Abstract
Editor's Note
The following was taken from public comments submitted by the Alternative Fuels & Chemicals Coalition to the Office of Science and Technology Policy (OSTP) on Sustainable Chemistry (published in Federal Register Vol. 87, No. 64, Monday, April 4, 2022, page 19539) in response to an OSTP request for input from interested parties on the definition of sustainable chemistry. OSTP noted that the term “sustainable chemistry” does not have a consensus definition and most uses of the term indicate that it is synonymous with “green chemistry.” Publications and legislation have typically treated sustainable chemistry and green chemistry synonymously, OSTP says, adding that green chemistry has traditionally focused on hazardous substances, while sustainable chemistry has been used in the context of both hazardous and non-hazardous substances. OSTP also requested comments on how the definition of sustainable chemistry could impact the following: The role of technology, Federal policies that may aid or hinder sustainable chemistry initiatives, future research to advance sustainable chemistry, financial and economic considerations, and Federal agency efforts. Comments provided in response to this RFI will be used to address Subtitle E—Sustainable Chemistry of the 2021 National Defense Authorization Act (NDAA) to identify research questions and priorities to promote transformational progress in improving the sustainability of the chemical sciences.
Introduction
The Alternative Fuels & Chemicals Coalition (AFCC) is a collaborative government affairs effort organized by the Kilpatrick Townsend & Stockton law firm and American Diversified Energy. AFCC was created to address policy and advocacy gaps at the federal and state levels with respect to renewable chemicals, bioplastics/biomaterials, cell-cultured food ingredients, single cell protein for food and feed, enzymes, alternative fuels, biobased products and sustainable aviation fuels sectors. AFCC member companies work on food and fiber supply chain security and sustainability, renewable chemicals, industrial biotechnology, bioplastics and biomaterials, and biofuels.
Industrial biotechnology uses microbial conversion technologies and gene editing methodologies in the development of sustainable products which mitigates climate change. Ground transportation and aviation biofuels from biomass provide opportunities to lower GHG emissions, especially in the use of biogenic carbon. The application of industrial biotechnology in the manufacturing of everyday products such as bioplastics, cosmetics, food ingredients, and additives minimize pollutants relative to fossil fuel manufacturing processes. When these new biotech-based manufacturing processes are combined with upstream, infield carbon sequestration processes, lower carbon intensity products are being produced. Renewable chemicals including bioplastics and biofuels can be made from a variety of biobased feedstocks such as agricultural or municipal waste, residue recovered from forests and grasslands that have been destroyed by fires or pests, algae, switch grass, and carbon oxide emissions. Biogenic carbon capture is the most cost-effective and near-term pathway to remove carbon oxide. Consumers now are increasingly demanding low carbon intensity products and more sustainable replacements for existing products. Industrial biotechnology allows for the production of low-carbon options through substitution of recycled carbon and use of tools available in sustainable chemistry.
Background
The term ‘‘sustainable chemistry’’ does not have a consensus definition and most uses of the term indicate that it is synonymous with ‘‘green chemistry.’’ Therefore, OSTP requests information on the preferred definition for Sustainable Chemistry. In addition, OSTP requests comments on how the definition of Sustainable Chemistry could impact: the role of technology, federal policies that may aid or hinder sustainable chemistry initiatives, and future research to advance sustainable chemistry, financial and economic considerations, and federal agency efforts.
Publications and legislation have often treated sustainable chemistry and green chemistry synonymously. However, green chemistry has traditionally focused on hazardous substances, while sustainable chemistry has been used in the context of both hazardous and non-hazardous substances. For example, EPA define: ‘‘Green chemistry as the design of chemical products and processes that reduce or eliminate the use or generation of hazardous substances. Green chemistry applies across the life cycle of a chemical product, including its design, manufacture, use, and ultimate disposal. Green chemistry is also known as sustainable chemistry.’’
Congress used the term ‘‘sustainable chemistry’’ and included expanded concepts such as pollution prevention, reducing risk, efficient manufacturing, and ‘‘ efficient use of resources in developing new materials, processes, and technologies that support viable long-term solutions to a significant number of challenges.”
The 38 members of the Organisation for Economic Co-operation and Development (OECD) follows on the United Nations' call for Sustainable Development Goals (SDGs) and considers a much broader definition that incorporates efficiency in the use of natural resources: ‘‘Sustainable chemistry is a scientific concept that seeks to improve the efficiency with which natural resources are used to meet human needs for chemical products and services. Sustainable chemistry encompasses the design, manufacture and use of efficient, effective, safe and more environmentally benign chemical products and processes.’’
