Renewable Fuel Standard News: February 28, 2013

Here’s an update on recent news items and other public policy developments relating to the U.S. Renewable Fuel Standard (RFS), and the efforts to produce commercial quantities of cellulosic biofuels which qualify to generate Renewable Identification Numbers (RINs) under the RFS.

Regulatory Developments


EPA qualifies additional pathways under the RFS.
On February 22, EPA issued a Final Rule adding several new fuel production pathways to the list of approved pathways under the Renewable Fuel Standard. The rule establishes Camelina (Camelina sativa) oil as a feedstock for production of biomass-based diesel and naphtha and liquefied petroleum gas, and energy cane (certain hybrids derived from Saccharum spontaneum) as a feedstock for ethanol, qualified to generate Renewable Identification Numbers (RINs) as cellulosic biofuels. The rule also certified that renewable gasoline and renewable gasoline blendstock made from certain feedstocks such as crop residues and other waste products qualify as cellulosic biofuels, and clarified that renewable diesel explicitly includes jet fuel. This final rule arises from a proposed rule first published by EPA in January 2012, and the final rule includes all the provisions in the proposed rule, except that EPA is continuing to consider whether  biofuels produced from giant reed (Arundo donax) or napier grass (Pennisetum purpureum) or biodiesel produced from esterification should qualify under the RFS. EPA received a significant number of comments to the proposed rule, citing the potential invasiveness of these two plant species and opposing the inclusion in the RFS of fuels produced from these species, EPA says it will make a final decision on these elements of the proposal at a later time. Those provisions that are part of the final rule will take effect 60 days after the rule’s formal publication in the Federal Register, which is expected shortly. 

Legislative Developments


Further developments: legislation targeting cellulosic volume mandates
. As previously reported, Rep. Gregg Harper (R-Miss.) introduced legislation, H.R. 550, or the “Phantom Fuel Reform Act of 2013,”  that would require the EPA to base its cellulosic biofuel volume mandates under the RFS on the prior year’s actual production. An identical bill, S. 251, has now been introduced in the Senate by Sen. Jeff Flake (R-Az.) and two cosponsors. In addition, Rep. Jim Sensenbrenner (R-Wisc.) has filed a similar bill in the House, H.R. 796, that would require EPA to set yearly cellulosic mandates based on the commercially available volume of cellulosic biofuels, and to make corresponding reductions to the Renewable Fuels and Advanced Biofuels volume mandates whenever the cellulosic mandates are reduced. Although most industry observers believe that the RFS will continue to be in jeopardy this year from challenges by Republican legislators, the prospects for these particular bills is unclear at this time, and it is unlikely that any of them will pass Congress in their present form.

Commercialization of Cellulosic Fuels


Cellulosic fuel projections for 2013. In an online report, Bloomberg News predicts that production of cellulosic biofuels will rise almost 20-fold in 2013 compared to 2012. Based on data from the Energy Information Administration, the report projected that 9.6 million gallons of cellulosic fuels will be produced this year, substantially up from the 500,000 gallons produced in 2012 but less than the RFS-mandated 1 billion gallons.

Progress towards commercial production of cellulosic fuels. A number of recent publications have described commercial-scale and demonstration-scale plants for the production of cellulosic fuels that are planned, under construction, or operational. One of these was a 35-page report profiling U.S. and Canadian cellulosic biofuels facilities and development projects, released by the Advanced Ethanol Council. I have summarized the information presented in this report and other published reports about commercial cellulosic ethanol projects in North America, Europe and Brazil, in two entries in my Advanced Biotechnology for Biofuels blog, which you can access here and here

Blue Sugars cellulosic plant files for bankruptcy. Western Biomass Energy LLC, a cellulosic ethanol facility based in Upton, Wyoming that is a subsidiary of Blue Sugars Corporation (formerly KL Energy), has filed for Chapter 11 bankruptcy. This facility gained notoriety last year when it became the first to generate RINs for cellulosic ethanol, for 20,000 gallons of production that were exported to Brazil to partner Petrobras. Blue Sugars has said that a reorganization plan is in the works for the Wyoming facility.

