by Katie Schroeder (Ethanol Producer Magazine) ... The industry waited for not months, but years to get an answer to that question, finally receiving direction in the 40BSAF-GREET 2024 model, released at the end of April.
In an exclusive podcast interview with Ethanol Producer Magazine, Geoff Cooper, CEO of the Renewable Fuels Association, explained that the process of bringing the new model forward was a steep challenge punctuated by the fact that it is widely considered to be a starting point. Cooper and others say the 2024 version of GREET—used in calculating greenhouse gas (GHG) emissions for both hydroprocessed esters and fatty acids (HEFA) and alcohol-to-jet (ATJ) SAF pathways—is the first step in working out how to translate greenhouse gas reduction into the language of the tax code. The modified GREET will only apply to the existing 40B SAF blending credit, which expires at the end of 2024. It will be replaced with 45Z, also known as the Clean Fuels Production tax credit, in 2025, and ethanol’s top voices are working diligently to shape it into a useful mechanism for ATJ production growth.
The History of 40BSAF-GREET
As Ethanol Producer Magazine previously reported, the 40B tax credit is a biofuel production incentive created by the IRA, signed into law in August 2022. The 40B tax credit offers SAF producers $1.25 per gallon of fuel that has a 50% greenhouse gas (GHG) reduction compared to petroleum-based jet fuel. For SAF with a GHG reduction greater than 50%, the incentive increases—one cent for each percentage point—up to $1.75 per gallon. In the legislation, the International Civil Aviation Organization’s most current CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) model “or similar methodology” were identified as acceptable ways to calculate the GHG of the SAF seeking to qualify for the program.
Early on, the ethanol industry championed the use of the Department of Energy-Argonne National Laboratory’s GREET (Greenhouse Gases, Regulated Emissions and Energy Use in Transportation) model, arguing that it should qualify as a “similar methodology.” They argued, effectively, that GREET offers a more accurate calculation of U.S. farming practices than CORSIA, which is governed by international consensus. “We and others pushed the administration, and specifically Treasury, to recognize the GREET model as that ‘other methodology,’” says Brian Jennings, CEO of the American Coalition for Ethanol. In mid-December, the Treasury department and the IRS released SAF tax credit guidance, stating that taxpayers would be able to use an updated iteration of the GREET model, made specifically for the 40B tax credit. Chris Bliley, senior vice president of regulatory affairs with Growth Energy, explains that the organization views “Argonne GREET”—the preceding version of the model—as the “gold standard” when it comes to GHG emissions analysis.
The new model and guidance were released on April 30, nearly two months after the self-imposed deadline of March 1. Industry representatives have applauded the inclusion of a variety of GHG reduction strategies including regenerative farming practices, renewable energy usage and carbon capture and sequestration. However, there are several GHG emissions reduction strategies not included in the model and others that are undervalued, explains Bliley.
Pros and Cons
Industry representatives point to encouraging elements included in 40BSAF-GREET, as well as some of the ways the model is lacking.
A lower induced land-use change number for ATJ SAF compared to the CORSIA model is one of the positive elements present in the model. 40BSAF-GREET assigns a nine-point induced land-use change penalty to SAF produced using corn ethanol, which is better than what ACE was expecting. “There’s not zero land-use change, but EPA and others have suggested that land-use change should be 20 or 30 points, so a nine-point induced land-use change penalty is reasonable and something we can certainly live with,” Jennings says. There was some worry that the indirect land-use change (ILUC) number would be unreasonably inflated out of concerns that farmers might start growing SAF feedstocks more aggressively with new market incentives in place.
...
The ILUC number for corn ethanol-based SAF dropped from 14 grams per megajoule under 2023 Argonne GREET, an encouraging development, but not low enough, Cooper says. “Yes, that’s a step in the right direction, but we believe that the data—the evidence from the real world—[justifies] zero penalty or a very low number, low enough to be negligible,” he says.
