RFA Welcomes 40B Sustainable Aviation Fuel Guidance, But Says Additional Work Needed

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April 30, 2024
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(Renewable Fuels Association) The 40B tax credit guidance and modified GREET model released today by U.S. Treasury begin to unlock the door for U.S. ethanol producers and farmers to participate in the emerging market for sustainable aviation fuels (SAF). However, more work must be done to fully open the SAF market to ethanol and properly recognize the climate benefits of modern agriculture and biofuels, according to the Renewable Fuels Association.

“Today’s guidance and modified GREET model help position ethanol-based SAF for takeoff, but more work is needed to fully clear the runway and get this opportunity off the ground,” said RFA President and CEO Geoff Cooper. “We are encouraged that, for the first time ever, this carbon scoring framework will recognize and credit certain climate-smart agricultural practices. We’re also pleased to see the integration of other carbon reduction strategies—like renewable process energy and carbon capture and sequestration—into the model. However, RFA believes less prescription on ag practices, more flexibility, and additional low-carbon technologies and practices should be added to the modeling framework to better reflect the innovation occurring throughout the supply chain.”

Cooper noted that today’s 40B package sets the stage for a more expansive and flexible modeling approach under the 45Z clean fuel production tax credit. RFA expects the Biden administration will soon request public comment on considerations and options for implementing the 45Z credit.

“We view today’s 40B announcement as the starting point—not the ending point—for additional modeling improvements, further integration of individual climate-smart agriculture practices, and emerging biorefinery technologies,” Cooper said. “45Z is where the rubber really meets the road. We look forward to working with USDA and other agencies across the administration to ensure 45Z is implemented in a way that truly swings the door wide open for farmers and ethanol producers to participate in the enormous decarbonization opportunity.”

The conversion of ethanol to jet fuel is one of the most promising forms of SAF, Cooper said. Low-carbon ethanol has key advantages as a feedstock for SAF, as it is cost-competitive with petroleum-based fuels, has established production and transportation infrastructure, and is by far the largest-volume biofuel produced in the United States, with output of nearly 16 billion gallons per year.

“We are especially grateful for the role that U.S. Agriculture Sec. Tom Vilsack and his team played in the effort,” Cooper concluded. “Sec. Vilsack has time and again demonstrated his commitment to serving rural communities, and understands the importance of lower-carbon, American-made renewable fuels.”

A History of Action

RFA has worked diligently with lawmakers and others over the past several years to ensure ethanol can participate in SAF opportunities. RFA’s efforts on the SAF tax credit began long before the Inflation Reduction Act was introduced, including correspondence with congressional tax-writing committees in August 2021 and a joint industry letter in April 2022. More recently:

  • In February 2023, RFA filed extensive comments urging the allowance of GREET modeling for the sake of the SAF tax credits. In June and July, the organization welcomed the introduction of the Sustainable Aviation Fuels Accuracy Act in both houses of Congress.
  • In August, at the RealClear Energy website, Cooper wrote about how farmers and ethanol producers can put “the S in SAF.” And in an August blog post, he pointed out how the SAF modeling debate isn’t really about GREET vs. ICAO, but about “current data vs. old data.” Click here for a chart RFA has developed to explain the key differences between the DOE GREET approach and the ICAO approach.
  • In November, many RFA member companies signed on to a historic coalition letter that included major airlines, calling on the Biden administration to integrate the best available science and data regarding the carbon impacts of SAF into the tax credit program.
  • RFA also endorsed the Farm to Fly Act in November, which would affirm a common definition of SAF for USDA purposes, as widely supported by industry and congressional leaders to enable U.S. crops to most effectively contribute to aviation renewable fuels via renewable fuels like ethanol. A Senate version was introduced in January.
  • In January, RFA offered specific recommendations for ensuring that the best available science and data are used in determining eligibility for the SAF tax credit established in the Inflation Reduction Act. 
  • In February, a bipartisan group of 43 lawmakers in both houses of Congress sent a letter to the Interagency Working Group, asking it to meet the March 1 deadline for updates to the GREET model and ensure the updates are based on sound science, current data, and methodologies that properly recognize modern practices in agriculture and biofuel production.
  • When the March 1 deadline passed, RFA called on the working group to move quickly, noting that it was important to get the modeling right. Later that month, RFA was part of a coalition of biofuel and farm advocates that called on the Treasury Department to swiftly resolve any questions standing in the way of efforts to scale up U.S. production of sustainable aviation fuel.
  • Just last week—on April 24—RFA was part of another major coalition that called on agriculture committee leaders in Congress to boost the role of American farms in fueling low-carbon aviation by including meaningful SAF provisions, such as the Farm to Fly Act, into the farm bill.
  • Finally, RFA is a founding member of the SAF Coalition, which launched Monday to accelerate the development and deployment of sustainable aviation fuel in the United States.  READ MORE

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Excerpts from U.S. Treasury Department: Biden-Harris Administration Partners Announce Updated GREET Model to Measure Lifecycle Emissions from Sustainable Aviation Fuels 

WASHINGTON – Today the U.S. Department of the Treasury and Internal Revenue Service (IRS) released guidance on the Sustainable Aviation Fuel (SAF) Credit established by the Inflation Reduction Act (IRA), part of President Biden’s Investing in America agenda to create good-paying jobs and reduce climate pollution by spurring innovation in the aviation industry.  

The Treasury Department worked closely with Biden-Harris Administration partners, including the Environmental Protection Agency (EPA), Department of Transportation (DOT), Department of Agriculture (USDA), and Department of Energy (DOE) on today’s Notice.  

“President Biden’s Inflation Reduction Act is driving American innovation to create good-paying jobs and help the U.S. clear hurdles in our clean energy transition,” said U.S. Secretary of the Treasury Janet L. Yellen. “Incentives in the law are helping to scale production of low-carbon fuels and cut emissions from the aviation sector, one of the most difficult-to-transition sectors of our economy. Today’s guidance provides additional clarity and certainty to companies and producers.”

“Sustainable aviation fuel is a key part of the Biden-Harris Administration's efforts to transition the American economy to a clean energy future and rebuild the middle class from the bottom up to the middle out in rural America,” said U.S. Secretary of Agriculture Tom Vilsack. “Today’s announcement is an important stepping stone as it acknowledges the important role farmers can play in lowering greenhouse gas emissions and begins to reward them through that contribution in the production of new fuels. This is a great beginning as we develop new markets for sustainable aviation fuel that use home grown agricultural crops produced using climate smart agricultural practices. USDA will continue to work with our federal agency partners to expand opportunities in the future for climate smart agriculture in producing sustainable aviation fuel.”

“The guidance released today reflects the latest data and science needed to help create new economic opportunities for America's agricultural sector,” said U.S. Secretary of Energy Jennifer M. Granholm. “This interagency effort will help our climate goals take flight with cheaper, cleaner sustainable aviation fuel -- ensuring America maintains an innovative edge on the global clean technology stage.”

“Innovation in the aviation sector has brought our country and our world together and now, it’s fueling the solution to meet our ambitious net-zero carbon emission goals,” said U.S. Secretary of Transportation Pete Buttigieg. “Today’s announcement will strengthen America’s position as a leader in the production of sustainable aviation fuels, help cut carbon emissions, and create a better future for all Americans.”

“The Inflation Reduction Act’s tax credit for sustainable aviation fuels is a critical tool for decarbonizing air travel,” said John Podesta, Senior Advisor to the President for International Climate Policy. “Today’s announcement of an updated GREET model and Treasury guidance is a big step forward for American farmers, for American innovation, for American jobs, and for America’s ability to cut carbon pollution from our transportation sector and protect our planet.”

The Treasury Department’s guidance provides important clarity around eligibility for the SAF Credit. The credit incentivizes the production of SAF that achieves a lifecycle greenhouse gas emissions reduction of at least 50% as compared with petroleum-based jet fuel. Producers of SAF are eligible for a tax credit of $1.25 to $1.75 per gallon. SAF that achieves a GHG emissions reduction of 50% is eligible for the $1.25 credit per gallon amount, and SAF that achieves a GHG emissions reduction of more than 50% is eligible for an additional $0.01 per gallon for each percentage point the reduction exceeds 50%, up to $0.50 per gallon. 

As part of today’s guidance, the agencies comprising the SAF Interagency Working Group (IWG) are jointly announcing the 40B SAF-GREET 2024 model. This model provides another methodology for SAF producers to determine the lifecycle GHG emissions rates of their production for the purposes of the SAF Credit.

The modified version of GREET incorporates new data, including updated modeling of key feedstocks and processes used in aviation fuel and indirect emissions. The modified GREET model also integrates key greenhouse gas emission reduction strategies such as carbon capture and storage, renewable natural gas, and renewable electricity.

The Notice released today also, on a pilot basis, incorporates a USDA pilot program to encourage the use of certain Climate Smart Agriculture (CSA) practices for SAF feedstocks. Incorporating CSA practices into the production of SAF provides multiple benefits, including lower overall GHG emissions associated with SAF production and increased adoption of farming practices that are associated with other environmental benefits, such as improved water quality and soil health. 

For corn ethanol-to-jet, the pilot provides a greenhouse gas reduction credit if a “bundle” of certain CSA practices (no-till, cover crop, and enhanced efficiency fertilizer) are used. It similarly would allow a greenhouse gas reduction credit for soybean-to-jet if the soybean feedstock is produced using a “bundle” of applicable CSA practices (no-till and cover crop). This is a pilot program specific to the 40B credit, which is in effect for 2023 and 2024.