A GAO publication (GAO–18–307) titled “Chemical Innovation: Technologies to Make Processes and Products More Sustainable” equated ‘‘green chemistry’’ with ‘‘sustainable chemistry’’ and found that participating stakeholders lacked agreement on how to define, measure, or assess the sustainability of chemical processes and products. The GAO did find several common themes on what sustainable chemistry strives to achieve:
Improve the efficiency with which natural resources—including energy,
water, and materials—are used to meet human needs for chemical products while avoiding environmental harm;
Reduce or eliminate the use or generation of hazardous substances in the design, manufacture, and use of chemical products;
Protect and benefit the economy, people, and the environment using innovative chemical transformations;
Consider all life-cycle stages including manufacture, use, and disposal when evaluating the environmental impact of a product; and
Minimize the use of non-renewable resources.
Comments from AFCC Member Companies
OSTP CONSENSUS DEFINITION FOR THE TERM “SUSTAINABLE CHEMISTRY”
OSTP consensus definition for the term ‘‘sustainable chemistry’’ to potentially include technology, policy, finance/economics, energetics, national security, critical industries, and critical natural resources & prioritizing and implementing research and development programs to advance sustainable chemistry practice in the United States.
In order to arrive at recommendations to OSTP for a consensus definition of “Sustainable Chemistry”, one has to first consider the scope of the term “Sustainability” or “Sustainable Development”. The term can then be used to characterize different aspects of a wholistic approach toward achieving Sustainability goals, such as “sustainable growth” and “sustainable chemistry”.
Ever since the 1987 UN “Brundtland Commission” report (“Our Common Future”), 1 Sustainable Development is defined as development that meets the needs of the present without compromising the ability of future generations to meet their own needs. This definition unified environmentalism with social and economic concerns on the world's development agenda. Indeed, the concept can be used to guide decisions at the global, national and at the individual consumer level.
Today, the UN Sustainable Development Goals include 17 dimensions: 2
No Poverty
Zero Hunger
Good Health & Wellbeing
Quality Education
Gender Equality
Clean Water & Sanitation
Affordable & Clean Energy
Decent Work & Economic Growth
Industry, Innovation & Infrastructure
Reduced Inequalities
Sustainable Cities & Communities
Responsible Consumption & Production
Climate Action
Life below Water
Life on Land
Peace, Justice & Strong Institutions
Partnerships for the Goals
Of these 17 ESG Goals, 13 have direct ties to how chemistry is developed, used, and governed (ESG Goals 3 and 6-17), whereas goals 1,2,4, and 5 have indirect ties to Chemistry, in particular via ESG aspects that impact access to and understanding of advanced chemistry. Hence, to the extent that technology, policy, finance/economics, energetics, national security, critical industries, critical natural resources, and research and development programs related to chemicals and chemistry impact any of the above ESG goals, they are inherently part of the definition of Sustainable Chemistry.
Aspects of both Green Chemistry and Sustainable Chemistry include one or more of the following: technology (such as modern biotechnology) that drives increased use of renewable resources instead of fossil fuels, use of biodegradable chemicals and biotechnology to render them more biodegradable, re-use, and recycling or upcycling of products and waste streams. All of these contribute to the development of the circular economy.
By virtue of the rigorous methodology developed to underpin Sustainability (Life Cycle Analysis), Sustainable Chemistry inherently incorporates both the development and use of products as well as the processes used to generate these products (up the supply chain) and the processes impacted by these products throughout their life cycle, all the way to the end-consumer. Issues of access to technology (including biotechnology) and safe use of chemistry (with respect to human health, the environment, and national security) are core to the definition of Sustainable Chemistry from policy making, regulatory, and research and development prioritization perspectives.
The definition of “Sustainable” in connection with “Chemistry” is much broader than “green”, which is generally focused on the environment and hazardous substances. As such, “Green Chemistry” and “Sustainable Chemistry” are not synonymous, but Green Chemistry is part of the much broader scope of Sustainable Chemistry.
TECHNOLOGIES THAT WOULD BENEFIT FROM FEDERAL ATTENTION
Technologies that would benefit from Federal attention to move society toward more sustainable chemistry: What technologies/sectors stand to benefit most from progress in sustainable chemistry or require prioritized investment? Why? What mature technology areas, if any, should be lower priority?
Industrial Biotechnology, including synthetic biology, gene editing and in vitro animal cell culture, has become an essential toolbox to improve microbes, plants, and cell systems to produce renewable chemicals for use in industrial applications, consumer applications, agriculture and food, in what can only be referred to as the convergence of chemistry and biology in a rational design approach. Biotechnologies such as synthetic biology and cell culture are on rapid trajectories of development, but adoption of the most advanced techniques is limited largely due to 1) lack of standardization and 2) scale-up hurdles, the exact nature of which may vary somewhat between microbial and animal cell systems.