The GHG benefit of carbon capture and sequestration (CCS) is defined within the new GREET model, too, giving ethanol producers the option to reduce emissions by 33 points by integrating it into their process. Many ethanol producers have been considering CCS as a strategy to meet the low GHG threshold, either as part of a CO2 pipeline project or onsite sequestration, Jenning explains. This 33-point valuation is what’s needed for many ethanol producers to reduce their emissions enough to reach the SAF market.
One of the most important breakthroughs within 40BSAF-GREET is the inclusion of climate-smart agriculture practices. “It opened the door for the very first time [to formally recognizing that] agriculture practices indeed have a meaningful impact on the carbon intensity of biofuels, so we were pleased with that,” Jennings says. ACE is helping lead the U.S. Department of Agriculture’s Regional Conservation Partnership Program, or RCPP, partnering with corn farmers and ethanol producers to demonstrate the impact that these farming practices can have.
“We don’t have any objections to the GREET model per se, we’ve always believed the GREET model is by far the superior method or approach to calculate lifecycle greenhouse gas emissions,” Jennings says. “The concerns we have with 40BSAF-GREET are not the GREET model itself, [but rather the] limitations or conditions [that have been] attached to [it] that have more to do with, frankly, politics than science.”
The carbon reduction impact assigned to climate smart agriculture practices within 40BSAF-GREET is one of the elements that Jennings believes must be decided by science alone.
...
Cooper also emphasizes that it is a mistake for Treasury to take a “one-size-fits-all” strategy when calculating the benefits of climate-smart farming. He explains that the requirement to use the three different practices together also simply does not work in the northern regions of the Corn Belt, and the model should account for the unique climate conditions and geography found in different parts of the country.
...
There are also several key GHG reduction strategies that are not included in 40BSAF-GREET, including combined-heat-and-power technology, energy sources such as hydroelectric power and biomass-to-power, sorghum as a feedstock for ethanol, as well as ethanol wet mills, explains Bliley.
...
In April, EPM reported that agencies will do further work on modeling, data, assumptions and verification to credit climate-smart ag practices for 45Z; it’s also been stated that a new 45Z-GREET model will be developed for use with the 45Z tax credit.
...
The producers in Jennings’ organization are eager to receive the details and rules that could determine whether the investments they have made, or plan to make, in efficiency-improving technologies will pay off in the context of access to 45Z tax credits.
...
One of RFA’s priorities moving forward is making sure the auditing and verification process are implemented in a way that does not discourage investment, and instead ensures that the process is extensive enough to provide the “assurance” needed by the IRS and Treasury department, he explains.
45Z tax credits are currently slated to run from the beginning of 2025 to the end of 2027, these three years are a small window for qualifying GHG reduction technologies to be financed and rolled out, Bliley explains. READ MORE
More than 50,000 articles in our online library!
Use the categories and tags listed below to access the nearly 50,000 articles indexed on this website.
Advanced Biofuels USA Policy Statements and Handouts!
- For Kids: Carbon Cycle Puzzle Page
- Why Ethanol? Why E85?
- Just A Minute 3-5 Minute Educational Videos
- 30/30 Online Presentations
- “Disappearing” Carbon Tax for Non-Renewable Fuels
- What’s the Difference between Biodiesel and Renewable (Green) Diesel? 2020 revision
- How to De-Fossilize Your Fleet: Suggestions for Fleet Managers Working on Sustainability Programs
- New Engine Technologies Could Produce Similar Mileage for All Ethanol Fuel Mixtures
- Action Plan for a Sustainable Advanced Biofuel Economy
- The Interaction of the Clean Air Act, California’s CAA Waiver, Corporate Average Fuel Economy Standards, Renewable Fuel Standards and California’s Low Carbon Fuel Standard
- Latest Data on Fuel Mileage and GHG Benefits of E30
- What Can I Do?
