This analysis overviews how US aviation and biofuel industries are promoting sustainable aviation fuel (SAF) as essential for decarbonization while advocating for weaker state-level SAF policy and federal SAF sustainability criteria. Such negative lobbying may result in increased production of corn-based SAFs and the expansion of cropland to satisfy increased demand, resulting in higher greenhouse gas (GHG) emissions as forests and natural lands, both key carbon sinks, are cleared for agriculture.
The two industries have coordinated advocacy to weaken federal sustainability criteria for SAFs. The ‘SAF BTC Coalition’, which includes American, Delta, United, Southwest, Airlines for America, and the Renewable Fuels Association, promotes lower estimations of fuel emissions calculated by producers through an alternative methodology to the method developed by the UN, currently proposed under federal policies. This method lacks protocols present in the UN's methodology to verify that estimates are accurate. Consequently, corn-based SAFs are more likely to be eligible for tax credits under federal policies, regardless of whether the favorable emissions calculations overstate their climate change mitigation potential.
The Renewable Fuels Association advocated for amendments that may undermine federal SAF sustainability criteria and make corn-based SAFs eligible for policy tax credits. The leading industry association for the US ethanol industry advocated for amendments to the US SAF blenders tax credit and Clean Fuels Production Credit, which appear more likely to underestimate corn-based SAF’s emissions, facilitating qualification for tax credits, than the UN's methodology proposed under such regulations. This could significantly weaken the emissions reduction potential of the policies, as SAFs with considerable risk of GHG emissions from cropland expansion are incentivized.
The report finds negative policy engagement from Airlines for America (A4A) on California’s Low-Carbon Fuel Standard (LCFS) and Oregon’s Clean Fuels Program (CFP). A4A is the leading US aviation industry association, with Southwest, United, JetBlue, Delta, and American holding board-level positions. The industry group advocated for amendments to make fuels with higher emissions eligible (and thus incentivized) under California’s LCFS and Oregon’s CFP, as well as opposing a cap on crop-based biofuels in California.
Overall, this report suggests that the US aviation sector is pushing for amendments to SAF policy to the detriment of meaningful, science-based decarbonization. Airlines strongly support SAFs as the primary current, viable solution to decarbonization without reducing demand. However, the US aviation sector appears to be pursuing a policy engagement agenda to get SAFs incentivized at any cost, including promoting policy amendments that risk stimulating SAF production with little, if any, overall GHG emission-saving contribution. Such policy engagement could jeopardize the integrity of US SAF policy and efforts to decarbonize aviation. It contrasts the advice of the Intergovernmental Panel on Climate Change (IPCC), the approach of the UN's International Civil Aviation Organization, and the advocacy of airlines in other regions, such as the European Union.
It is noted that logos of industry associations are occasionally utilized in the graphics associated with the analysis in this report, as is common practice in public-facing releases of this kind. This in no way implies agreement and/or endorsement by the entities concerned with the report’s content.
Please note that all entities analyzed in this report are fully updated as of 01/06/2023.
Following an explanation of the purpose of this report, this section summarizes the possible route to aviation decarbonization through sustainable aviation fuels (SAFs), including an overview of the risks highlighted by the Intergovernmental Panel on Climate Change (IPCC) on the potential negative impact of bio-based SAFs on climate and biodiversity due to land-use change. It subsequently provides a comparison of two key methodologies designed to estimate the lifecycle GHG emissions of SAFs.
InfluenceMap’s platform assesses the climate policy engagement activities of over 500 companies and 250 industry associations globally. The assessments provide a direct point of comparison between companies’ high-level communications on climate policy and their detailed policy engagement, including the advocacy of the industry associations that engage on their behalf.
InfluenceMap’s analysis of climate policy engagement focuses on the five largest airlines in the US by number of passengers in 2021 - American Airlines, United Airlines, Delta Air Lines, Southwest Airlines, and JetBlue Airways*. It also includes Airlines for America (A4A), the main industry association representing the US airline sector, with all five airlines on A4A’s board of directors. This briefing also analyzes lobbying from the Renewable Fuels Association (RFA), the leading trade association for America’s ethanol industry. RFA has over 100 members, including ethanol producers (such as Gevo and LanzaJet) and national corn associations (such as the National Corn Growers Association).
Industry associations intend to influence policy in the interests of their corporate members, collectively representing the positions held by their respective members. As companies increasingly come under pressure to act on climate change, much of the negative advocacy is now outsourced to their industry associations. Globally, the most powerful advocacy groups are instrumental in shaping climate and energy policy in their respective regions. The UN Guide for Responsible Corporate Engagement in Climate Policy outlines the important role they play.