Previous Biofuel Policy Watch posts on RFS policy:

D. Glass Associates, Inc. is a consulting company specializing in government and regulatory support for renewable fuels and industrial biotechnology. David Glass, Ph.D. is a veteran of over thirty years in the biotechnology industry, with expertise in industrial biotechnology regulatory affairs, U.S. and international renewable fuels regulation, patents, technology licensing, and market and technology assessments. Dr. Glass also serves as director of regulatory affairs for Joule Unlimited Technologies, Inc. More information on D. Glass Associates’ government and regulatory consulting capabilities, and copies of some of Dr. Glass’s prior presentations on biofuels and biotechnology regulation, are available at www.slideshare.net/djglass99 and at www.dglassassociates.com. The views expressed in this blog are those of Dr. Glass and D. Glass Associates and do not represent the views of Joule Unlimited Technologies, Inc. or any other organization with which Dr. Glass is affiliated. Please visit our other blog, Advanced Biotechnology for Biofuels

 

E15 and E85 Ethanol News: February 26, 2013

Here’s an update on recent news items and other public policy developments during the last few weeks relating to the use and market acceptance of 15% blends of ethanol into gasoline (“E15″) and other higher blends of ethanol such as E85.

E15 Federal Developments


API and its allies file Supreme Court appeal
. On February 21, 2013, the American Petroleum Institute and its co-plaintiffs filed an appeal with the U.S. Supreme Court of the January 15 decision by the U.S. Court of Appeals ruling that the plaintiffs did not have standing to challenge EPA’s partial waivers to approve the sale of E15 ethanol. In filing this appeal, API reaffirmed its belief that the petitioners had standing to challenge the decisions, and restated their assertion that “E15 is not safe for millions of vehicles now on the road”.

Senate bill would block EPA approval of E15. On February 14, 2013, Senators Roger Wicker (R-Miss.) and David Vitter (R-La.) introduced a bill, S.344, that would prevent EPA from approving ethanol blends of greater than 10%, and which would overturn EPA’s prior approval of E15 blends.  Statements by the senators alleged that EPA’s “flawed waivers” were “short-sighted regulations” issued by bureaucrats that would negatively affect families and businesses and which were made “without sufficient testing and analysis” of E15. Rep. Jim Sensenbrenner (R-Wisc.) is reportedly planning to submit an identical bill in the House.

New pump configuration approved. On Feb. 7, the EPA approved a new blender pump configuration for the sale of E15 and E10, in response to a proposal submitted by the Renewable Fuels Association. The new configuration addresses the problem arising when two different gasoline-ethanol blends are dispensed from the same hose and nozzle – because this may cause residual fuel from an E15 fueling to mix with a later E10 fueling, EPA had previously instituted a 4 gallon minimum purchase, but this posed a problem for vehicles and other small engines which could not receive as much as four gallons in a single fueling. Under the new option, a retailer could provide a dedicated pump only for gasoline with 10% or less ethanol, with accompanying signage directing customers to this pump, and with the requirement that the E15 dispenser be labeled with the message “Passenger Vehicles Only. Use in Other Vehicle Engines and Equipment May Violate Federal Law.”

E15 Developments in the States 


Update: Proposed anti-E15 legislation in Maine
. To clarify previously-reported items, the anti-ethanol bills filed in the Maine legislature by Representative Jeff Timberlake are distinct from the legislation that is being prepared by the state’s Department of Environmental Protection. One of Timberlake’s bills would ban ethanol completely from Maine’s gasoline if other New England states adopt similar bans. In fact, such a bill is pending in the New Hampshire state legislature: House Bill 362, which has been introduced in previous years, would ban the use of “corn-based” ethanol in the state. Committee hearings were held in New Hampshire in late January, but the bill’s chances of success are not known.

Illinois sales tax incentives. A bill introduced in the Illinois legislature would transfer a sales tax incentive now available for E10 fuel to E15. Rather than have the incentive apply to any ethanol-gasoline blends of greater than 10%, the  language of the bill would apparently remove the tax incentive completely from E10 in favor of E15, and because E15 may not be widely available in regions of the state, particularly Chicago (allegedly due to the need for upgrading vapor recovery systems), the bill has been criticized as increasing the tax burden on most motorists.