To credit CSA practices in the Clean Fuel Production Credit (45Z), which becomes available in 2025, the agencies will do further work on modeling, data, and assumptions, as well as verification. A new 45Z-GREET will be developed for use with the 45Z tax credit.  READ MORE

 

Excerpt from The Fence Post: The National Oilseed Processors Association President and CEO Kailee Tkacz Buller had a mixed reaction.

“Acknowledging, for the first time, the carbon benefits that climate-smart agriculture practices can deliver is a significant step to ramping up SAF production and NOPA is pleased to see the updated GREET model recognize the positive environmental impact of U.S.-produced biofuels.

“However, we are concerned the requirement to implement climate-smart ag practices simultaneously will limit this opportunity, particularly in parts of the country where it may not be possible to plant a cover crop or the cost to implement new practices is too steep.

“We look forward to further reviewing today’s announcement and having a continued dialogue with the administration to better understand what this and other provisions, including indirect land use change impact, mean for the industry and how we can competitively and efficiently meet the needs of the SAF market,” Tkacz Buller said.

But Rep. Angie Craig, D-Minn., who is in a competitive race for re-election, said, she wasn’t satisfied with the guidance. “The new and emerging SAF market offers tremendous growth opportunities for Minnesota’s farmers and biofuel producers, including the ones in my district — farmers the administration has committed to supporting,” Craig said. “Today’s guidelines do the opposite — in fact, this announcement will significantly hinder farmers and producers’ ability to participate in the SAF market.”

“These guidelines fail to support the Minnesota farmers I represent, and they stifle the emerging SAF industry that creates a once-in-a-lifetime opportunity for airlines to meet their carbon reduction goals,” Craig said.

“I urge the Biden administration to rework these guidelines to make sure they support the ag communities that work so hard to feed and fuel our nation.”

On a call to reporters Monday that was embargoed until 4 p.m. today, John Podesta, President Biden’s senior adviser for clean energy innovation and implementation, said “aviation is hard to decarbonize,” but that it must be decarbonized.

The Treasury Department is in charge of tax regulations and the Energy Department is expected to announce an update of the GREET model.

GREET (Greenhouse gases, Regulated Emissions, and Energy use in Technologies) life-cycle analysis (LCA) is used to determine what growing conditions and production methods will have to be used for biofuels to be eligible for the credits.Agriculture Secretary Tom Vilsack said on the call that “the guidance is going to provide a clear pathway” on how to best qualify for:

▪ The 40B tax credit, a refundable blenders tax credit for each gallon of sustainable aviation fuel (SAF) sold or used after Dec. 31, 2022, and before Jan. 1, 2025, as part of a qualified fuel mixture, and

▪ The 45Z Clean Fuels Production Credit, which is designed to encourage the production of clean transportation fuels, with a focus on reducing greenhouse gas (GHG) emissions for qualifying transportation fuels produced after 2024 and sold on or before December 31, 2027.

Vilsack said the program will recognize “climate smart practices” and that farmers who use those practices won’t be audited or face penalties.

A USDA official said modeling supports the conclusion that producers will benefit from the program, but that data on how many producers will benefit is unclear.  READ MORE

 

Excerpt from Biofuels Digest: The modified version of GREET incorporates new data, including updated modeling of key feedstocks and processes used in aviation fuel and indirect emissions. The modified GREET model also integrates key greenhouse gas emission reduction strategies such as carbon capture and storage, renewable natural gas, and renewable electricity.

The Notice, on a pilot basis, incorporates a USDA pilot program to encourage the use of certain Climate Smart Agriculture practices for SAF feedstocks. Incorporating CSA practices into the production of SAF provides multiple benefits, including lower overall GHG emissions associated with SAF production and increased adoption of farming practices that are associated with other environmental benefits, such as improved water quality and soil health.  For corn ethanol-to-jet, the pilot provides a greenhouse gas reduction credit if a “bundle” of certain CSA practices (no-till, cover crop, and enhanced efficiency fertilizer) are used. It similarly would allow a greenhouse gas reduction credit for soybean-to-jet if the soybean feedstock is produced using a “bundle” of applicable CSA practices (no-till and cover crop). This is a pilot program specific to the 40B credit, which is in effect for 2023 and 2024. To credit CSA practices in the Clean Fuel Production Credit (45Z), which becomes available in 2025, the agencies will do further work on modeling, data, and assumptions, as well as verification. A new 45Z-GREET will be developed for use with the 45Z tax credit.

Reaction from industry and The Hill

Industry and farm sector reaction oscillated from weak-positive to sharp-negative.

Sen. Chuck Grassley (R-Iowa) said, “THere are two main issues with the Biden administration’s GREET Model decision: First, this new formula is going to be easy to violate. Second, without grain in the formula, there won’t be enough feedstock to make all the Sustainable Aviation Fuel environmentalists are crying for. To put it bluntly, this GREET Model update is a stupid approach. Widespread use of Sustainable Aviation Fuel will help fight global warming. But rejecting grain feedstocks will impede efforts to produce that fuel on a commercial scale.“

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The Bottom Line

Well, you can measure the width of the window to meet the SAF Grand Challenge in micrometers, now, possibly nanometers, possibly the width of a quantum tunnel. Nevertheless, it’s progress, and good news for fans of GREET to see it finally enshrined in US tax policy. Been a long journey for GREET. Good to see it grow from a concept to an internatinoal standard of great renown. Deservedly so.   READ MORE

 

Excerpt from Clean Fuels Alliance America: Clean Fuels urges USDA and Treasury to further update the GREET model to include additional climate smart agriculture practices specific to oilseed crops and quickly finalize rules for the 2025-2027 tax incentives (§45Z Clean Fuel Production Credit), which will support U.S. biodiesel, renewable diesel, and SAF producers.

“Clean Fuels and its members appreciate the significant work of USDA and other federal agencies to account for the role that U.S. farmers will play in decarbonizing the nation’s aviation fuel,” said Kurt Kovarik, Vice President of Federal Affairs for Clean Fuels. “U.S. farmers and SAF producers will continue to work with the agencies to rapidly expand SAF production over the next few years.”

Clean Fuels continues to assess the changes to the GREET model unveiled today, including updated indirect emission penalties for U.S. oilseed crops like soy and canola. Clean Fuels believes there is more work to be done to enable credit for climate smart agriculture practices that U.S. farmers are deploying.

“Biodiesel, renewable diesel, and SAF producers are already negotiating feedstock and fuel offtake contracts for 2025, so we look forward to working with Treasury and USDA to quickly turn attention to guidance for the Clean Fuel Production Credit that begins on January 1 next year.” Kovarik added. “We believe there are additional climate smart agriculture practices and industry data that can be incorporated in the GREET model to support the continued sustainable growth of the entire clean fuel industry.” READ MORE

 

Excerpt from Associated Press: Skeptics worry that a large share of the tax credits will go to ethanol and other biofuels instead of emerging cleaner fuels.

“The science matters and we are concerned this decision may have missed the mark, but we are carefully reviewing the details before reaching any final conclusions,” said Mark Brownstein, a senior vice president for the Environmental Defense Fund.

While aviation’s share of carbon emissions is small, it is growing faster than any other industry because the technology of powering planes by electricity is far behind the adoption of electric vehicles on the ground.

In 2021, President Joe Biden set a goal set a goal of reducing aviation emissions 20% by 2030 as a step toward “net-zero emissions” by 2050. Those targets are seen as highly ambitious — and maybe unrealistic.

Major airlines have invested in SAF, and its use has grown rapidly in the last few years. Still, it accounted for just 15.8 million gallons in 2022 — or less than 0.1% of all the fuel burned by major U.S. airlines. The White House wants production of 3 billion gallons a year by 2030. READ MORE

 

Excerpt from New York Times: President Biden’s 2022 Inflation Reduction Act offered federal tax credits for sustainable aviation fuels, industry jargon for jet fuel made without fossil fuels, that cut greenhouse gas emissions by at least 50 percent. For months now, federal officials have been evaluating research to decide how to measure whether various biofuel-based alternatives meet that standard.

Sustainable aviation fuel is already occasionally blended into traditional jet fuel, albeit at small, single-digit percentages. That scale is well below the government’s target of 3 billion gallons per year by 2030. Currently, most of it is made out of used cooking oil, and it costs two to four times as much as jet fuel.

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Biden Administration officials introduced a new pilot program for corn ethanol to be used as jet fuel that could qualify for tax credits if certain climate-friendly farming practices were used in combination. They include no-till farming, which minimizes erosion, and covering the soil with crops that leave behind organic matter in the dirt. The program sets out similar guidelines for soy.

The new formula for claiming the tax credits — which spans 40 pages, is highly technical and must still be finalized — would also consider whether producers use carbon capture and storage, low-emissions natural gas, and renewable electricity in their processes.

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The powerful corn and ethanol industries had been watching the Biden administration’s announcement closely to understand just how much corn farmers and ethanol producers would have to adapt, and how much detailed record-keeping would be required, to take advantage of the tax credits.

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“We of course understand there will be a level of stringency needed,” said Geoff Cooper, president of the Renewable Fuels Association, a leading ethanol lobby group. “It’s a balancing act. And there is no way the U.S. produces 3 billion gallons by 2030 unless corn ethanol is part of that picture.”

