Comment on Proposed Denial of Petitions for Rulemaking to Change the RFS Point of Obligation" was published in the Federal Register on November 22, 2016. According to the NBB: "EPA has received several petitions requesting that it initiate a rulemaking process to reconsider or change its regulations that identify refiners and importers of gasoline and diesel fuel as the entities responsible for complying with the annual percentage standards adopted under the RFS program. These requests have suggested that the obligation be shifted to those parties that blend renewable fuel into transportation fuel, to those parties that hold title to the gasoline or diesel fuel immediately prior to the sale of these fuels at the terminal (referred to as "position holders"), or to "blenders and distributors." EPA has proposed to deny these petitions, but is requesting comments on whether or not changing the point of obligation would be likely to significantly increase the production, distribution, and use of renewable fuels as transportation fuel in the United States. Comments on the petitions it has received and on its proposed denial of the requests to initiate rulemaking are due by   January 23, 2017. The proposed denial is  available here , and the petitions submitted can be found at   www.regulations.gov  u nder Docket ID No. EPA-HQ-OAR-2016-0544.
   
US EPA: Renewable Fuel Standard (RFS): Proposed Renewables Enhancement and Growth Support (REGS) Rule 
 
In October, the EPA released its proposal for the REGS Rule, and this month it was published in the Federal Register, officially opening a 60-day public comment period. Comments are due Jan. 17. The rule, which includes many changes, clarifications and technical corrections to the RFS regulation and other fuels regulations aimed at enhancing the use of renewable fuels in the transportation sector. According to the NBB, "A key part of the REGS Rule is addressing "biointermediates" processed at one facility for use in the production of renewable fuels at another facility to allow those fuels to qualify under the existing fuel pathways. The proposal also purports to address some of the issues NBB has raised with EPA for some time. NBB is reviewing the proposed changes and has begun to work with the NBB regulatory committee to submit comments on behalf of the biodiesel industry.

EPA will hold a public hearing on the proposal on December 6th. A summary of the REGS Rule can be read on EPA's website, here: https://www.epa.gov/renewable-fuel-standard-program/2016-announcements-renewable-fuel-standard-program.
 
US EPA: Renewable Fuel Standard (RFS): Argentinian Imports 

Oct 27th , the NBB presented its arguments to the U.S. Court of Appeals for the District of Columbia Circuit regarding its petition for review of EPA rules on Argentinian biodiesel imports under the Renewable Fuel Standard (RFS).  An audio file of the argument is available  here .

 
Thank you for your engagement and support of CBA and for your time and effort on behalf of our industry. I look forward to continuing to work with you.
 

Best,
Celia DuBose
Executive Director
California Biodiesel Alliance (CBA)