Groups urge Congress to use DOE modeling for SAF tax credit

By Erin Voegele | August 09, 2021

Growth Energy, Renewable Fuels Association, National Biodiesel Board, National Corn Growers Association, National Farmers Union and American Farm Bureau Federation are urging federal lawmakers to ensure any future tax credit for sustainable aviation fuel (SAF) is based on accurate carbon accounting lifecycle analysis led by the U.S. Department of Energy.

The six biofuel and ag groups on Aug. 6 sent a letter to the U.S. Senate Committee on Finance and the U.S. House of Representatives Committee on Ways and Means outlining recommendations for a sound and effective SAF tax credit.

“As the Senate and House of Representatives consider new legislation to establish a tax credit for sustainable aviation fuel (SAF) this year, we respectfully request this tax credit be based on the most updated and accurate science-based lifecycle carbon assessment (LCA) methods,” the groups wrote. “Without a sound LCA as its basis, a SAF tax credit will be significantly less effective in driving investment in new fuels and reducing aviation emissions.

“Numerous members of our respective organizations are poised to produce SAF or sustainable feedstocks for SAF,” they continued. “Many others are looking to work toward participation in the full value chain in the relatively near future. We recognize the importance of decarbonizing the aviation sector with low carbon liquid fuels. Because biomass feedstocks are essential SAF sources, it is imperative that the tax credit properly account for the lifecycle emissions of these sources and the petroleum products these new fuels will replace.”

The ag and biofuel groups ask lawmakers to make the DOE the lead agency in establishing a regularly updated LCA for any SAF credit. “Across our federal government, DOE has the best resources, expertise, and current ability to assess lifecycle emissions fairly and scientifically,” the groups wrote. “At minimum, the DOE should be a full and equal partner in this role with the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Agriculture (USDA).”

The letter explains that current legislation relies heavily on LCA modeling from the International Civil Aviation Organization. That modeling, the groups explain, does not use the most comprehensive model approaches or most recent data for some important SAF pathways. As a result, “carbon intensity estimates under ICAO for some SAF pathways are inaccurate and inappropriately penalized,” the groups said.

The letter also points to potential problems with the use of EPA modeling. “Unlike the DOE, EPA does not maintain a regularly updated LCA model or methodology for biofuels,” the groups wrote. “Notably EPA’s most recent comprehensive analysis for biofuels was conducted in 2009. EPA’s analysis does not reflect or capture the continuous improvement that has been witnessed over the past decade in biomass production or the technology and efficiency improvements in fuel production. As climate-smart agriculture practices continue to improve and expand and as new fuel production technologies for SAF are developed and scaled to market, a regularly updated LCA is essential to the success of a SAF tax credit and its ability to incentivize new fuels and reduce emissions.”

In addition, the biofuel and ag groups ask lawmakers to ensure LCA for petroleum jet fuels be based on the most recent and accurate data and recommend Congress designate a baseline carbon intensity value for fossil jet fuel.

“In summary, our recommendation for a sound, sustainable, and effective SAF tax credit is to ensure the legislation allows a DOE-led LCA, unencumbered by ICAO, utilizing USDA expertise on agriculture feedstocks,” the groups wrote. “Furthermore, a date-certain, near-term transition to this DOE-led LCA methodology must be an integral part of any SAF tax credit legislation. Finally, we urge that you consider establishing or directing a clear baseline emissions value for petroleum-based aviation fuel, informed by the most recent science and data.

“Without these reforms, the federal government’s desire to promote and develop robust domestic SAF production capabilities as quickly as possible will be put at serious risk,” they continued. “Sustainable biomass use, with a proper, scientifically driven LCA, is essential to produce SAF here in America for domestic and international consumption. Our organizations could only support a SAF tax credit with a sound LCA as its basis.”

A full copy of the letter can be downloaded from the Growth Energy website