Previous Biofuel Policy Watch posts on ethanol policy:

D. Glass Associates, Inc. is a consulting company specializing in government and regulatory support for renewable fuels and industrial biotechnology. David Glass, Ph.D. is a veteran of over thirty years in the biotechnology industry, with expertise in industrial biotechnology regulatory affairs, U.S. and international renewable fuels regulation, patents, technology licensing, and market and technology assessments. Dr. Glass also serves as director of regulatory affairs for Joule Unlimited Technologies, Inc. More information on D. Glass Associates’ government and regulatory consulting capabilities, and copies of some of Dr. Glass’s prior presentations on biofuels and biotechnology regulation, are available at www.slideshare.net/djglass99 and at www.dglassassociates.com. The views expressed in this blog are those of Dr. Glass and D. Glass Associates and do not represent the views of Joule Unlimited Technologies, Inc. or any other organization with which Dr. Glass is affiliated. Please visit our other blog, Advanced Biotechnology for Biofuels

 

Renewable Fuel Standard News: February 12, 2013

Here’s an update on recent news items and other public policy developments during the last month or two relating to the U.S. Renewable Fuel Standard (RFS).

Legislative Developments


Proposed bills target cellulosic volume mandates. Rep. Gregg Harper (R-Miss.) introduced legislation that would require the EPA to base its cellulosic biofuel volume mandates under the RFS on the prior year’s actual production. The bill, H.R. 550, or the “Phantom Fuel Reform Act of 2013,” would require EPA to calculate the average monthly volume of cellulosic fuels each year, and directly extrapolate that average to set the volume target for the subsequent year. Industry groups have expressed opposition to this bill, since it would guarantee that each year’s target volume would be no greater than the actual production for the prior year, thus removing the incentive for the industry to grow. The bill is similar to legislation introduced last year by then-Rep. Jeff Flake (R-Ariz.), and its filing clearly seems to have been triggered by the Appeals Court decision to vacate EPA’s 2012 cellulosic volume mandates. Flake, who is now a senator, reportedly introduced the same bill in the Senate after Rep. Harper filed H.R. 550 in the House.

Ranking Republican on Senate Energy Committee skeptical of RFS. Senator Lisa Murkowski (R-Alaska), the ranking minority member of the Senate Energy Committee, has called for reevaluation and reform of the RFS, as part of an overall energy proposal she unveiled on February 4.

Interest Group Actions


Chain Restaurants Issue Anti-RFS Study
. In the latest food industry attack on the RFS and biofuels, the National Council of Chain Restaurants has issued a report which it had commissioned from PricewaterhouseCoopers that is critical of the RFS and its corn-ethanol mandate. The report claims that in some scenarios, the RFS could cost chain restaurants over $3 billion annually, and the group called for repeal of the RFS. The report has been roundly criticized by industry groups, who have pointed out flawed assumptions and outdated data used in the study.

Farm Bureau expresses support for the RFS. At a meeting in January, delegates for the American Farm Bureau Federation overwhelmingly voted to support continuation of the Renewable Fuels Standard. This vote comes even though Farm Bureau membership includes livestock producers who might have been expected to oppose the RFS out of concern over the alleged impact of corn ethanol on feed costs.

New group critical of the RFS has formed. A coalition of interest groups have called for reform of the RFS, claiming the program negatively impacts the environment, farmers and taxpayers. The coalition includes the Environmental Working Group, ActionAid, American Fuel and Petrochemical Manufacturers, Environmental Working Group, FarmEcon LLC, National Marine Manufacturers Association and Taxpayers for Common Sense. Ethanol industry groups such as the American Coalition for Ethanol have disputed the group’s contentions.

Industry/NGO Op-Ed published. DuPont Industrial Biosciences President Jim Collins and Jeremy Martin of the Union of Concerned Scientists (UCS) have written an op-ed article in Politico.com expressing strong support for the RFS, saying that cellulosic biofuels are a key element of UCS’s plan to projected oil use by 50% over the next 20 years.

RFS Studies and Analyses


University of Missouri RIN Analysis. The Food and Agricultural Policy Research Institute at the University of Missouri has published a report forecasting how three different scenarios could impact markets for ethanol and conventional (i.e. corn ethanol) Renewable Identification Numbers (RINs). The report analyzes how the value of conventional RINs may be affected by the blend wall and possible revisions to the RFS volume obligations.

University of Illinois RIN projections. A University of Illinois economist has published a report projecting how 2012 ethanol production will impact the number of banked RINs available for RFS compliance in 2013. The economist, Nick Paulson, projects that the combination of 2012 production and banked 2011 RINs will result in the availability of 1.895 billion RIN-gallons for carry-over for 2013 compliance. This represents a lower number of banked RINs than in any prior year since 2008.  Paulson’s report also showed that the value of “conventional” (corn ethanol) RINs tracked the price of corn, with a low of $0.01/gallon in June 2012 but rising as high as $0.05/gallon in July and August as the effects of the drought were becoming clear. The latest RIN price cited in the report was about $0.04/gallon in late October. Also click here for more information.

