D. Glass Associates, Inc.

Government and Regulatory Affairs
Certification and Sustainability of Renewable Fuels

A variety of government programs in the U.S., Europe and elsewhere in the world potentially affect companies developing biofuels or other renewable fuels. In many countries, new motor vehicle or aviation fuels need to be approved or certified by a government agency before they can be legally sold. In addition, renewable fuels may need to be accepted under sustainability schemes such as the U.S. Renewable Fuel Standard or the EU Renewable Energy Directive in order to qualify for the credits or other economic value available under such regulations. D. Glass Associates, Inc. (DGA) can assist renewable fuel companies in planning for, and compliance with, such regulations, including the following. Renewable Fuels

Services Offered

  • Assist in planning for and compliance with the U.S. Renewable Fuel Standard. DGA can analyze whether the fuels a company is developing qualify as “renewable fuels” under the RFS, and for those fuels not covered under any existing fuel pathway, we can coordinate the preparation and filing of new pathway petitions. DGA can also help companies producing renewable fuels plan for the issuance of Renewable Identification Numbers (RINs), and we can assist in liaison to EPA on most matters pertaining to the RFS.

  • Assist in compliance with the California Low Carbon Fuel Standard. DGA can assess whether a fuel is covered under the Low Carbon Fuel Standard (LCFS) administered by the California Air Resources Board (ARB). We can help companies prepare and file Method 2A or 2B petitions to have new fuels accepted under the LCFS.

  • Certification to sell new renewable fuels. Over and above the requirements of the federal RFS, fuel manufacturers must have their fuels certified for sale and use in the U.S. For motor vehicle fuels, certification must be obtained from the U.S. EPA under 40 CFR Part 79. The approval process for civilian and military aviation fuels is more complicated, and involves engine testing for performance and compatibility with common aircraft engines, in conformance with applicable ASTM standards. DGA can help companies navigate either certification process.

  • Compliance with renewable fuel standards and sustainability programs outside the U.S. DGA can help companies understand the impact of renewable fuels programs elsewhere in the world, such as European Union Renewable Energy Directive, and we can assist in the needed steps to have a fuel pathway certified as sustainable in order to comply with such regulations.

  • Other permitting matters for renewable fuel plants. DGA can assist in applying for and obtaining certain permits required for fuel production in the U.S., including Alcohol Fuel Plant permits from the U.S. Treasury Department Alcohol and Tobacco Tax and Trade Bureau (TTB) and other permits for biofuel plant construction and operation.

  • Monitor government and legislative activity relating to biofuels and bio-based chemicals, including international public policy matters, and provide periodic reports to company management, or assist in government relations efforts in support of company initiatives.


David J. Glass, Ph.D. has over 30 years experience in the biotechnology industry, including extensive experience with the regulation of industrial biotechnology and recent experience managing regulatory affairs for a major U.S. renewable fuels company. Dr. Glass has advised several leading biofuels companies on the impact of biotechnology regulations on their activities. He has also coordinated the preparation and filing with the U.S. EPA of a new pathway petition under the Renewable Fuels Standard, and has successfully obtained a Medium Alcohol Fuel Producer permit from the U.S. Alcohol and Tobacco Tax and Trade Bureau.

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