Even though the enzyme industry is relatively mature, enzyme catalysis is still largely unexplored (with a few exceptions) and holds great potential as 1) enzymes are made from renewable resources and 2) they are recycled in use, in particular if protein-engineered to perform in a stable manner under the desired reaction conditions. Beyond “digestive” applications of common enzymes used in cleaning and processing of agricultural commodities into biofuel, food and animal feed, enzyme catalysis applications range from enzymatic synthesis of chemicals and polymers to enzymatic modification of naturals. Not unlike the scale-up hurdles mentioned under industrial biotechnology, a key factor to success and sustainability impact is the selection of appropriate scale of operations, as well as the availability of substrate.
Biomass conversion technologies using chemocatalytic processes (homogeneous or heterogeneous catalysis) to directly convert cellulose in biomass into key platform chemicals such as polyols, furans, and glucose. Chemocatalytic technologies produce sustainable chemicals by reducing the production of greenhouse gas emissions while compared to the traditional petrochemical industry.
Chemicals produced from biomass that are drop-in ready and can leverage existing recycling infrastructure.
Natural chemicals produced by microorganisms on land and in the ocean are an abundant, untapped resource of non-toxic, highly effective replacement for thousands of tons of hazardous petrochemicals. There is currently no funding for the identification of these natural chemicals or for their commercialization, classification, scale-up, regulatory approval.
FUNDAMENTAL RESEARCH AREAS
What fundamental and emerging research areas require increased attention, investment, and/or priority focus to support innovation toward sustainable chemistry (e.g., catalysis, separations, toxicity, biodegradation, thermodynamics, kinetics, life-cycle analysis, market forces, public awareness, tax credits, etc.). What Federal research area might you regard as mature/robustly covered, or which Federal programs would benefit from increased prioritization?
LCA
In order to support sustainability claims, Life Cycle Analysis is used as a tool to quantify inputs, outputs, emissions and various other aspects. Conducting a full LCA is costly and time-consuming, and a consensus on a more rapid or streamlined approach would benefit from investment.
Lower GHG emissions
Sustainable claims should cover processes that produce products with lower lifecycle greenhouse gas emissions when compared to fossil-based chemical products. This reduction in lifecycle GHG's can come from using sustainable feedstocks with biogenic carbon.
Policy hurdles
In order to promote the application of Sustainable Chemistry, various policy hurdles need to be overcome—including promotion of Sustainable Chemistry as a pillar of the Bioeconomy and recognition/education of its compatibility (of using renewable resources) with food use, followed by appropriate incentives that promote R&D investment - especially in scale-up.
Natural chemical research and development.
QUANTITATIVE FEATURES
Potential outcome and output metrics based on the definition of sustainable chemistry: What outcomes and output metrics will provide OSTP the ability to prioritize initiatives and measure their success? How does one determine the effectiveness of the definition of sustainable chemistry? What are the quantitative features characteristic of sustainable chemistry?
There must be more transparency or disclosure on the part of the chemical manufacturer, scrutiny by qualified inspectors, and rigorous EPA and FDA toxicology testing to establish hard limits of use, concentrations, disposal protocols, for harmful fossil fuel chemicals. Those limits need robust enforcement with bans and sanctions for non-compliance. For example, to force the urgent need to remove harmful PFAS chemicals from the groundwater of communities adjacent to military bases.
Federal programs funding recycling with the appropriate disposal for bioplastics which are marine biodegradable and compostable should use sustainable chemistry. Federal agencies funding sustainable solutions for recycling and infrastructure for composting, should use best practices established by sustainable chemistry.
Carbon capture and utilization for carbon emission decarbonizing the planet, measuring the emissions or draw down in smart climate farm practices in soil, which is regenerative agriculture or also known as science based sustainable farming has inherent uses of tools from sustainable chemistry, and therefore, should provide our farmers tax incentives (Section 45Q) for producing healthy soils by using compost for improving soil health which is an emerging solution to protect the climate and restoring the Earth's topsoil for better draw down of carbon dioxide in soil, thereby reducing emission in the atmosphere, and the soil is the carbon sink for smart climate practices for U.S. farmers.
Chemicals that show a decrease on impact on human health and the environment, lower carbon intensity compared to the traditional petrochemical industry, and integrated into everyday products that support the decarbonizing of supply chains.
Microalgae cultivation captures 400x more carbon than a tree. Support is needed to expand microalgae production in urban areas, including in bioreactors on rooftops fed directly by flue pipes and rural areas, such as inarable land, and deserts, using any water source, including bracking and recycled water.
U.S. chemical manufacturing industry could produce renewable products through retrofitting existing petrochemical manufacturing facilities, which in turn will support U.S. agricultural feedstocks, and job creation where these feedstocks are grown.