Donate
DonateARCHIVES
- August 2024
- July 2024
- June 2024
- May 2024
- April 2024
- March 2024
- February 2024
- January 2024
- December 2023
- November 2023
- October 2023
- September 2023
- August 2023
- July 2023
- June 2023
- May 2023
- April 2023
- March 2023
- February 2023
- January 2023
- December 2022
- November 2022
- October 2022
- September 2022
- August 2022
- July 2022
- June 2022
- May 2022
- April 2022
- March 2022
- February 2022
- January 2022
- December 2021
- November 2021
- October 2021
- September 2021
- August 2021
- July 2021
- June 2021
- May 2021
- April 2021
- March 2021
- February 2021
- January 2021
- December 2020
- November 2020
- October 2020
- September 2020
- August 2020
- July 2020
- June 2020
- May 2020
- April 2020
- March 2020
- February 2020
- January 2020
- December 2019
- November 2019
- October 2019
- September 2019
- August 2019
- July 2019
- June 2019
- May 2019
- April 2019
- March 2019
- February 2019
- January 2019
- December 2018
- November 2018
- October 2018
- September 2018
- August 2018
- July 2018
- June 2018
- May 2018
- April 2018
- March 2018
- February 2018
- January 2018
- December 2017
- November 2017
- October 2017
- September 2017
- August 2017
- July 2017
- June 2017
- May 2017
- April 2017
- March 2017
- February 2017
- January 2017
- December 2016
- November 2016
- October 2016
- September 2016
- August 2016
- July 2016
- June 2016
- May 2016
- April 2016
- March 2016
- February 2016
- January 2016
- December 2015
- November 2015
- October 2015
- September 2015
- August 2015
- July 2015
- June 2015
- May 2015
- April 2015
- March 2015
- February 2015
- January 2015
- December 2014
- November 2014
- October 2014
- September 2014
- August 2014
- July 2014
- June 2014
- May 2014
- April 2014
- March 2014
- February 2014
- January 2014
- December 2013
- November 2013
- October 2013
- September 2013
- August 2013
- July 2013
- June 2013
- May 2013
- April 2013
- March 2013
- February 2013
- January 2013
- December 2012
- November 2012
- October 2012
- September 2012
- August 2012
- July 2012
- June 2012
- May 2012
- April 2012
- March 2012
- February 2012
- January 2012
- December 2011
- November 2011
- October 2011
- September 2011
- August 2011
- July 2011
- June 2011
- May 2011
- April 2011
- March 2011
- February 2011
- January 2011
- December 2010
- November 2010
- October 2010
- September 2010
- August 2010
- July 2010
- June 2010
- May 2010
- April 2010
- March 2010
- February 2010
- January 2010
- December 2009
- November 2009
- October 2009
- September 2009
- August 2009
- July 2009
- June 2009
- May 2009
- April 2009
- March 2009
- February 2009
- January 2009
- December 2008
- November 2008
- October 2008
- September 2008
- August 2008
- July 2008
- June 2008
- May 2008
- April 2008
- March 2008
- February 2008
- January 2008
- December 2007
- November 2007
- October 2007
- September 2007
- August 2007
- June 2007
- February 2007
- January 2007
- October 2006
- April 2006
- January 2006
- April 2005
- December 2004
- November 2004
- December 1987
CATEGORIES
- About Us
- Advanced Biofuels Call to Action
- Aviation Fuel/Sustainable Aviation Fuel (SAF)
- BioChemicals/Renewable Chemicals
- BioRefineries/Renewable Fuel Production
- Business News/Analysis
- Cooking Fuel
- Education
- 30/30 Online Presentations
- Competitions, Contests
- Earth Day 2021