ISU Policy Brief projects outlook for ethanol RINs. The Center for Agricultural and Rural Development (CARD) of Iowa State University has issued a Policy Brief analyzing the economic factors that are likely to affect the value of corn ethanol RINs in 2013 and 2014. The Brief, written by Bruce Babcock, concludes that profit margins for corn ethanol will be low in 2013 due to the high corn prices caused by the 2012 drought, and may continue to be low if ethanol prices need to be discounted to meet the RFS mandates. Babcock believes that the U.S. ethanol market is saturated at 10% of total gasoline usage due to the “blend wall,” so that the rising RFS mandates will be hard to reach unless ethanol prices drop low enough to foster increased usage of E85, or unless barriers to E15 usage are overcome.  The Brief speculates on whether banked RINs will be used in 2013 to help offset current high production costs or in 2014 to help offset low ethanol prices.

New study documents economic impact of the RFS. Researchers at Oak Ridge National Laboratory published a paper in January analyzing the impacts of the RFS on the U.S. economy. According to the paper, the RFS has had several beneficial effects, including reducing crude oil prices and decreasing oil imports, which have resulted in a modest increase in the U.S. gross domestic product, and having only minor impacts on global food markets and land use. However, if future RFS mandates are met by biofuel imports, the favorable impacts on the U.S. economy would be lessened. The study, which is available for purchase here, apparently makes use of global economic modeling to forecast the impacts of the RFS through 2022.

Previous Biofuel Policy Watch posts on RFS policy:

D. Glass Associates, Inc. is a consulting company specializing in government and regulatory support for renewable fuels and industrial biotechnology. David Glass, Ph.D. is a veteran of over thirty years in the biotechnology industry, with expertise in industrial biotechnology regulatory affairs, U.S. and international renewable fuels regulation, patents, technology licensing, and market and technology assessments. Dr. Glass also serves as director of regulatory affairs for Joule Unlimited Technologies, Inc. More information on D. Glass Associates’ government and regulatory consulting capabilities, and copies of some of Dr. Glass’s prior presentations on biofuels and biotechnology regulation, are available at www.slideshare.net/djglass99 and at www.dglassassociates.com. The views expressed in this blog are those of Dr. Glass and D. Glass Associates and do not represent the views of Joule Unlimited Technologies, Inc. or any other organization with which Dr. Glass is affiliated. Please visit our other blog, Advanced Biotechnology for Biofuels

 

E15 and E85 Ethanol News: February 5, 2013

Here’s an update on recent news items and other public policy developments during the last few weeks relating to the use and market acceptance of 15% blends of ethanol into gasoline (“E15″) and other higher blends of ethanol such as E85.

E15 Federal Developments


Regulation of E15 storage at gas station underground storage tanks. The Petroleum Marketers Association of America (PMAA), in a January 8, 2013 letter, has called for EPA to withdraw a proposed rule updating the regulations for underground storage tanks (USTs), that included proposals for upgrading USTs to ensure compatibility with E15. This proposed rule was published on November 18, 2011, and attracted almost 200 responses during the public comment period that closed in April 2012. The proposed rule would specify how UST operators could prove tank compatibility with fuels having more ethanol than E10, more biodiesel than B20, or for other fuels such as biobutanol. Specifically, UST operators would need either to have UST system components certified or listed by a nationally-recognized testing laboratory, or to receive written approval of compatibility from the component manufacturer, or use another method acceptable to EPA. It is known that gas station operators are also concerned over these changes, which would be difficult to implement for UST that have been in place for many years, as well as other large capital expense infrastructure changes needed to accommodate E15 such as new gasoline dispensing systems (e.g. see these trade association comments on the EPA rule). In asking EPA to withdraw the proposed rule, PMAA has asked EPA to convene an expert panel to review and help mitigate the costs of the rule on small businesses.

E15 Developments in the States 


Update: Proposed anti-E15 legislation in Maine
. I had previously reported that the Maine Department of Environmental Protection was preparing to propose a bill that would ban the sale of gasoline containing more than 10% ethanol if at least two other New England states adopt a similar ban. It has now been reported that a state representative has introduced two related bills in the legislature. One of these bills would limit the percentage of corn-derived ethanol in Maine gasoline to 5%; and the other would allow the state to form a coalition with other New England states to create an ethanol-free gasoline market, which would be supplied by the Canadian petroleum-vendor Irving. The legislator, Rep. Jeff Timberlake, appears to have been motivated by the alleged damages ethanol causes to small engines, and by an opposition to the use of corn to produce fuel, and the subsidies he believes farmers are paid to grow corn for ethanol.