While the United States has set ambitious targets for production, building a supply chain will take years. Not one large-scale sustainable aviation fuel plant exists in the United States yet. The Biden administration’s stated goal is to grow production rapidly so it can satisfy all domestic jet fuel demand by 2050.

Europe is at least slightly ahead. The European Union is set to introduce a blending mandate requiring airports to supply jet fuel at 2 percent blends from 2025.

Ethanol producers are looking for a new outlet for their product as electric-vehicle usage cuts into gasoline demand. And with national elections in the United States set for November, politicians can benefit from broadening incentives that are politically popular in Corn Belt states.

On Monday, major airlines including American, Alaska, Hawaiian, JetBlue and United announced a partnership with dozens of other organizations including agricultural enterprises, aircraft makers, airports, labor unions and biofuel producers that aims to scale up sustainable aviation fuel production. The group “believes in the importance of ethanol as a tool to help our industry decarbonize,” said Lauren Riley, the chief sustainability officer at United Airlines.  READ MORE

 

Excerpt from Reuters: Bill Hohenstein, director of USDA's Office of Energy and Environmental Policy, said the administration is confident in the plan. “We do have robust data, analysis, information and modeling that all supports the conclusions that these practices do have greenhouse gas benefits," he said. READ MORE

 

Excerpt from Brownfield Ag News: The U.S. Secretary of Agriculture says updates to a model that measures the carbon footprint for sustainable aviation fuel should allow U.S. agriculture to participate in the sustainable aviation fuel market.

Secretary Tom Vilsack says the updated Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies or GREET model might not be enough by itself to allow renewable fuel producers to qualify for a new tax credit, but using climate-smart ag practices could help.  He says, “Agriculture’s foot is in the door; we’re in the game.”

“If you’re producing ethanol, you can use the GREET model, and maybe you use renewable energy, and you use climate-smart agriculture, and you do something else,” he says. “Maybe you ultimately get to less than less than 50 for your CI score, and that qualifies for the tax credit.”

...

Vilsack also says an interagency working group will continue working on another tax credit included in the Inflation Reduction Act called 45z, which supports the production of low-carbon biofuels. He says there are a few questions that need to be answered in the next few months.  “What other commodities besides corn and soybeans ought to qualify,” he says.  “And what other practices beyond no-till, cover crop, and energy-efficient fertilizer should qualify.”  READ MORE

 

Excerpt from Ethanol Producer Magazine: Language included in the IRA specifies that the GHG reduction threshold can be calculated using the most recent Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) model that has been adopted by the International Civic Aviation Organization, or by a “similar methodology” to the most recent CORSIA model. The use of the European-based CORSIA model has been criticized by the U.S. agriculture and biofuel industries for failing to accurately account for U.S. agricultural practices and preventing crop-based fuels from participating in the SAF market.

The Treasury Department and IRS on Dec. 15, 2023, released initial guidance on the SAF tax credit, announcing that taxpayers will be able to use an updated version of the U.S. Department of Energy’s Greenhouse Gases, Regulated Emissions and Energy Use in Transportation (GREET) model to calculate lifecycle GHG reductions for the purposes of the SAF tax credit. 

As part of that guidance, the U.S. EPA, U.S. Department of Transportation, USDA and DOE announced the formation of the SAF Interagency Working Group to support the development of the updated GREET model, referred to as 40BSAF-GREET. The working group committed to release that updated model by March 1, 2024. 

The agencies failed to meet that self-imposed deadline. Agriculture Secretary Tom Vilsack on March 1 announced a short-term delay in the release of 40BSAF-GREET, citing the need to get calculations for climate-smart agriculture right. 

The updated guidance issued April 30 provides clarity around eligibility for the SAF credit, including release of the 40BSAF-GREET 2024 model.

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Within the notice, the IRS also provides a safe harbor provision that can ultimately allow a SAF synthetic blending component produced from CSA corn or CSA soybean to be eligible for an additional proxy reduction (CSA reduction) in the calculation of the emissions reduction percentage. The notice includes specific equations for calculating this emissions reduction percentage, and offers an example of a registered SAF producer that produces a SAF synthetic blending component via the ethanol-to-jet production pathway using 100% CSA corn, indicating the resulting fuel would achieve a 53% GHG reduction.

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The American Coalition for Ethanol applauded the guidance’s treatment of CSA and called the guidance a step in the right direction. “The Biden Administration is providing an important tailwind for corn ethanol produced with no-till, cover crops and enhanced efficiency fertilizers to qualify as a feedstock for SAF under 40B so long as all three of these climate-smart agriculture practices (CSA) are adopted,” said Brian  Jennings, CEO of ACE. “This marks the first time a regulatory body has formally acknowledged the role CSA practices play in reducing corn ethanol’s GHG emissions, in this case enabling some ethanol-to-jet to qualify for the 40B credit.

“The United States Departments of Agriculture (USDA) and Energy (DoE) deserve praise for diligently ensuring this first step is being taken with respect to CSA practices,” Jennings continued. “ACE is particularly grateful to U.S. Secretary of Agriculture Vilsack for successfully advocating that corn ethanol is part of the solution to fulfill the Biden Administration SAF goals and for his leadership on CSA pathways for corn ethanol under the new 45Z credit.

“While today’s announcement is a step in the right direction, ethanol-to-jet continues to face headwinds such as artificially inflated land use change (LUC) penalties in 40B GREET and the initial all or none requirement to bundle three CSA practices in order to produce qualifying corn ethanol feedstock for SAF.

“With the 2024 planting season underway and the expiration of the 40B credit on December 31, 2024, Treasury’s SAF guidance speaks more to the Administration codifying the important role CSA practices play in decarbonizing liquid fuels than the amount of ethanol-to-jet that will qualify for the 40B credit,” Jennings added. “Today’s announcement provides ACE a roadmap for how to prevent the conditions placed on CSA practices in 40B from being applied as 45Z is implemented. Ultimately, we need to enable farmers and ethanol companies to recoup value from these tax credits for their investments to reduce GHG emissions.

The Advanced Biofuels Association is applauding the flexibility on SAF through the new modeling. “The Advanced Biofuels Association applauds the Treasury Department and IRS for their decision to offer increased modeling flexibility for measuring the carbon intensity of sustainable aviation fuel (SAF),” said Michael McAdams, president of the ABFA. “This move will facilitate greater production of SAF and pave the way for its widespread adoption. We look forward to continued and unequivocal support from the federal government for sustainable, low-carbon aviation fuels.

“The Biden administration set the ambitious goal of supplying at least 3 billion gallons of SAF per year by 2030 and the aviation industry intends to reach net zero emissions by 2050,” he added. “To help meet these goals ABFA has long fought to extend advanced biofuels credits and to increase the Renewable Fuel Standard. These deadlines are fast approaching, and ABFA’s members stand ready to meet this challenge with the support of effective federal policy. The flexible modeling approach provided in today’s 40B rule greatly increases the likelihood of meeting these targets.

“Later this year, the administration will have another opportunity to further boost advanced biofuel production when it establishes the model for qualifying fuels under the Clean Fuel Production Credit, or 45Z,” McAdams continued. “We hope that regulators will craft this rule transparently and in consultation with industry partners to achieve emissions reduction goals alongside economic outcomes.”

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Additional information, including a full copy of the IRS guidance, is available on the Department of Treasury website.      READ MORE

 

Excerpt from DTN Progressive Farmer: Politicians from both parties searched for the right verb to express their hostility without fully explaining why they felt they should "slam" or "condemn" the tax-credit guidance.

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Josh Gackle, North Dakota farmer and president of the American Soybean Association (ASA), said the guidance "goes sideways for soy" by requiring soybeans going into a jet fuel to be grown using no-till and cover crops. Gackle said ASA was supportive that climate-smart practices were being used to lower carbon-intensity scores, but cover crops aren't feasible in every region soybeans are grown.

"For growers like me here in North Dakota, short growing seasons and unpredictable fall weather make the cover crop requirement alone next to impossible," Gackle said. "Growers in the Northern Plains do so when possible. However, employing both no-till and cover cropping is contrary to what Mother Nature will allow, no matter what the guidance specifies."

While there are concerns about who qualifies, the states that have the highest production of ethanol and biodiesel also are the states that have some of the highest planting of cover crops. Farmers grew just under 18 million acres of cover crops in 2022, according to the USDA Ag Census released earlier this year. Among ethanol-producing states, eight of the top states for cover crops nationally also were among the top ten states for ethanol production. The top five states for biodiesel production are among the top ten states for cover crops as well.

Not everyone had major issues with cover crops.

Michael McAdams, president of the Advanced Biofuels Association, noted the Treasury guidance provides more flexibility for measuring carbon intensity. Pointing to the Biden administration's goal of producing 3 billion gallons of SAF a year by 2030, the 40B rule "greatly increases the likelihood of meeting these targets," McAdams said.

"This move will facilitate greater production of SAF and pave the way for its widespread adoption," he said.

On the flip side, the Environmental Defense Fund questioned the "scientific rigor" of the Treasury guidance for accepting climate-smart farming practices without any specific measurement or verification.

"Today's actions highlight that significant questions remain as to whether and how to credit certain beneficial agricultural practices in the context of implementing the 40B sustainable aviation fuel tax credit," said Mark Brownstein, senior vice president of energy transition, Environmental Defense Fund. "The science matters and we are concerned this decision may have missed the mark, but we are carefully reviewing the details before reaching any final conclusions."

