EPA Finding on Aircraft Emissions Can't Be Counted on to Motivate Biofuels Development and Deployment

by Joanne Ivancic* (Advanced Biofuels USA) In the world of renewable jet fuel, hopes that the Environmental Protection Agency's finding that greenhouse gases from aircraft pose a risk to human health might lead to incentives for development and use of aviation biofuels have been diminished, as the Civil Aviation Alternative Fuels Initiative (CAAFI) explains that EPA plans only to look at tailpipe emissions, not at life cycle carbon intensity.

Thus, the same reasoning that supports the idea that plug-in, battery-operated electric vehicles with power sourced at coal-fired power plants have "zero emissions" will spur the aviation industry to concentrate on engine designs that will make no significant impact for scores of years rather than motivate the industry to develop and deploy less carbon intense fuels that could have a significant impact in dozens of months.

You could just say, "oh, well" or you could plan to contribute comments to EPA on this subject.

In response to a request for comment from Advanced Biofuels USA, CAAFI executive director, Steve Csonka, explained the whole situation in detail:

"The expected finding that aircraft greenhouse gas emissions "cause or contribute" to an "endangerment" is under Section 231 of the Clean Air Act. The CAA only authorizes EPA to adopt aircraft engine emission standards for air pollutants that pose "endangerment." So, this finding sets in motion the EPA going down the path of establishing CO2 certification standards for aircraft/engines (fuel burned per passenger mile flown - think CAFÉ standards for cars) that the manufacturers will have to meet for new aircraft production.

"It has nothing to do with the actual operation of the aircraft, or the total amount of fuel burn from the industry, or the carbon content of SAJF (ed: sustainable alternative jet fuels). We expect the new CO2 standards will be approved by ICAO (ed: International Civil Aviation Organization) next year for implementation in the following several years - EPA has signaled they intend to use the ICAO standards, as they already do with standards for CO, UHC, smoke, NOx, and noise (and PM soon). The entire industry has been working on the definition of these standards in ICAO/CAEP deliberations for the past several years. The metric has already been defined, and the final work is being done on implementation (cost/benefit of setting the stringency to be applied, when, etc.).

"That said, the aviation industry's message remains that alternative fuels are an important element in a combined "basket of measures," needed alongside the future CO2 certification standard for new aircraft, to help us meet our voluntary emissions goals (CNG 2020, and the eventual 50% reduction in net carbon). The industry continues to work with ICAO on the development of a market based mechanism (MBM) that helps us address total CO2 production and carbon neutral growth - it is also expected to be approved next year for implementation in 2020. That is where the use of alternative fuels come into play. That could take the form of having alternative fuel usage being removed from airline inventories associated with the mechanism, carbon pricing, etc. But again, this has nothing to do with the EPA endangerment activity.

"So, biofuels cannot assist us in meeting the new EPA regulations. The EPA regs will only establish fuel mileage standards for new aircraft. EPA has no authority to go beyond that, nor do I believe they can point to the use of such fuels as obviating the need to establish the standards. Same situation as with cars."

In the past, some accommodations, waivers and regulatory adjustments have been made to CAFE (Corporate Average Fuel Economy) standards that have encouraged the use of biofuels; credit for production of flex fuel vehicles that could use 85% ethanol, for example. Perhaps the same kind of flexibility could exist in regulations developed in response to EPA's latest "endangerment" finding. Nothing of the kind will even be considered without a "push" from the public. One opportunity is to attend public hearings; another is to submit written comments.

If you would like to comment in person, the EPA will hold a public hearing on August 11, 2015 in Washington, DC, at the William Jefferson Clinton East Building, Room 1153, 101 Constitution Avenue NW, Washington, DC 20004. Speakers should contact Ms. JoNell Iffland to request to speak at the hearing. The last day to pre-register in advance to speak at the hearing will be August 6, 2015. The hearing will start at 10:00 am local time and continue until everyone has had a chance to speak. Requests to speak will be taken the day of the hearing at the hearing registration desk, although preferences on speaking times may not be able to be fulfilled. For further information on the public hearing or to register to speak at the hearing, go to http://www.epa.gov/otaq/aviation.htm.

• Online: www.regulations.gov Follow the on-line instructions for submitting comments.

• Email: A-and-R-Docket@epamail.epa.gov Attention Docket ID No. EPA-HQ-OAR- 2014-0828.

• Mail: U.S. Postal Service, send comments to Air and Radiation Docket and Information Center, Environmental Protection Agency, Mail Code: 28221T, 1200 Pennsylvania Ave., NW, Washington, DC 20460. Attention Docket ID No. EPA-HQOAR-2014-0828.

• Hand Delivery: U.S. Environmental Protection Agency, EPA West, EPA Docket Center, EPA West Building, Room 3334, 1301 Constitution Ave., NW., Washington, DC 20004. Attention Docket ID No. EPA-HQ-OAR-2014-0828.

*Joanne Ivancic, serves as Executive Director of Advanced Biofuels USA. She also served as a lobbyist promoting advanced biofuels research and production on Capitol Hill and with executive agencies. She has observed the development of advanced biofuels’ research and financing for more than fifteen years. From 2010 to 2015 she was voted one of the Top 100 People in Bioenergy by Biofuels Digest readers and editors.