The Climate Action 100+ aviation sector strategy, published in March 2022, asserts that SAFs will play an “essential” role in delivering alignment of aviation with 1.5°C and concludes that investors should encourage airlines to stop direct and indirect lobbying against policy that facilitates decarbonization, support measures intending to scale-up SAF and avoid the use of crop-based biofuels. Therefore, this briefing analyzes corporate policy engagement with US SAF-related policies, with a particular focus on the integrity of the underlying sustainability criteria. While this engagement only minimally contributes to overall company scores, InfluenceMap will update its methodology to include this analysis in final entity scores in 2023. It is currently shown in this briefing as a distinct ‘land-use engagement score’.
* Considering JetBlue’s merger with Spirit Airlines in October 2022, the airlines’ passengers have been combined.
Over the last two decades the climate impacts (CO2 and non-CO2) of aviation, the most climate-intensive form of transport, have risen rapidly. In 2019, the aviation sector accounted for 2.8% of global CO2 emissions, 28% of which were generated by US aviation. The impacts of COVID-19 temporarily reversed this growth, causing a fall in CO2 emissions from international aviation of approximately 50%. However, in April 2023, global air traffic reached 90.5% of pre-Covid levels and the International Air Transport Association’s (IATA) December 2022 Global Outlook Report forecasted that the number of passengers/year would almost double by 2040. Consequently, in September 2022, Climate Action Tracker concluded that without significant policy action, emissions from international aviation could triple by 2050, in a trajectory consistent with a 4°C world – well beyond the Paris Agreement’s temperature goals.
In its landmark 2022 AR6 Working Group III report, the IPCC found that aviation has a strong dependency on liquid fossil fuels; the principal greenhouse gas (GHG) emitted is CO2 from the combustion of fossil-based jet fuel (10.5.1, 1086). The report highlighted the need for “fundamental shifts in technology, fuel types, or changes of behavior or demand” to decarbonize the aviation sector (10.5.2, 1086), identifying sustainable aviation fuels (SAFs), liquid hydrogen, and electricity as potential options.
SAFs, an umbrella term referring to fuels derived from non-fossil sources, can be split into two main groups:
Bio-SAFs: a biofuel used to power aircraft. This category can be further split into 1st generation (conventional) and 2nd generation (advanced) biofuels. 1st generation biofuels are produced from food crops, such as corn and soy, while 2nd generation biofuels are produced from non-food biomass, such as perennial grass, waste cooking oil, and agricultural residues.
Synthetic fuels: Jet fuel is synthesized in a process that involves low-carbon electricity, CO2, and water.
The IPCC’s 2022 AR6 Working Group III report asserts that bio-or synthetic fuels are the “only way for demand for aviation to continue to grow without increasing CO2 emissions”. Conventional biofuels are currently widely used (6.4.2.6, 643) and although advanced biofuels are an “emerging viable option”, they are typically more expensive, limited by supply (6.4.2.6, 645), and require commercialization (6.4.2.6, 643). The process of synthetically producing fuels is also in its infancy compared to bio-SAFs (10, 1088).
Currently, only 0.1% of fuel uptake is SAF, with the remaining 99.9% of jet fuel fossil-based. Yet no binding global or federal SAF targets yet apply to the US aviation industry. Instead, the industry is largely self-regulated, setting only voluntary SAF targets, with the industry often failing to meet such non-binding targets. For example, a May 2022 Possible study found that since 2000 every fuel target set by the aviation industry had been missed, weakened, or abandoned. To further promote SAFs in the US, the Biden Administration launched a ‘SAF Grand Challenge’ in 2022 to rapidly increase US SAF production to at least 3 billion gallons/year by 2030, an increase from just 4.5 million gallons/year in 2021. The US Inflation Reduction Act also proposed two tax credits to incentivize the production and uptake of SAFs.
The IPCC 2022 report concluded that the finite availability of land, growing demands for food, feed, and fuels, exacerbated by a necessary fossil fuel phase-out, will create major competition for land. Increased demand for biofuels, anticipated at 11% a year under the International Energy Agency’s Net Zero Scenario, may motivate the conversion of land to energy crop plantations (direct land use change), or food-and-feed crops may be redirected to biofuel markets, creating a domino effect as agriculture expands to replace this loss; indirect land-use change (ILUC).