The bottom line? To decarbonize aviation, U.S. airlines need a volume of alternative fuels that sustainable biomass alone cannot meet.

Some lawmakers in both parties also bristled. Sen. Chuck Grassley, R-Iowa, "condemned" the guidance. Rep. Angie Craig, D-Minn., "slammed" it. Sen. Joni Ernst, R-Iowa, called out the administration for "picking winners and losers."  READ MORE

 

Excerpt from AgNewsWire: Iowa farmer and consultant Mitchell Hora, Continuum Ag, spent some time Wednesday morning breaking down the 40B sustainable aviation fuel (SAF) tax credit guidance released this week for farmers hoping to be eligible.

There were over 400 farmers and other stakeholders on Hora’s webinar which ran for an hour and still was not able to address all the questions. Continuum Ag has its TopSoil® Summit coming up June 3 in Riverside, Iowa which will be focused on Carbon Intensity to help prepare for the SAF tax credits. Continuum recently introduced CI Certification as a product for farmers to earn premiums for producing lower carbon intensity grain while ensuring secure data control.

Listen to Hora’s summary of the 40B SAF tax credit guidance:
PlayMitchell Hora, Continuum Ag 12:53  READ MORE

 

Excerpt from Fence Post: Sen. Sherrod Brown, D-Ohio, said, “Unfortunately the guidance released by Treasury this week misses the mark and falls well short of the goal of jumpstarting this new homegrown industry. The Treasury Department must move quickly to release a robust and flexible rule for the 45Z Clean Fuels Production Credit that fixes the problems with the guidance released this week and lives up to the goals of the Inflation Reduction Act.”

National Farmers Union President Rob Larew said, “While we appreciate the administration modifying the GREET model and issuing guidance on the 40B tax credit, more work is needed to better recognize and credit certain climate-smart agriculture practices to reduce greenhouse gas emissions in SAF production. As the administration works on the next set of guidance for Section 45Z, the Clean Fuels Tax Credit, a wider variety of climate-smart agriculture practices must be included to achieve our nation’s climate goals.”

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National Corn Growers Association President Harold Wolle, a Minnesota farmer, said, “We are deeply disappointed that this updated model requires farmers to implement environmental practices that are not practical for all acres of the large and varied geographic region in which corn is grown. This requirement in GREET will significantly hinder the chances corn growers have in accessing the sustainable aviation fuel market, even as higher blends of corn ethanol offer great promise in the country’s fight against greenhouse gas emissions and climate change.”

Wolle said cover crops “can be difficult, if not impossible, to grow in drier climates, making the bundling requirement extremely unreasonable.” He also noted that growers should be able to implement their own environmental practices.

Wolle noted that the Inflation Reduction Act, passed in 2022, allocates tax credits for biofuels that can demonstrate that they cut greenhouse gas emissions by 50% or more. After the law was passed, Treasury and EPA were charged with choosing a model that would measure emissions throughout the life of biofuels.

Wolle said NCGA and corn growers across the country will increase their advocacy efforts to improve the changes Treasury made to the GREET model as the Biden administration focuses on the next phase of the Inflation Reduction Act for passenger vehicles, referred to as the 45Z tax credit. The 45Z tax credit will take effect at the beginning of 2025. As part of the law, the aviation tax credit will be folded into the 45Z tax credit beginning on January 1, 2025.

The American Soybean Association said the Treasury Department guidance first recognized soy as an eligible sustainable aviation fuel (SAF) feedstock in initial guidance last December and now “goes a step further to sweeten the value for soy” because “it provides a second pathway for soybean oil-based SAF to qualify for the SAF tax credit (40B) and assigns the feedstock a better carbon intensity (CI) reduction score.”

But ASA added, “Where the guidance from Treasury goes sideways for soy, however, is that for soybean oil to qualify through this new pathway, the soybeans must be grown using both no-till and cover cropping. ASA is very supportive of using climate-smart agriculture practices to improve CI reductions, but specifying only two practices out of a variety of sustainability measures will further restrict soybean oil use as a SAF feedstock. Adding to concerns, no-till and cover cropping are feasible only for soybean farmers in certain parts of the soy growing region, which means regional disparity is likely.”

ASA President Josh Gackle, a grower from Kulm, N.D., said, “For growers like me here in North Dakota, short growing seasons and unpredictable fall weather make the cover crop requirement alone next to impossible. Growers in the Northern Plains do so when possible. However, employing both no-till and cover cropping is contrary to what Mother Nature will allow, no matter what the guidance specifies.”

Patrick Gruber, CEO of Gevo, an Englewood, Colo.-based company, said, “We look forward to sharing key insights from anonymized data to inform the administration’s upcoming 45Z SAF tax credit guidance.”

Gruber said Gevo’s wholly owned subsidiary, Verity, uses distributed ledger technology to facilitate accurate accounting of emission reduction efforts from on-farm practices, including on a field-level basis.

A New York Times analysis focused on broader questions surrounding sustainable aviation fuel.  READ MORE

 

Excerpt from Brownfield Ag News: A Senate Ag Committee member is asking for modeling used to measure transportation emissions for sustainable aviation fuel to be reevaluated.

During a Senate Appropriations Committee hearing Wednesday, Nebraska Republican Deb Fischer raised concerns that American corn and soybean biofuels could be at a disadvantage to imports with the new model.

“With this updated modeling, corn and soy-based biofuels, even if they complete the additional conservation practices, would still be deemed more carbon intensive than Brazilian sugar cane ethanol,” she said.

Environmental Protection Agency Administrator Michael Regan said his department’s role in the interagency task force that released the updates was to ensure all farmers had options to comply with the Clean Air Act.

“I think the design of conservation programs and tax policy well, those questions are probably better steered to USDA or Treasury,” he countered. “I’m not an architect of how those programs work.”

Fischer said the model has the potential to use taxpayer dollars to incentivize importing foreign fuel.

Regan disagreed, saying the updates allow farmers to compete in the sustainable aviation fuel global marketplace.  READ MORE

 

Excerpt from MIT Technology Review: Consequently, the so-called Climate Smart Agricultural program has already sounded alarm bells among some observers, who fear that the federal government is both overestimating the emissions benefits of ethanol and assigning too much credit to the agricultural practices in question. Those include cover crops, no-till techniques that minimize soil disturbances, and use of “enhanced-efficiency fertilizers,” which are designed to increase uptake by plants and thus reduce runoff into the environment.

...

Since the vast majority of US ethanol is produced from corn, let’s focus on the issues around that crop. To get technical, the program allows ethanol producers to subtract 10 grams of carbon dioxide per megajoule of energy, a measure of carbon intensity, from the life-cycle emissions of the fuel when it’s generated from corn produced with all three of the practices mentioned. That’s about an eighth to a tenth of the carbon intensity of gasoline.

...

Corn, like any plant that uses photosynthesis to produce food, sucks up carbon dioxide from the air. But using corn for fuel rather than food also creates pressure to clear more land for farming, a process that releases carbon dioxide from plants and soil. In addition, planting, fertilizing, and harvesting corn produce climate pollution as well, and the same is true of refining, distributing, and burning ethanol. 

For its analyses under the new program, the Treasury Department intends to use an updated version of the so-called GREET model to evaluate the life-cycle emissions of SAFs, which was developed by the Department of Energy’s Argonne National Lab. A 2021 study from the lab, relying on that model, concluded that US corn ethanol produced as much as 52% less greenhouse gas than gasoline. 

But some researchers and nonprofits have criticized the tool for accepting low estimates of the emissions impacts of land-use changes, among other issues. 

...

Nikita Pavlenko, who leads the fuels team at the International Council on Clean Transportation, a nonprofit research group, asserted in an email that the climate-smart agricultural provisions “are extremely sloppy” and “are not substantiated.” 

He said the Department of Energy and Department of Agriculture especially “put their thumbs on the scale” on the question of land-use changes, using estimates of soy and corn emissions that were 33% to 55% lower than those produced for a program associated with the UN’s International Civil Aviation Organization.

He finds that ethanol sourced from farms using these agriculture practices will still come up short of the IRA’s 50% threshold, and that producers may have to take additional steps to curtail emissions, potentially including adding carbon capture and storage to ethanol facilities or running operations on renewables like wind or solar.

...

Freya Chay, a program lead at CarbonPlan, which evaluates the scientific integrity of carbon removal methods and other climate actions, says that these sorts of agricultural practices can provide important benefits, including improving soil health, reducing erosion, and lowering the cost of farming. But she and others have stressed that confidently determining when certain practices actually and durably increase carbon in soil is “exceedingly complex” and varies widely depending on soil type, local climate conditions, past practices, and other variables.

One recent study of no-till practices found that the carbon benefits quickly fade away over time and reach nearly zero in 14 years. If so, this technique would do little to help counter carbon emissions from fuel combustion, which can persist in the atmosphere for centuries or more.

...

There are many other paths for producing SAFs that are or could be less polluting than ethanol. For example, they can be made from animal fats, agriculture waste, forest trimmings, or non-food plants that grow on land unsuitable for commercial crops. Other companies are developing various types of synthetic fuels, including electrofuels produced by capturing carbon from plants or the air and then combining it with cleanly sourced hydrogen. 

But all these methods are much more expensive than extracting and refining fossil fuels, and most of the alternative fuels will still produce more emissions when they’re used than the amount that was pulled out of the atmosphere by the plants or processes in the first place. 

