Policy Challenges for
Growing the Algae Industry
April 2014
GHG Emissions are at Historic Highs
IPCC reports that our climate needs swift shift to clean energy
 Global greenhouse gas emissions
rose 2.2% annually in the past
decade — nearly twice the annual
rate of 1.3% from 1970 to 2000
 Fossil fuel combustion and industrial
processes accounted for 78% of the
emissions' increase between 1970
and 2010
 Holding emission increases to 2
degrees celsius above pre-industrial
levels will require "heroic efforts"
and a "massive" shift in the energy
sector
Source: IPCC WGII “Climate Change 2014: Impacts, Adaptation, and Vulnerability”
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Oil and Gas Interests are Undermining Advanced Biofuel
Companies
Almost half of global biofuels were made in the United States as a direct
result of the RFS policy
 Anti-RFS scare tactics have had a negative effect on investment in the
renewable fuels sector
 This attempt to bully the renewables industry is made worse by the current
administration’s lack of support on rule setting—Mixed signals jeopardizes the
US’ ability to utilize valuable fuel technologies
 We should not let misleading ads and information de-rail our industry and
further hinder renewable technologies that benefit our country
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Is this Administration Friend or Foe?
Source: AP Images
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EPA Undercuts the Low-Carbon Benefits of Advanced Biofuels
 The EPA’s proposed New Source Performance Standard (NSPS) would create a
permanent barrier to integrate with CO2 point sources and prohibit EGU’s from
reducing CO2 emissions through recycling
‒ Establishes CCS/EOR, and forecloses all beneficial reuses of CO2
‒ Sec. 111, CAA is a emissions limitation (performance) NOT a technology
standard
‒ Foolishly designates one technology to meet the performance standard
‒ Impermissible under Sec. 111, CAA
“Generally, the EPA does not prescribe a particular technological system that must be used
to comply with a standard of performance. Rather, sources generally can select any
measure or combination of measures that will achieve the emissions level of the standard.”
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Proposed EPA RVO Pulls the Rug out From the Advanced Fuels
Industry
 NPRM for RVO proposes to cut volume requirements for advanced biofuels by
more then 40%
 In contrast they propose a less than 10% reduction to volume requirements for
conventional biofuels
 Delivering a material blow to the category of fuels that will deliver the largest
reductions in GHG emissions, infrastructure compliant and required by the DoD
 One must assume that the administration is playing politics with this nascent
industry in order to pay favor for the much larger and more powerful producers
of starch ethanol
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EPA Proposes to Require Co-Location of Biofuels Companies Who
Produce Intermediate Feedstocks
 NPRM for the 2014 RVO asserts that producers of renewable fuel would not be
allowed to generate RINs on their production unless the pre-processing of the
renewable biomass and final upgrading of the fuels are co-located at the same
facility
‒ The rule is not supported by the original legislation and is inconsistent with
the practices and methods in which biofuels companies operate
‒ A rulemaking should not be necessary to allow for the generation of RINs
under existing pathways for renewable fuels
‒ Existing pathway definitions and RFS reporting and recordkeeping
requirements – along with a QAP – will ensure the integrity of renewable fuel
produced and RINs generated in this manner
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USDA is on the Way to Cherry Pick Farm to Fleet
Winners and Losers
 With great fanfare and anticipation the Secretary of Agriculture and Navy
announced its intention to, “make biofuel blends part of regular, operational fuel
purchase and use by the military.
―“The Navy will seek to purchase JP-5 and F-76 advanced drop-in biofuels
blended from 10-50% with conventional fuels.”
 This announcement will begin regular procurement of fuels from advanced
feedstocks that meet JP-5 and F-76 specifications.
 CCC support was to be employed to reduce the cost of feedstock production as
the industry transitioned from small to larger scale
 As it stands today, the USDA seems to be leaning in the direction of picking
winner and loser feedstocks for acceptance into the farm to fleet program
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Conclusion
 Any one of the outlined regulatory, policy and political challenges could have a
devastating effect on the ability of the advance biofuels industry to achieve critical mass
 The administration seems to be asleep at the wheel when it allowed proposal to come
from its agencies, any one of which, would completely undercut the Advanced biofuels
industry ability to compete with incumbent energy producers
 The unrelenting lobbying, politicking and media campaigns being run by the API on
behalf of incumbent energy giants is taking a significant toll on this industry
― Is this administration doing whatever it can to help out these carbon intense industries
― The uncertainty in policy has resulted in a record low investment for this industry
 The political tone from policy makers, expired tax incentives, RFS repeal rhetoric, etc, is
taking a toll on investor confidence, public confidence and left to continue will result in the
destruction of the low carbon fuels space or future companies and investments being
made in China, India or the Middle East
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