ECONOMIC CONSIDERATIONS
Financial and economic considerations for advancing sustainable chemistry: How are financial and economic factors considered (e.g., competitiveness, externalized costs), assessed (e.g., economic models, full life cycle management tools) and implemented (e.g., economic infrastructure).
Federal programs such as grants, loan guarantees, and awards, to produce sustainable solutions for replacing fossil fuel-based chemicals will promote sustainable chemistry. Promoting and funding USDA and DOE grant programs and loan guarantees will increase sustainable manufacturing in the U.S. Maintaining EPA's Presidential Green Chemistry and Safer Choice awards, both of which promote and reward the process and production of sustainable chemistry-based products need continuous federal support and funding. These federal agencies and programs they administer should use the same standard modeling methodology for assessing sustainability or the production of sustainable chemistry; implementing the gold standard GREET LCA model, encouraging all federal agencies to be transparent in the use of GREET LCA modeling methodology to produce renewable chemicals and biofuels.
Providing an investment or production tax credit for sustainable production of renewable chemicals (including bioplastics) will promote manufacture of sustainable chemicals. These tax incentives are available to other sectors such as wind, solar, and geothermal. Natural chemicals and renewable chemicals which are sustainably produced for food ingredients and biomaterials are not eligible for these tax incentives, therefore, by levelling the playing field will promote sustainably produced chemicals (natural and renewable chemicals) to receive these tax incentives. Tax incentives for renewable chemicals (includes bioplastics) will promote growth, as companies look to deploy capital in a highly uncertain economic (COVID-19 recovery, inflation, and supply-chain constraints) and geopolitical time, investors stressing the importance of disciplined allocation. Congress needs to take a positive step in providing that certainty, as government support is pivotal, and changes are necessary to ensure the economic viability of renewable chemical projects and the deployment of capital. The shortage of oil in United States and globally provides an opportunity to implement sustainable chemistry tools and provide tax incentives for manufacturers to invest in lower carbon technologies for renewable chemical manufacturing and protecting national security interests. It is imperative that America leads the world in combatting climate change and reducing dependence on fossil fuels. Providing tax credits to produce renewable chemicals, will decrease our dependence on the fossil fuel industry.
POLICY
Policy considerations for advancing sustainable chemistry: What changes in policy could the Federal government make to improve and/or promote sustainable chemistry?
OSTP should consider the following actions to advance sustainable chemistry:
Create an NSF educational training program for graduating students in natural chemical, renewable chemical development, biofuels, and sustainable production of biobased products using industrial biotechnology tools such as synthetic biology and other microbial conversion technologies in industry, or using traditional catalysis to convert renewable resources to high value biobased products/biomaterials—the program will educate students in conducting research and biobased manufacturing scale-up for sustainable production of renewable chemicals (includes bioplastics) for food ingredients, alternative proteins and food substances, biogas, sustainable aviation fuels, and ground transportation biofuels. This would result in providing the student course credits, job-training, and experience to, create a new generation of U.S. scientists, and keep the U.S. globally competitive.
Develop public-private partnership in sustainable chemistry for the development of U.S. biobased manufacturing programs and maintain domestic manufacturing experts – this program would be based on matching grants from the private sector and the federal program.
Encourage employment in rural America by promoting and rewarding rural employment in biobased manufacturing using sustainable chemistry (federal program could pay for a one-year employment to employees accepting positions in rural America).
Policies that can provide incentives to scale-up and commercialize new sustainable chemistry technologies would balance the risks around a first plant with new technology.
Policies that provide incentives for producers and/or purchasers of renewable chemicals to cover initial higher costs of these products relative to petrochemicals.
INVESTMENT CONSIDERATIONS
Investment considerations when prioritizing Federal initiatives for study: What issues, consequences, and priorities are not necessarily covered under the definition of sustainable chemistry, but should be considered when investing in initiatives? Public Law 114–329, discussed in the background section above, includes the phrase: ‘‘support viable long-term solutions to a significant number of challenges’, such as national security, jobs, funding models, partnership models, critical industries, and environmental justice.
Definition of Sustainable Chemistry
AFCC member companies would propose the following definition for “Sustainable Chemistry”: Sustainable Chemistry leverages ever-evolving technology often at the nexus of biology and chemistry to optimize the use of natural resources to meet human needs for chemical products and services in a wide range of applications, while reducing their environment impact and benefitting society at large. It encompasses the design, manufacture, access, use, and end-of-life of chemical products using efficient, effective, equitable, safe and environmentally preferable inputs, processes, and products.
Conclusion
The definition of sustainable chemistry has several identifiable importance to the industrial biotechnology sector, and its implementation needs to be accounted for across the value chain and promoted through federal programs and public private partnerships. AFCC and its member companies stand prepared to provide further clarification. Thank you for the opportunity to provide our views and vision for sustainable chemistry.