The best way to think of these fuels is arguably as a stopgap, a possible way to make some climate progress while smart people strive to develop and build fully emissions-free ways of quickly, safely, and reliably moving things and people around the globe.  READ MORE

 

Excerpt from AgWeb: The new guidance includes the release of the now called 40BSAF-GREET 2024 model, designed to calculate these GHG reductions more accurately, incorporating new data and methodologies including climate-smart agricultural practices for soybeans and corn as a feedstock for SAF. GREET stands for Greenhouse gases, Regulated Emissions, and Energy use in Technologies. 

EPA's new model is designed to address previously identified shortcomings in the R&D GREET model, particularly in how it calculated lifecycle greenhouse gas emissions. The lifecycle approach accounts for all emissions from the initial production stages through to the final use of the fuel.

...

The Treasury Department notes that the methodology used by the new 40BSAF-GREET 2024 model is like that of the CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) methodology. CORSIA also evaluates the full fuel lifecycle, which includes all stages from the production of feedstock to the end use of the finished fuel.

Both these methodologies aim to provide a comprehensive assessment of the environmental impact of aviation fuels, focusing on reducing greenhouse gas emissions throughout the entire lifecycle of the fuel. This is crucial for developing effective strategies and regulations for mitigating the aviation industry's impact on climate change.

...

Significantly, a pilot program was introduced to credit SAF production using feedstocks grown under specific climate-smart agriculture (CSA) practices, like no-till farming and cover cropping. This pilot, part of the broader strategy to decarbonize aviation fuels, represents a shift towards recognizing and rewarding agricultural practices that contribute to carbon reduction. The release from Treasury on the credit noted that the CSA practices incorporated into the USDA CSA Pilot Program "are not a part of either the 40BSAF-GREET 2024 model or any CARB program including the LCFS program. Therefore, the Treasury Department and USDA have developed additional unrelated party certification requirements for the USDA CSA Pilot Program."

...

SAF production requirements:

  • SAF producers seeking to use the CSA reduction for producing SAF from CSA crops must contract directly with farmers enrolled in the USDA CSA Pilot Program for either CSA corn or CSA soybeans.

     CSA corn production practices:

  • Farmers producing CSA corn for Alcohol to Jet (ATJ)-ethanol must implement three specific practices on the same acreage:
  1. No-till farming.
  2. Planting cover crops.
  3. Using enhanced efficiency nitrogen fertilizer.

     CSA soybean production practices:

  • For CSA soybeans, only two practices are required:
  1. No-till farming.
  2. Planting cover crops.

               Added nitrogen is not required for soybean production.

 

     USDA CSA pilot program and emissions reduction:

  • In partnership with the USDA, the Treasury Department allows for a SAF synthetic blending component produced from CSA corn or soybeans to be eligible for an additional proxy reduction (CSA reduction) in emissions calculation, without needing a full lifecycle analysis.

     Emissions reduction example:

  • A synthetic blending component using CSA corn or soybeans is granted a safe harbor, with Treasury citing an example where CSA corn used in SAF production achieves a 53% emissions reduction.

     Regulatory alignment and definitions:

  • The definitions and practice requirements outlined by the Treasury in their notice align with USDA's Natural Resources Conservation Service (NRCS) practice standards and enhancements, with specific details provided in the notice.  READ MORE

 

Excerpt from AgWeb Opinion: The Safe-Harbor requires these practices to be applied to either a full field or perhaps all of the farm operation. The guidance is not totally clear on this requirement. Plus, third-party verification is required to determine the farmer met the CSA Pilot rules. The farmer is required to maintain very detailed records on all of these practices so the third-party can accurately verify the corn or soybeans meet the CSA Pilot rules.

It appears that the farmer must sell and contract their crop directly with the SAF producer. If they deliver their crops to an elevator or other third-party storage system, then that elevator must track that corn and verify it is delivered to the SAF plant.

Now why do we believe this safe-harbor is essentially worthless:

Corn or soybeans being converted this year is from crops harvested in 2023. CSA Pilot rules likely apply to so little corn or soybeans that can be delivered to a SAF plant to be of little use.

This safe-harbor might have had the needed impact if it was released in September, 2022 for the 2023 crop. This would have allowed the farmer to plant cover crops, utilize no-till when planting their crop and EENF.

Corn or soybeans harvested in 2024 that could be processed before year-end must meet the CSA Pilot rules including having a contract with the SAF producer directly not with the local ethanol plant. Agin, this guidance should have been in place before September, 2023 to allow the farmer to meet the rules. Providing guidance now is way too late for any farmer who is not already enrolled in some type of CSA Pilot program to ever provide any corn or beans to the SAF producer.

If the SAF producer is hundreds of miles away, the freight cost would outweigh any potential extra premium the SAF producer would pay to the farmer.

It is pretty easy to see why SAF plants are importing sugar ethanol from Brazil and will not waste their time with this safe-harbor. Our understanding is sugar ethanol reduces emissions by about 61%. This results in a potential credit of $1.36 per gallon to the SAF producer versus perhaps a $1.28 credit for corn ethanol. Why would a SAF producer want to go through the hassle of finding some CSA Pilot corn when they can simply import cheap Brazil sugar ethanol and get a higher credit with a lot less work.

I think the IRS and DOE will need to make this easier for farmers to get value from the Section 45Z credit starting in 2025 than this guidance will ever provide. We are ready to be wrong, but based on what we say from the guidance we are not hopeful. READ MORE

 

Excerpt from Energy.AgWired.com: The 40B tax credit guidance and modified GREET model released April 30 by U.S. Treasury lays the groundwork for U.S. ethanol producers and farmers to participate in the emerging market for sustainable aviation fuels (SAF).

But since 40B expires at the end of this year, all the attention will now turn to implementing the 45Z credit to start next year, and the Renewable Fuels Association is already working on the next steps.

In this edition of the Ethanol Report podcast, we get some of the details from US Treasury Secretary Janet Yellen and USDA Secretary Tom Vilsack, RFA Senior VP, Government & Public Affairs, Troy Bredenkamp, and Mitchell Hora, Continuum Ag.  READ MORE

 

Excerpt from Continuum Ag: There is some good, some bad, and some unknowns within the update, so let’s dive into it:

1. Indirect Land Use Change (ILUC): There was a huge unexpected positive outcome regarding ILUC in the IRS Rules.  I was anticipating that the ILUC factor (historically 7.4CI points US corn based ethanol) would go up by 5 points or worse.  Luckily, this was not the case and corn based ethanol shows a lot of promise in the future of sustainable fuels.   

2. Feedstock Calculator: Unfortunately, we haven’t seen an update to the GREET feedstock calculator. This absence raises concerns, especially considering its significance in quantifying the carbon intensity score of various feedstocks. While it’s disappointing, it highlights the urgency of advocating for its release before the implementation of 45Z. Our industry relies heavily on accurate data and tools, and the absence of an updated calculator presents a significant challenge that we must address collectively.  “In lieu” of using the GREET feedstock calculator, the 40B rules used a “punt” approach and are allocating a simple 10 CI point reduction for farms using cover crop, no-till, and enhanced efficiency fertilizer. They grant a 5 CI point reduction for soybean producers using cover crops and no-till. Hopefully 45Z will use the real CI reduction rather than this oversimplified approach. 

3. Definitions of Climate-Smart Ag Practices: On a positive note, we’ve received clear definitions of climate-smart ag practices. While this doesn’t compensate for the lack of a feedstock calculator update, it provides valuable guidance for farmers. Cover crop, no-till, and enhanced efficiency fertilizers are highlighted as key practices to be deemed climate smart. 

  • Cover Crop: The base rules go with flexibility toward cover crop species and planting/termination timing, as long as the farmer adheres to NRCS guidelines. Options for interseeding, companion cropping, haying and grazing exist, but harvesting covers for seed is restricted.
  • No-Till: Per these new rules, no-till doesn’t necessarily mean no tillage.  Per the guidance, no-till now includes leaving residue evenly distributed over soil surfaces, with exceptions for the planting furrow (aka strip-till is fine). Burning residue is prohibited.
  • Enhanced Efficiency Fertilizer: This practice requires the use of stabilizers on at least 50% of nitrogen content, with a written plan for NPK management. Approved stabilizers have to be used and we are researching these university derived lists now.

4. Mass Balancing for Traceability: The unexpected emphasis on traceability by the IRS caught many by surprise. However, the guidelines laid out provide a solid framework for ensuring the accountability of climate-smart grains in sustainable aviation fuel production. By tracking the movement of loads and maintaining detailed documentation, the traceability of climate-smart grains throughout the supply chain is ensured. Additionally, the requirement for each entity storing grain to conduct its own mass balance equation ensures transparency and accountability at every stage of the process. I need to learn a lot more in this arena, but the rules appear promising.

5. Restrictions on Stacking Carbon Outcome Programs: Another unexpected development was the IRS’s stance on stacking carbon intensity programs with other carbon credit programs. While this may come as a disappointment to some, it clarifies the boundaries between different types of carbon initiatives. The IRS laid out a “farmer attestation” document (we anticipated needing one of these and have been working on it for months) but the farmer must also attest that they are not in any other carbon programs. Although it would have been nice to stack, I wasn’t confident the IRS would allow for it, now we have clarity. 