- Earth Day 2022
- Earth Day 2023
- Earth Day 2024
- Executive Training
- Featured Study Programs
- Instagram TikTok Short Videos
- Internships
- Just a Minute
- K-12 Activities
- Mechanics training
- Online Courses
- Podcasts
- Scholarships/Fellowships
- Teacher Resources
- Technical Training
- Technician Training
- University/College Programs
- Events
- Coming Events
- Completed Events
- More Coming Events
- Requests for Speakers, Presentations, Posters
- Requests for Speakers, Presentations, Posters Completed
- Webinars/Online
- Webinars/Online Completed; often available on-demand
- Federal Agency/Executive Branch
- Agency for International Development (USAID)
- Agriculture (USDA)
- Commerce Department
- Commodity Futures Trading Commission
- Congressional Budget Office
- Defense (DOD)
- Air Force
- Army
- DARPA (Defense Advance Research Projects Agency)
- Defense Logistics Agency
- Marines
- Navy
- Education Department
- Energy (DOE)
- Environmental Protection Agency
- Federal Energy Regulatory Commission (FERC)
- Federal Reserve System
- Federal Trade Commission
- Food and Drug Administration
- General Services Administration
- Government Accountability Office (GAO)
- Health and Human Services (HHS)
- Homeland Security
- Housing and Urban Development (HUD)
- Interior Department
- International Trade Commission
- Joint Office of Energy and Transportation
- Justice (DOJ)
- Labor Department
- National Academy of Sciences
- National Aeronautics and Space Administration
- National Oceanic and Atmospheric Administration
- National Research Council
- National Science Foundation
- National Transportation Safety Board (NTSB)
- Occupational Safety and Health Administration
- Overseas Private Investment Corporation
- Patent and Trademark Office
- Securities and Exchange Commission
- State Department
- Surface Transportation Board
- Transportation (DOT)
- Federal Aviation Administration
- National Highway Traffic Safety Administration (NHTSA)
- Pipeline and Hazardous Materials Safety Admin (PHMSA)
- Treasury Department
- U.S. Trade Representative (USTR)
- White House
- Federal Legislation
- Federal Litigation
- Federal Regulation
- Feedstocks
- Agriculture/Food Processing Residues nonfield crop
- Alcohol/Ethanol/Isobutanol
- Algae/Other Aquatic Organisms/Seaweed
- Atmosphere
- Carbon Dioxide (CO2)
- Field/Orchard/Plantation Crops/Residues
- Forestry/Wood/Residues/Waste
- hydrogen
- Manure
- Methane/Biogas
- methanol/bio-/renewable methanol
- Not Agriculture
- RFNBO (Renewable Fuels of Non-Biological Origin)
- Seawater
- Sugars
- water
- Funding/Financing/Investing
- grants
- Green Jobs
- Green Racing
- Health Concerns/Benefits
- Heating Oil/Fuel
- History of Advanced Biofuels
- Infrastructure
- Aggregation
- Biofuels Engine Design
- Biorefinery/Fuel Production Infrastructure
- Carbon Capture/Storage/Use
- certification
- Deliver Dispense
- Farming/Growing
- Precursors/Biointermediates
- Preprocessing
- Pretreatment
- Terminals Transport Pipelines
- International
- Abu Dhabi
- Afghanistan
- Africa
- Algeria
- Angola
- Antarctica
- Argentina
- Armenia
- Aruba
- Asia
- Asia Pacific
- Australia
- Austria
- Azerbaijan
- Bahamas
- Bahrain
- Bangladesh
- Barbados
- Belarus
- Belgium
- Beliz
- Benin
- Bermuda
- Bhutan
- Bolivia
- Bosnia and Herzegovina
- Botswana
- Brazil
- Brunei
- Bulgaria
- Burkina Faso
- Burundi
- Cambodia