Update: Florida Renewable Fuel Standard Act. I previously reported on a bill that was filed in the Florida state legislature that would repeal that state’s Renewable Fuel Standard Act and remove the requirement that ethanol be blended into all gasoline sold in Florida. More recently, it has been reported that the Florida Agriculture Commissioner has dropped his opposition to this pending bill, House Bill 4001. The Commissioner’s opposition was reportedly key to blocking previous repeal attempts.

State Policies for E15. A recent article in Ethanol Producer News stated that E15 is available in Kansas, Iowa and Nebraska as well as one gas station in South Dakota. E15 is not yet available in Illinois although the infrastructure is in place and several retailers are preparing to sell E15. Other states may need to amend their laws to allow E15 sales: for example, although Missouri has an agriculture department that is generally friendly to ethanol, its laws specifically mention E10, so that legislative action will be needed to allow the sale of E15 in that state.

News Briefs:

Other E15 Developments 


Another study alleges that E15 causes engine damage. Another report has been issued that purports to show that E15 can damage fuel system components. The report, entitled “Durability of Fuel Pumps and Fuel Level Senders in Neat and Aggressive E15“, was issued by the Coordinating Research Council (CRC). As summarized in Biofuels Digest, the report claims to have shown that E15 can cause problems such as an elevated incidence of fuel pump failures, fuel system component swelling, and impairment of fuel measurement systems that could cause erratic and misleading fuel gauge readings or cause faulty check engine light illuminations. As reported in Ethanol Producer magazine, the ethanol industry is vigorously disputing this study, saying its study design is flawed and that it used an outdated fuel for this testing. For what its worth, this article in Ethanol Producer magazine also notes that the American Petroleum Institute is a “sustaining member” of CRC.

E85 News


E85 Availability in Virginia. The first three service stations offering E85 in Virginia have opened. The stations are operated by MAPCO Express, which is obtaining the fuel from Protec Fuel, and which has rebranded their retail stores under the “East Coast” brand. 

Previous Biofuel Policy Watch posts on ethanol policy:

D. Glass Associates, Inc. is a consulting company specializing in government and regulatory support for renewable fuels and industrial biotechnology. David Glass, Ph.D. is a veteran of over thirty years in the biotechnology industry, with expertise in industrial biotechnology regulatory affairs, U.S. and international renewable fuels regulation, patents, technology licensing, and market and technology assessments. Dr. Glass also serves as director of regulatory affairs for Joule Unlimited Technologies, Inc. More information on D. Glass Associates’ government and regulatory consulting capabilities, and copies of some of Dr. Glass’s prior presentations on biofuels and biotechnology regulation, are available at www.slideshare.net/djglass99 and at www.dglassassociates.com. The views expressed in this blog are those of Dr. Glass and D. Glass Associates and do not represent the views of Joule Unlimited Technologies, Inc. or any other organization with which Dr. Glass is affiliated. Please visit our other blog, Advanced Biotechnology for Biofuels

 

EPA’s 2013 Proposed Rules under the Renewable Fuel Standard

On January 31, EPA announced two long-awaited actions proposing new rules under the Renewable Fuel Standard.

Proposed volume obligations for 2013

The major announcement on January 31 was EPA’s issuance of its long-awaited proposed rule setting the 2013 volume mandates for the fuel categories under the RFS. As described in earlier posts on my Advanced Biotechnology for Biofuels blog, the 2007 legislation that created “RFS2” established annual mandates through 2022, but it also gave some discretion to EPA, specifically, the obligation to set each year’s mandated volume for biomass-derived diesel, and the discretionary ability to revise the volume mandate for cellulosic biofuels, both of which would be implemented through the rule-making process. EPA had previously set the volume mandate for biomass-derived diesel, and in the proposed rule, EPA used its power under the law to revise the originally-specified mandate for cellulosic biofuel, based on estimates of 2013 production capacity. The proposed volume of 14 million gallons was a substantial reduction from the statute-set mandate of 1 billion gallons, but higher than the 8.65 million gallon threshold for 2012 that was not met through actual production of fuel last year.