6. Other CI-Reducing Pathways: The 40B GREET model introduces various pathways for reducing carbon intensity beyond purchasing low-carbon feedstock. From carbon capture and storage (CCS) to utilizing renewable energy systems, there are numerous avenues available for reducing carbon intensity scores. While the impact of on-farm practices may not be as significant in this version of the GREET model, it highlights the importance of exploring diverse strategies to achieve carbon intensity reductions.  This is the first time that the IRS is using the GREET model for tax credit purposes and the first time that the government is directly rewarding the noted soil health practices as part of their climate goals.

7. Preparation for 45Z: As we navigate through the intricacies of the 40B rules and GREET updates, it’s important to keep our sights set on the implementation of 45Z. With its rollout coming soon, we must take proactive measures by knowing your CI Score and organizing/verifying your data to make sure the opportunity is maximized.  READ MORE; includes VIDEO

 

Excerpt from Agriculture Dive: A Stanford study of the U.S. Corn Belt found yields declined by as much as 5.5% for corn and 3.5% for soybeans on fields that used cover crops for at least three years. Those production declines equate to a loss of about $40 per acre for corn and $20 per acre for soybeans, making “long-term adoption of the practice challenging,” researchers said.

It can also be very difficult to transition to completely no-till, which often takes years and “is a completely different system of farming,” according to Neil Sass, a Natural Resources Conservation Service soil scientist. Transition hurdles have caused many farmers to simply give up — a little more than half of the 293 counties in Illinois, Iowa and Indiana experienced disadoption of no-till practices in 2022, a report Iowa State University found.

Farm groups say they need more assistance and flexibility in the transition to climate-smart practices, including more freedom to decide which conservation practices make the most sense for their land.

“As corn growers, we already understand the environmental practices that work best for our growing conditions and climate, so it is not necessary for the government to dictate specifically how we reach an emissions reduction goal,” Harold Wolle, president of the National Corn Growers Association, said in a statement. “Farmers are going to have different methods depending on a variety of factors, including where their farms are located.”

Farm groups are now awaiting guidance on the IRA’s 45Z tax credit for passenger vehicles, which will also replace several biofuels-related credits scheduled to expire at the end of the year. The Treasury Department is expected to release the model for the 45Z credits in the weeks to come. READ MORE

 

Excerpt from Iowa Farmer Today:  Illinois Corn Growers Association President Dave Rylander said the update pushes farmers to implement a bundle of three on-farm conservation practices (cover cropping, minimized tillage and nitrogen management) for their corn to qualify for ethanol intended for SAF and to access the tax credits available.

He said this limits farmers’ options for the rest of the year, before new guidance comes at the beginning of 2025.

“Our concern is there are other practices modeled in GREET that are not being allowed (toward the tax credit),” Rylander said. “They have to bundle those three and there are probably only 2-3% of farmer taht can do that right now.”

In a press release following the update, Monte Shaw, president for the Iowa Renewable Fuels Association, said it was important to get these decisions out to the public, and now groups can discuss and adjust things in future updates.

“The approved bundle of farm practices won’t work for many Iowa farmers, let alone farmers throughout the Midwest,” Shaw said. “Given the range of climates and soil types, farmers do not want one-size-fits-all bundles mandated from D.C.

“Moving forward, it is paramount that many additional farming practices be recognized on an individual basis. Further, the carbon reduction given for the bundled practices appears to be much smaller than we’ve seen in other voluntary carbon programs.”

Rylander said while there is work to be done ahead of the next update in the coming months, this news allows the corn group to begin working with farmers and the Department of the Treasury to hone in on what the best course of action will be to help as many farmers as possible and continue to lower the carbon footprint of SAF.

“We have a starting point,” Rylander said. “Now we can develop our case for improving it or making it more flexible and workable. The GREET model is an ongoing process but it’s the best way to make a comparison compared to a full lifecycle analysis. The best way to develop a public policy in our minds is developing a technology-neutral level playing field.”  READ MORE

 

Excerpt from Brownfield Ag News: A leader with Clean Fuels Alliance America says concerns about potential requirements for sustainable aviation fuel feedstocks derived from crops are well-founded.

Kurt Kovarik suggests there’s an anti-corn ethanol agenda as the Biden administration develops guidance for the emerging SAF market.

“In this whole process there’s been, when we started the construction of this bill in Congress with the IRA, there was an inherent bias against crop-based biofuels. And that primarily came from environmentalists.”

He tells Brownfield climate-smart ag practices will help improve the carbon intensity score of crop-based biofuels, but possible penalties attributed to indirect land use changes are concerning.

“Or any indirect change. The assumption that producing the crop and using the crop for the production of fuel thereby has some indirect effect somewhere halfway across the globe.”

Kovarik says there’s no need for new modeling because there’s 15 years of domestic renewable fuels data proving no indirect land use changes occurred because of biofuels.  READ MORE; includes AUDIO

