Aviation Organizations Urge 'Fixes' To EPA SAF Proposal

 - May 16, 2022, 12:54 PM

A cross-section of aviation and energy organizations appealed to the Biden Administration to remove roadblocks toward ramping up the availability of sustainable aviation fuel (SAF). Forty-two organizations last week wrote to national climate advisor Gina McCarthy that the Environmental Protection Agency (EPA) could take “simple first steps [that] would have a tremendous impact on SAF scale-up and enjoy broad support.” These steps will play a critical role in helping meet the administration’s SAF Grand Challenge to increase SAF production to at least three billion gallons per year by 2030, said the organizations.

Key to this, the groups said, is that the EPA release, but incorporate fixes, to proposed provisions involving biointermediates—feedstocks that have been partially converted at one facility but sent to a separate facility for final processing.

Among the fixes, they said should include the ability to process SAF feedstock at more than two facilities. EPA has proposed allowing the transfer of biointermediates between two facilities. However, SAF production can involve multiple steps that may involve three or more facilities. “It is vital that EPA provide flexibility,” they said.

In addition, they asked that EPA permit the sale of biointermediate feedstock to more than one refinery. “EPA has proposed that a biointermediate producer may only sell its feedstock to a single off-taker each year, which is clearly restrictive and would severely limit production scale-up while interfering with free competition in the fuels market.”

Further, EPA should update the definition of biocrude with a broader definition of refinery. This would recognize more potential processing facilities, the letter stated.

The organizations also are concerned that EPA is proposing physical segregation of biointermidiates, prohibiting commingling. “Preventing any commingling of fully fungible feedstocks in the biointermediate context will significantly raise costs for SAF producers and could render some SAF pathways impracticable,” they warned. And they also asked for the ease of restrictions on pipeline biogas.

“The aviation industry stands united in calling for sound regulatory and legislative policies that will foster increased production of SAF—a cleaner, more sustainable, drop-in fuel that is crucial to meeting our industry’s goal of net-zero carbon emissions by 2050,” said Karen Huggard, managing director of legislative affairs and industry relations for the National Air Transportation Association, which was a signatory of the letter.