- Cameroon
- Canada
- Caribbean
- Central African Republic
- Central America
- Chad
- Chile
- China
- Colombia
- Congo, Democratic Republic of
- Costa Rica
- Croatia
- Cuba
- Cyprus
- Czech Republic
- Denmark
- Dominican Republic
- Dubai
- Ecuador
- El Salvador
- Equatorial Guinea
- Eqypt
- Estonia
- Ethiopia
- European Union (EU)
- Fiji
- Finland
- France
- French Guiana
- Gabon
- Georgia
- Germany
- Ghana
- Global South
- Greece
- Greenland
- Guatemala
- Guinea
- Guyana
- Haiti
- Honduras
- Hong Kong
- Hungary
- Iceland
- India
- Indonesia
- Iran
- Iraq
- Ireland
- Israel
- Italy
- Ivory Coast
- Jamaica
- Japan
- Jersey
- Jordan
- Kazakhstan
- Kenya
- Korea
- Kosovo
- Kuwait
- Laos
- Latin America
- Latvia
- Lebanon
- Liberia
- Lithuania
- Luxembourg
- Macedonia
- Madagascar
- Malawi
- Malaysia
- Maldives
- Mali
- Malta
- Marshall Islands
- Mauritania
- Mauritius
- Mexico
- Middle East
- Monaco
- Morocco
- Mozambique
- Myanmar/Burma
- Namibia
- Nepal
- Netherlands
- New Guinea
- New Zealand
- Nicaragua
- Niger
- Nigeria
- North Africa
- North Korea
- Northern Ireland
- Norway
- Oman
- Pakistan
- Panama
- Papua New Guinea
- Paraguay
- Peru
- Philippines
- Poland
- Portugal
- Qatar
- Romania
- Russia
- Rwanda
- Saudi Arabia
- Scotland
- Senegal
- Serbia
- Sierra Leone
- Singapore
- Slovakia
- Slovenia
- Solomon Islands
- South Africa
- South America
- South Korea
- South Sudan
- Southeast Asia
- Spain
- Sri Lanka
- Sudan
- Suriname
- Swaziland
- Sweden
- Switzerland
- Taiwan
- Tanzania
- Thailand
- Timor-Leste
- Togo
- Trinidad and Tobago
- Tunisia
- Turkey
- Uganda
- UK (United Kingdom)
- Ukraine
- United Arab Emirates UAE
- Uruguay
- Uzbekistan
- Vatican
- Venezuela
- Vietnam
- Wales
- Zambia
- Zanzibar
- Zimbabwe
- Marine/Boat Bio and Renewable Fuel/MGO/MDO/SMF
- Marketing/Market Forces and Sales
- Opinions
- Organizations
- Original Writing, Opinions Advanced Biofuels USA
- Policy
- Presentations
- Biofuels Digest Conferences
- DOE Conferences
- Bioeconomy 2017
- Bioenergy2015
- Biomass2008
- Biomass2009
- Biomass2010
- Biomass2011
- Biomass2012
- Biomass2013
- Biomass2014
- DOE Project Peer Review
- Other Conferences/Events
- R & D Focus
- Carbon Capture/Storage/Use
- Co-Products
- Feedstock
- Logistics
- Performance
- Process
- Vehicle/Engine/Motor/Aircraft/Boiler
- Yeast
- Railroad/Train/Locomotive Fuel
- Resources
- Books Web Sites etc
- Business
- Definition of Advanced Biofuels
- Find Stuff
- Government Resources
- Scientific Resources
- Technical Resources
- Tools/Decision-Making
- Rocket/Missile Fuel
- Sponsors
- States
- Alabama
- Alaska
- Arizona
- Arkansas
- California
- Colorado
- Connecticut
- Delaware
- Florida
- Georgia
- Hawai'i
- Idaho
- Illinois
- Indiana
- Iowa
- Kansas
- Kentucky
- Louisiana
- Maine
- Maryland
- Massachusetts
- Michigan
- Midwest
- Minnesota
- Mississippi
- Missouri
- Montana
- Native American tribal nation lands
- Nebraska
- Nevada
- New Hampshire
- New Jersey
- New Mexico
- New York
- North Carolina
- North Dakota
- Ohio
- Oklahoma
- Oregon
- Pennsylvania
- Puerto Rico
- Rhode Island
- South Carolina
- South Dakota
- Tennessee
- Texas
- Utah
- Vermont
- Virginia
- Washington
- Washington DC
- West Coast
- West Virginia
- Wisconsin
- Wyoming
- Sustainability
- Uncategorized
- What You Can Do
tags
© 2008-2023 Copyright Advanced BioFuels USA. All Rights reserved.
Comments are closed.