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thermocellum cloud point clover cmelina CNG Conversion kit co co-generation co-location Co-op Extension co-operative co-processing co-products CO2 Electrolysis CO2 neutral fuels CO2Removal Certificates (CORCs) coal Coal and Biomass to Liquid (CBTL) Coast Guard coastal habitat conservation coastal hay cobalt cock's foot coco coco methyl ester (CME) cocoa Coconut coffee coffee cherries coffee grounds coffee pulp cold flow cold-tolerance college/university Colombia Colorado combined heat and power (CHP) Comment Request commercial flights commercialization commissioning commo Commodity Credit Corporation (CCC) Commodity Futures Trading Commission (CFTC) commodity trading common reed Community activity community college Community involvement/engagement community scale Community Wood Energy Program competition compliance compliance credits compost Compressed Natural Gas (CNG/R-CNG/bioCNG) compression ratios compression-ignition engine computer simulation concrete condensate Congo Congressional Budget Office (CBO) Connecticut Conservation Reserve Program (CRP) Conservation Stewardship Program (CSP) construction and demolition waste/debris consumer education contamination contest contrails conversion technology Cook Islands cook stoves cooking fuel cooperatives COP21 COP22 COP23 COP24 COP25 COP26 COP27 COP28 COP29 COP30 copper coppice cordgrass corn bran Corn cobs corn ethanol corn fiber corn growers corn harvest corn kernel corn meal corn oil corn oil/distillers corn oil (DCO) corn prices corn stalks corn stover corn supply corn surplus corn syrup corn-based products corn/maize Corporate Average Fuel Economy (CAFE) standards corporate social responsibility corrosion corruption CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) cosmetics Costa Rica cotton cotton seed hulls cotton seed oil cotton stalk cottonwood Council on Environmental Quality county cover crops cow rumen cracking Crambe crassulacean acid metabolism plants (CAM) crimes criteria pollutants Croatia crop crop insurance cropland croton crowdfunding crude oil Cuba cup plant cuphea currency/foreign exchange policy curriculum cusi cutworm caterpillars cyanobacteria (blue-green algae) cylindro Cyprus Czech Republic d D-3 (cellulosic) RINs D-4 (bio-based diesel) RINs d-5 D-5 (advanced biofuel) RINs D-6 (renewable fuel) RINs D-7 RINs (Cellulosic Diesel) D-8 (proposed) RINs D20 (20%DME) D5 (5%DME) dairy waste dandelion DARPA date kernel oil date palm date palm pits date palm waste Dates DDGS (distiller’s dried grains with solubles) dead zone decanol decision-support tool deep water drilling Defense Logistics Agency (DLA) Defense Production Act deficit definitions deforestation defossilization Dehydration Delaware DeltaWing demonstration demonstration scale/unit Denmark densify density Department of Agriculture (USDA) Department of Commerce Department of Defense (DOD) Department of Education Department of Energy (DOE) Department of Health and Human Services Department of Homeland Security Department of Justice Department of Labor Department of the Interior Department of Transportation (DOT) depolymerization depots dextrose dfdsffsfdfsf diatoms diesel Diesel Emissions Reduction Act (DERA) diesel fuel blendstock diesel prices Diesel R5 diesel with renewables diesel-range hydrocarbons diesel-to-biodiesel conversion diethyl ether digital Digital Biology diisobutylene (DIB) dilute acid hydrolysis pretreatment DIN 51605 DIN EN 15376 (Ethanol blending component) direct air capture direct injection direct ocean capture Direct Sugar to Hydrocarbon Conversion (DSHC) direct-to-fuel directed evolution dispense distillates distillation distilled biodiesel distilled palm methyl ester (DPME) distilleries distributed/centralized distribution distribution capacity distribution waiver diversification divestment DME/rDME (dimethyl ether)/renewable DME DMF (2.5-dimethylfuran) Dominican Republic double cropping drawdown Drones/Unmanned Aerial Vehicles (UAV) drop-in biofuels/hydrocarbons drought drought tolerant drought-resistant dry ice dual cropping Dubai duckweed e e-diesel e-LNG (synthetic/electro Liquified Natural Gas) e-methanol e-NG (synthetic natural gas) E. coli E0 E0 price E1 E10 E10 certification fuel E10 price E100 E100 conversion kit E11 E12 E13 E15 E15 price E15 pumps E2 E20 E20 price E20 pumps E22 E25 E25 pumps E27 E3 E30 E30 capable E30 certification fuel E30 optimized E30 price E30 pumps E35 E4 E40 E40 conversion kit E40 pumps E5 E5 price E50 E55 E6 E7 E70 diesel E75 E78 E8 E80 E85 E85 conversion kit E85 optimized engines E85 price E85 pumps E90 E92 E95 E97 E98 earthquakes East Africa Eastern Europe economic development Economic Development Administration economic modeling economic policy economics Ecosystems Services Ecuador ED7 (7% ethanol 93% diesel) ED95 education Education Series 3030 educational business private educational tour EERE efficiency egg shell Egypt El Salvador Electric aircraft Electric Car/Electric Vehicle (EV) electric car/Electric Vehicle (EV) Prices electric grid electricity electricity price electricity/power generation electricity/power transmission electrocatalysis electrochemical electrochemical cell electrofuels (e-fuels) electrofuels (e-fuels) prices electrolysis electrolytic cation exchange electromethanogenesis (ME) electrons Elephant grass/Napier grass elephants embargo eminent domain emissions emissions standards EN 15751 EN 15940 EN 16709 EN 228 EN 590 EN228 (standard pump gasoline) end user end-of-life Endangered Species Act (ESA) Energy Bill energy cane energy consumption energy crops energy density energy dominance energy grasses energy independence Energy Independence and Security Act of 2007 (EISA) Energy Information Administration (US EIA) energy law energy policy energy prices energy reserves Energy Return on Energy Invested (EROEI or EROI) energy security Energy Security Trust energy storage enforcement engine Engine Development engine problems Engine/Fuel Co-optimization engineering England enhanced oil recovery (EOR) entrepreneur environment environmental impact study (EIS) environmental justice/socially inclusive environmental policy Environmental Quality Incentive Program (EQIP) Environmentalists Enzymatic enzymatic conversion enzymatic depolymerization enzymatic hydrolysis enzyme production enzyme recycling Enzyme solicitation enzymes EPA (Environmental Protection Agency) EPACT (Energy Policy Act) Equatorial Guinea equipment eRINs/electric pathway Eritrea erosion control EROWI (Energy Return on Water Invested) ESG (Environmental Social Governance) esterification Estonia ETBE (ethyl tert-butyl ether) etha ethane ethanol ethanol benefits ethanol blend wall ethanol blended diesel ED ethanol blends/ethanol flex fuels ethanol emissions ethanol ether diesel fuel ethanol fire ethanol fuel cells ethanol hybrid ethanol pipeline ethanol prices ethanol production ethanol pumps ethanol tax ethanol terminal ethanol to gas ethanol tolerance ethanol-fueled aircraft Ethanol-to-Gasoline (ETG) ethanol/bioethanol ethanol/diesel ethanol/methanol synthesis ethanol2G Ethiopia Ethiopian mustard ethyl levulinate (EL) ethylbenzene ethylene ets eucalyptus Euglena European Emissions Trading System (ETS) European Union (EU) eutrophication executive order executive order--state Extended Range Electric Vehicle (EREV) externalities extremophiles f F Factor F-24 F-34 F-76 (Marine Diesel) F-T FAEE FAEE (fatty acid ethyl esters) Fair trade False Claims Act FAME (Fatty Acid Methyl Ester) Farm Bill Farm Bureau farm equipment farm policy Farm to Fleet Farm to Fly farmers farming farnesane farnesene Fats fecal sludge Federal Aviation Administration (FAA) Federal Bureau of Investigation (FBI) Federal Emergency Management Agency (FEMA) Federal Energy Regulatory Commission (FERC) Federal Highway Administration (FHWA) federal land Federal Railroad Administration Federal Reserve Bank Federal Trade Commission (FTC) Federal Transit Administration (FTA) feed Feed In Tariffs (FIT) feed prices Feedstock Flexibility Program for Bioenergy Producers feedstock logistics feedstock material feedstock prices feedstock storage feedstock terminal feedstock transportation Feedstocks fermentation ferry fertilizer fiber Fiji Financing Finland Fischer-Tropsch Synthetic Kerosene with Aromatics (FT-SKA) Fischer-Tropsch Synthetic Paraffinic Kerosene (FT-SPK) Fischer-Tropsch Synthetic Paraffinic Kerosene with Aromatics (FT-SPK/A) Fischer-Tropsch/FT fish feed fish oil fish waste fit for purpose Fixed Base Operator (FBO) flameleaf sumac flavors flax fleet turnover Fleets fleshings flex-fuel vehicles (FFV) flight tests Flightpath flixweed/tansy/herb-Sophia flood-prone soil Florida flue gas FOG (Fats/Oils/Grease) follow-the-crop food Food and Agriculture Organisation (FAO) Food and Drug Administration (FDA) food and fuel food policy food prices food processing waste food safety food security food vs biomaterials/bioplastics food vs fuel food waste for forage forage sorghum forecasts foreign oil Foreign Policy forest Forest Biomass for Energy forest biotechnology forest residue/waste Forest resources Forest Service forestry forklifts Formate formic acid fossil carbon fossil fuel Frace fracking fractionation fragrance France franchise fraud free fatty acids (FFA) Freedom of Information Act (FOIA) freight/cargo French French Guiana fructose fruit FT-SKA fuel fuel additives fuel cell electric vehicle (FCEV) fuel cells fuel economy fuel efficiency fuel injection fuel mixtures fuel molecules fuel oil fuel performance fuel prices Fuel Quality Directive (FQD) fuel registration Fuel Retailers fuel testing fuel transportation fuel use fuel wholesaler fully burdened cost fund funding fungus/fungi Furanics furfural fusel oils Future Farmers of America (FFA) Gabon gallium Gambia games gas prices gas tax/highway user fee gas-to-liquid (GTL) gasification gasoline gasoline baseline gasoline consumption gasoline mandate gasoline markets gasoline price gasoline-range hydrocarbons Gemany General Services Administration general waiver authority generators genetically engineered yeast cells genetically enhanced microbes genetically modified organism (GMO) genome Georgia Georgia (country) geothermal German Germany Gerrmany Ghana GHG (Greenhouse Gas Emissions) GHG (Greenhouse Gas Emissions) Intensity giant cane giant kelp Giant King Grass Giant Reed/Arundo GIS glass tubing gliricidia sepium global rebound effect Global South global warming global warming potential glucose glycerin glycerin standards glycerol goats gorse Governance practices) Government Accountability Office (GAO) government investment government resources government subsidies grain sorghum/milo grain speculators grains GRAND-AM grants grants-local grants-state grapefruit grapes graphene graphite GRAS (generally regarded as safe) Grasses grasses grasshoppers grease Great Green Fleet Great Lakes Greece green bonds green chemistry Green Deal EU green economy green house facility Green Jobs Green New Deal Green Racing Green Recovery green/black economy Greenland GREET Greenhouse Gases Regulated Emissions and Energy Use in Transportation Model Grenada gribble growers gua beans Guam guar Guatemala guayule Guerbet reaction Guinea Guinea Bissau Gulf states gulmohar Gumweed (grindelia squarosa) Guyana GWP gypsum h Haiti Halophytes harvest site processing harvesting Hawai'i hay hazardous waste hazelnut HBIIP Higher Blends Infrastructure Incentive Program HDCJ HDO-SAK (hydro deoxygenated synthetic aromatic kerosene) health