The chart below shows the proposed volumes, along with the “percentage standard”, which is the ratio of each category’s volume to the overall nonrenewable fuel market, which is used to calculate the volume obligations for each responsible party under the RFS. It is important to remember that the categories are nested: the fourth-listed category of “renewable fuel” represents the total of all fuels covered by the RFS, and the “advanced biofuel” category encompasses both “cellulosic biofuel” and “biomass-based diesel”.

EPA did not seem unduly influenced by the recent Appeals Court decision vacating the 2012 cellulosic standard, and the agency applied the same methodology for setting the cellulosic mandate as it did in previous years. However, as noted in today’s Biofuels Digest, the agency was somewhat more conservative in basing the volume mandate on its estimate of actual cellulosic fuel production for the year, rather than its estimate for what the total (annualized) capacity of cellulosic fuel production will be by yearend. It is widely expected that 2013 will be the first year where there is substantial production of ethanol and other fuels from cellulosic feedstocks, and so EPA’s projections seem to be achievable. The agency did not revise the overall volume mandates for the year, consistent with its prior position that other fuels qualifying as “Advanced Biofuels” (e.g. sugarcane ethanol, biomass-derived diesel) will be produced and used in sufficient volume to make up for the reduction in the cellulosic biofuel mandate – an approach that was validated by the Appeals Court in last week’s ruling.

Formal publication of the proposed rule in the Federal Register will open a 45 day comment period. One can expect the formal comments EPA receives, as well as those to be voiced online and elsewhere in the court of public opinion, to follow predictable lines. Biofuel opponents will likely challenge the 14 million gallon cellulosic volume mandate, as well as the fact that the mandates continue to require substantial amounts of corn-derived ethanol (the difference between the 16.55 billion gallons of all renewable fuels and the 2.75 billion gallons to come from advanced biofuels would be expected to be derived almost exclusively from cornstarch ethanol). In particular, one can expect a vigorous challenge to the cellulosic mandates from the American Petroleum Institute and its allies who have opposed EPA in the various lawsuits that have challenged the RFS and the cellulosic mandates.

It’s also interesting that EPA has largely stuck with its methodology for estimating the cellulosic volume mandate, albeit with a bit more caution, in spite of last week’s Court decision, because I had expected EPA to take a much more cautious approach in the wake of that decision. This could be a signal that EPA believes its approach to the cellulosic mandate is appropriate and consistent with the law, and that the agency intends to appeal last week’s decision.

Proposed 2013 RFS Volume Mandates.

Category Volume (gallons) % Standard
Cellulosic biofuel 14 million 0.008%
Biomass-based diesel 1.28 billion 1.12%
Advanced biofuel 2.75 billion 1.60%
Renewable fuel 16.55 billion 9.63%

RIN Validation

Also on January 31, EPA issued a second proposed rule which it says would “provide a structured process for buyers of Renewable Identification Numbers (RINs) … to verify their validity.” Under the RFS, RINs are the identifying numbers that are to be created when qualifying renewable fuels are produced, and which are used by obligated parties to meet their annual volume obligations under the law. As I have previously reported, EPA has been developing such a plan as a response to the 2012 discovery that several entities had issued RINs that did not correspond to any existing fuels, thus fraudulently benefitting from the economic value of the RINs without actually producing fuels. EPA is proposing that RINs be verified through a voluntary quality assurance plan under which third parties would establish programs to audit and verify RIN validity. The proposed rule is based on a Draft Quality Assurance Plan that EPA published in late October 2012, which I described briefly in a previous post. EPA has set a 30-day public comment period on this proposed rule, also to begin on formal publication in the Federal Register.

D. Glass Associates, Inc. is a consulting company specializing in government and regulatory support for renewable fuels and industrial biotechnology. David Glass, Ph.D. is a veteran of over thirty years in the biotechnology industry, with expertise in industrial biotechnology regulatory affairs, U.S. and international renewable fuels regulation, patents, technology licensing, and market and technology assessments. Dr. Glass also serves as director of regulatory affairs for Joule Unlimited Technologies, Inc. More information on D. Glass Associates’ regulatory affairs consulting capabilities, and copies of some of Dr. Glass’s prior presentations on biofuels and biotechnology regulation,  are available at www.slideshare.net/djglass99 and  at www.dglassassociates.com. The views expressed in this blog are those of Dr. Glass and D. Glass Associates and do not represent the views of Joule Unlimited Technologies, Inc. or any other organization with which Dr. Glass is affiliated. Please visit our other blog, Advanced Biotechnology for Biofuels