A plan by the California Air Resources Board to increase the use of sustainable aviation fuel is drawing criticism from the airline industry, which says the proposal goes too far, while the soybean industry is concerned about possible sustainability requirements for ag feedstocks.
The plan, contained in proposed amendments to the state's Low Carbon Fuel Standard released in December, is intended to boost the use of SAF on flights that originate and land in the state. The amendments would remove an existing exemption from the LCFS for jet fuel in 2028.
Other proposed amendments would ensure that dairy digesters would remain in the LCFS program as credit creators over the objections of some environmentalists.
The growing SAF industry – and the ag industry in general – is examining the details of the SAF proposal in anticipation of submitting comments next month. A public hearing is scheduled in March.
In California, intrastate jet fuel makes up about 10% of total jet fuel consumption and is responsible for 2% of greenhouse gas emissions in the state’s transportation sector, the CARB staff’s “Initial Statement of Reasons” document states.
As emissions from other forms of transportation decline, the 2% share is expected to increase, CARB said.
But Airlines for America, the trade group for the nation’s airline industry, said in a brief statement provided to Agri-Pulse, that it does not "support California’s proposal to amend the LCFS to regulate jet fuel for intrastate flights as it would raise the cost of jet fuel and not lead to greater volumes of SAF production.” In addition, A4A said CARB “does not have legal authority for the proposal as states are federally preempted from regulating jet fuel.”
“U.S. airlines are committed to increasing the availability and use of sustainable aviation fuels throughout the United States,” A4A said, adding that allowing SAF use to generate credits “has helped California become a leader in SAF production and use.”
The International Air Transport Association has committed to achieving net-zero carbon emissions by 2050, with SAF potentially providing 65% of the solution.
“We would expect new propulsion technology, such as hydrogen, to take care of another 13%,” IATA said in 2021. “And efficiency improvements will account for a further 3%. The remainder could be dealt with through carbon capture and storage (11%) and offsets (8%).”
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The National Business Aviation Association is taking a similar position. In a statement, NBAA commended the adoption of the LCFS, but said that “we don't support the proposed amendment to the standard, as it would not meet our overall objective of boosting SAF production, it would likely lead to cost increases for existing jet fuel and as written the proposal likely sidesteps federal preemption on the regulation of jet fuel.”
The International Council for Clean Transportation, however, called the proposed amendments underwhelming.
Responding to a request for comment, ICCT researcher Jane O’Malley said while ICCT “supports the inclusion of conventional jet as a deficit-generating fuel,” the proposed amendments “fell really short on ambition.”
“Only intrastate flights (those that take off and land in California) will be obligated, so this is only a small fraction of total jet fuel consumption,” O’Malley said in an email. “The obligation period was delayed to 2028 and no meaningful sustainability safeguards were implemented to prevent a ramp-up in high-risk, low-reward hydroprocessed vegetable oils.”
She said ICCT would be writing in more detail about the proposal soon. The comment period ends Feb. 20 and the public hearing is scheduled for March 21.
A source in the SAF industry disagreed with the preemption argument, saying that just as California can regulate maritime or rail operations in the state, it can regulate jet fuel.
“All diesel in the state, whether it's used in the state or out of the state is obligated – whether it's imported into the state, or produced in the state," the source said. "They don't track whether that truck goes out of the state or not, they just obligate that diesel fuel.”
“Obligated parties” under the LCFS must purchase credits to meet the program’s goals.
Alexa Combelic, ASAOne issue groups and companies will be seeking clarity on has to do with the extent of the new requirement.
“What I'm curious about is if it's going to apply to any jet fuel that fuels an airplane in the state of California,” said Alexa Combelic, director of government affairs at the American Soybean Association, citing as an example a plane that fuels up at LAX and then flies somewhere out of the state.
The provision “would be limited to flights that take off and land within the state of California,” the staff report says.
Overall, Combelic called the proposal a “mixed bag.” ASA was happy to see that it does not include a cap on agricultural feedstocks in the LCFS, something that had been discussed during CARB workshops leading up to the proposal.
At the same time, the group is concerned about sustainability requirements for feedstocks that are under consideration.
“We just want to make sure that, that we can prove our sustainability in a way that's not going to cost an arm and a leg in reporting requirements,” she said.
Combelic also wonders whether the proposed elimination of palm-based feedstocks will include palm-derived used cooking oil, which right now is a large part of the market. “I don't think that's been made quite clear,” she said.
LanzaJet, which uses ethanol to produce SAF, said it was “encouraged by [CARB] taking this initial step, as it helps level the playing field for the production of Sustainable Aviation Fuel (SAF) relative to other renewable fuels, further supporting aviation's ability to decarbonize the industry.”
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