health benefits health effects heat of combustion heat of vaporization heat-tolerance heather heating oil/fuel Heavy Duty Truck Rule heavy duty vehicles (HDV) hedging HEFA (Hydro-processed esters and fatty acids) HEFA50 helicopters hemicellulace enzymes hemicellulose hemicellulosic sugars Hemp hemp oil hemp seed herb hexanol HFO (Heavy Residual Fuel Oil) hibiscus high blend renewable fuels (HBRF) High Hydrogen Content Synthetic Paraffinic Kerosene (HHC-SPK) High Octane Fuel (HOF) High Octane Fuel Standard High Octane Gasoline (HOG) high octane low carbon (HOLC) fuel High Octane Vehicles (HOV) high performance regular high school project high sulphur fuel oil (HSFO) high-octane/low-carbon (HOLC) liquid fuels Highway Bill highway rights-of-way Highway Trust Fund history hog farmers hombayniya homogeneous-charge compression-ignition Honduras honey locust Hong Kong Honge tree nuts hops horticulture Housing and Urban Development (HUD) HPF (High Performance Fuels) HRJ (Hydrotreated Renewable Jet) human rights Hungary Hurricane Sandy HVO (Hydrotreated vegetable oil) HVO100 HVO20 HVO30 Hybrid aircraft hybrid buses hybrid locomotive hybrid ships hybrids hydrocarbon fuels Hydrocarbon-Hydroprocesed Esters and Fatty Acids (HC-HEFA-SPK) hydrodeoxygenation hydrodiesel hydrofaction hydroformylation hydrogen aircraft hydrogen carrier hydrogen combustion engines hydrogen fuel cells hydrogen leaks hydrogen pipeline hydrogen pumps/fueling stations hydrogen tax credit hydrogen terminal Hydrogen/Renewable Hydrogen Hydrogen/Renewable Hydrogen Price hydrogenase hydrogenation hydrogenation-derived renewable diesel (HDRD) hydrogenolysis hydropower Hydroprocessed fermented sugars to synthetic isoparaffins (HFS-SIP) hydroprocessing hydropyrolysis hydrothermal carbonization hydrothermal gasification hydrothermal liquefaction (HTL) hydrothermal treatment Hydrotreated renewable diesel (HRD) hydrotreating hydrotreatment hydrous ethanol hypoxia zone Iceland Idaho Illinois Illiois illuppai ILUC (Indirect/Induced Land Use Change) import/export incinerator ash India Indian beech tree Indian grass Indiana indirect effects indirect emissions indirect fuel use change indium Indonesia industrial burners industrial ethanol industrial gases industrial sugars industrial waste industrial waste gases IndyCar infographic Infrastructure inhibitors innovation insecticide/pesticide insects insurance integrated biorefineries integrated food/energy systems intellectual property Inter-American Development Bank inter-crop interactive map intercropping internal combustion engine (ICE) internal combustion engine (ICE)/gasoline engine ban International international balance of payments International Council on Clean Transportation (ICCT) International Energy Agency (IEA) International Maritime Organization (IMO) International Monetary Fund (IMF) International Organization for Standardization (ISO) International Renewable Energy Agency (IRENA) International Sustainability and Carbon Certification model(ISCC) International Trade International Trade Administration International Trade Commission Internships inulin invasive species Investing investment tax credit Invvesting ionic liquids Iowa IPCC Intergovernmental Panel on Climate Change Iran Iraq Ireland iridium iron iron oxide IRS (Internal Revenue Service) IS 1460 ISO 8217 (marine distillate fuel standard) ISO 9000 isobutanol isobutanol price isobutanol pump price isobutene isobutylene isomerisation isooctane isooctene isopropanol Israel Italy Ivory Coast JAA jackfruit Jamaica jamelão Japan jatobá Jatropha Jersey Jerusalem artichoke jet jet A Jet A-1 jet B Jetfuel (Sustainable Aviation Fuel (SAF)) Jimmy Carter Jobs Joint Office of Energy and Transportation jojoba Jordan JP-10 JP-4 JP-5/NATO F-44 JP-8/NATO F-34 juniper Just A MInute Just Transition jute K-12 Education Kabakanjagala kalanchoe kamani Kans grass Kansas Karanja Kazakhstan kelp Kemiri Sunan kenaf Kentucky Kenya kerosene ketones kinggrass Kiribati knotweed Knowledge Discovery Framework Korea Kosovo kudzu kukui nut kulpa kusum Kuwait Kygryzstan labels labor policy Labrador lactic acid lactose Lake County lamp oil land ownership land prices land rights land subsidence land tenure land transfer land use land use change land use policy landfill methane Landfills landscape Laos Latin America Latvia LCFS (Low Carbon Fuel Standard) lead Leadtree leaf ant Lebanon lecithin legislation Legislation-Federal Legislation-State lemna lend-lease Lesotho lesquerella leucaena levulinic acid Liberia Libya licensing lichens life cycle analysis (LCA) light rail lignin Lignin Ethanol Oil (LEO) Lignocellulosic Biofuel lignocellulosic sugars lime Lipid liquefaction liquid liquid petroleum gas (LPG) liquid transportation fuels liquidation Liquified Biogas (LBG) Liquified Biogas (LBG) pumps liquified biomethane (LBM) Liquified Natural Gas (LNG) lithium Lithuania litigation Litigation-Federal Litigation-State livestock loan guarantees loans lobbying loblolly pine locomotives lodgepole pine logistics long-term contracts Louis Louisiana low c low carbon emissions low carbon octane standard (LCOS) Low Emission Vehicle Standards (LEV) low sulfur diesel low sulfur fuel low sulfur marine fuel lubricants lumber mill Luxembourg lysis M100 M15 M3 M50 ma macadamia macauba Macedonia machine learning machinery macororo Madagascar magnesium mahua Maine Malawi Malaysia Maldives Mali mallees Malta Malyasia mamona management changes mandates mangaba manganese mango mangrove Manitoba mannose manure maple maps marginal land marine algae Marine Corps Marine Diesel Oil (MDO) Marine Fuel Oil Marine Gas Oil (MGO) Marine/Maritime Bio and Renewable/Sustainable Fuel (SMF) Marine/Maritime Bio and Renewable/Sustainable Fuel (SMF) price Marine/Maritime Bio and Renewable/Sustainable Fuel Terminal Marine/maritime renewable fuel terminal/bunkering market forces market share marketing markets/sales Mars Marshall Islands Maryland Masdar Institute mass balance standard Massachusetts Master Limited Partnership (MLP) Mauritania Mauritius Mazda meat mechanics training medical waste MEEC membranes mergers and acquisitions mesquite methanation methane leaks methane/biomethane methanization methanol benefits methanol fuel cells methanol price Methanol-to-Jet (MTJ-SPK) Methanol/Biomethanol/Renewable Methanol methylbutenol Mexico Michelin GreenX Challenge Michigan micro-crop microalgae microbial electrosynthesis microbiology microorganisms/microbes microwave Mid-Atlantic Middle East Midwest mileage military military policy military reserves military specifications military strategic flexibility military strategy military use of biofuels milk permeate millennium fruit millet millettia pinnata milo stover mineralization minerals mining Minn Minnesota miscanthus misfueling missile fuel Mississippi Missouri mixed prarie mobile refinery modeling modular molasses mold molinia molybdenum MON (Motor Octane Number) Monaco Mongolia mongongo monitoring/measuring reporting verifiction (MRV) Montana Montenegro moose morama Moringa tree Morocco morula motorcycles motors MOVES (motor vehicle emissions simulator) modeling system MOVES2014 MOVES3 (MOtor Vehicle Emission Simulator model) Mozambique MSW (Municipal Solid Waste) MTBE (Methyl tert-butyl ether) multi-fuel municipal/city mushroom mushroom substrate mustard seed mvr Myanmar n-butanol n-butene nahar Namibia nano nano particles nanocatalysts 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Nevada New Brunswick new fuel approval New Guinea New Hampshire New Jersey New Mexico New South Wales New York New Zealand Newfoundland Newfoundland and Labrador next generation biofuels next generation vehicles NHRA drag racing Nicaragua nickel Niger Nigeria nipa sap nitrate leaching nitrates nitrogen Nitrogen fertiliser nitrogen starvation nitrous oxide (N2O) Niue NO2 noodles nopal North Africa North America North Carolina North Dakota North Korea Northeast northern catalpa Northern Ireland Northern Territory Northwest Territories Norwary Norway Nova Scotia NOx (nitrogen oxides) noxious weeds nuclear Nunavut nut shells nutraceuticals nutrient credit trading nutrient management nutrients nutrition oak oat hulls oat straw oats Obligated Parties/Point of Obligation (PoO) ocean-based energy Oceania octane octane price/value octanol Office of Energy Efficiency and Renewable Energy Office of Management and Budget (OMB) Office of Science and Technology Policy Office of Science and Technology Policy (OSTP) Office of Science Technology and Policy (OSTP) Offices of Inspector Generals offtake agreements Ohio oil oil embargo oil exploration oil monopoly oil p oil price parity oil prices oil production oil refineries oil replacement oil sands oil seed oil seed crops oil speculators oil spill oil subsidies oil taxes oil/gas terminals Oils Oklahoma olefins oligomerization olive cake olive oil olive pits olive pomace olive water olives Oman Omega-3s on-farm algae production on-farm ammonia production on-farm biodiesel on-farm ethanol production on-farm natural gas production on-farm processing on-site hydrogen production one p one pound waiver onion waste online courses Ontaio Ontario OPEC (Organization of the Petroleum Exporting Countries) open fuel standard open pond opportunity zones optimized flex fuel vehicles orange peel orchard grass orchard prunings Oregon organic solar cells Organization for Economic Cooperation and Development (OECD) osage orange OSHA Overseas Private Investment Corporation overview overview/survey course owa oxygen oxygenate ozone Pakistan Palau palm palm biomass palm fatty acid distillate palm fiber palm fronds palm kernel palm kernel oil palm kernel shell palm oil Palm Oil Methyl Ester (PME) palm oil mill effluent (POME) palm oil prices palm trunk sap palm waste Paludiculture/peatland cultivation Panama pandas panic grass papaya paper Papua Indonesia Papua New Guinea paraffins Paraguay Paris Agreement parity partial waiver particulates pasture land Patent and Trademark Office (PTO) patents pathways Paulownia paulownia tree payments peach shell peaches peak oil peak oil demand peanuts/groundnuts peas pectin peela kaner pellet pellets Pennsylvania pennycress/stinkweed pentane pentanol pentose pequi perennial grains perennial grasses Performance permitting Peru pest-tolerance pesticide-tolerance pests pet food petition petroleum pharmaceuticals phase separation Philippines phosphorus photobioreactor photoelectrocatalysis 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RNG tax credit roadmap rocket fuel Romania RON (Research Octane Number) rosin rotation crops Roundtable on Sustainable Biomaterials (RSB) royalties RP-1 RTP (rapid thermal processing) rubber rubber seeds rumen ruminants rural development Rural Energy for America Program (REAP) Rural Energy Self-Sufficiency Initiative Rural Renewable Energy Pilot Program rushes Russia Russian olive rutabaga Rwanda ry rye Rye grass rye straw s saccharification SAF pipeline SAF10 SAF30 SAF40 SAFc (Sustainable Aviation Fuel certificates) Safer and Affordable Fuel Efficient Vehicles (SAFE) safety safflower sago pond weed SAIC sal tree Salicornia salt water salt-tolerant saltbush saltcedar Samoa Sanctions Santa Monica sardine oil Saskatchewan Saudi Arabia sawdust scale up Scandinavia scholarships/fellowships Science Advisory Board (SAB) Science Based Targets initiative (SBTi) Science Policy scooters Scotland scum sea level rise seaports seashore mallow seawater seaweed cultivation Seaweed/Macroalgae 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