The IPCC report also finds that large-scale production, high expansion rates (12.5.3, 1299), monocultures of biofuel crops (6.4.2.6, 645), and the cultivation of oil, sugar, and starch crops (12.5.3, 1299- 1300) heighten the risk of land-use change - increasing the fuels' lifecycle emissions and depleting its climate change mitigation potential (12.5.3, 1299- 1300). These factors are also associated with the displacement of natural ecosystems and reduced biodiversity (12.5.3, 1299). The IPCC finds that growing dedicated bioenergy crops “raises a broad set of sustainability concerns” (6.4.2.6, 643) and may be “incompatible with net-zero emissions in some contexts” (6.4.2.6, 646). Consequently, safeguards are necessary to limit the impacts of bioenergy production on carbon stocks (7.6.3, 823), alongside a scale-up of advanced biofuels (6.4.2.6, 644).
The current state of the US corn sector appears to embody the IPCC’s highlighted risks; A March 2022 ICCT publication found that biofuel production uses 40% of corn produced in the US, diverting crops from food markets and leading to agricultural expansion through deforestation and destruction of other natural lands domestically and internationally. Similarly, Lark et al 2 concluded that incentivized biofuel use under the US Renewable Fuel Standard expanded total cropland by 2.4%. Consequently, academics such as Becken et al. argue that SAF production “undermines” the goal of limiting temperature rise to 1.5°C 3.
The IPCC report does recognize that agricultural practices, such as cover crops, intercropping (12, Cross-Working Group Box 3, 1307-1311), and the use of degraded/marginal lands (12.5.3, 1302) can enhance carbon sequestration (the process of storing atmospheric carbon dioxide in soils and other geologic formations) and reduce emissions from biofuel production (12, Cross-Working Group Box 3, 1307-1311). However, the impact of these solutions is highly contextualized (12, Cross-Working Group Box 3, 1307-1311) with ill-deployment potentially causing carbon losses (7.4, 800). Therefore, governance has a “critical influence on outcome” (12.5.3, 1299), and ensuring additionality (carbon sequestration above business as usual), addressing the non-permanence of carbon sequestration, and monitoring and verification of emissions reduction are key governance issues (12.5.4, 1303-1304).
While there is scientific consensus on the need to rebuild carbon stored in soil 4, scientific literature indicates that there is significant uncertainty in understanding the impact of agricultural practices on carbon sequestration in soil 5. This uncertainty results from 3 key factors:
Sequestration is dependent on variable conditions: Bradford et al. concluded that the rate and total amount of carbon sequestration possible is dependent on conditions, such as soil moisture, texture, and slope. Therefore, the impact of management practices will differ and are hard to predict 4.
No scientific consensus on measuring changes over time: Soil carbon is also slow to accrue, and it may take years to detect a change in response to intervention4. Consequently, detailed site-specific data is needed for environmental models but, Tonitto et al. highlighted that models don’t generally provide accurate estimates for a single field6. Oldfield et al. indicated that there is not yet a standard approach to measuring soil carbon changes, or a defensible business-as-usual baseline estimation of emissions7.
Research trials are unlikely to represent actual practice: Tautges et al. highlighted that agricultural research trials estimating soil organic carbon may not reflect actual farm practices 8. An example of this is shown in a June 2021 ICCT article which determined that cover crops, often presumed as a positive agricultural management practice, may cause ILUC emissions by displacing other crops, necessitating agricultural expansion.
Indirect land use change (ILUC) emissions cannot be measured directly, as it is a domino effect caused by changes in demand, so researchers have developed systems of modeling to simulate how an agricultural system may react. Since it predicts future outcomes, modeling is intrinsically uncertain and employs numerous assumptions 9 on the behavior of environmental and economic systems. Variations in these assumptions can significantly alter the magnitude of estimated ILUC emissions.
The Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) model can be used to analyze the lifecycle emissions from SAF production and use. In addition, the UN body for aviation, the International Civil Aviation Organization (ICAO), has also developed a methodology to determine the lifecycle emissions of SAFs under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). Each of these methodologies employs different models, with different assumptions, which result in widely divergent estimations for lifecycle emissions from SAFs derived from corn-based ethanol. The ICAO CORSIA methodology was approved by the ICAO Council, a permanent body composed of 36 member states, and is the proposed methodology under US federal policy.
A key difference between GREET and ICAO CORSIA is whether the conversion of cropland pasture (land that was previously cropped but is currently in a pasture state) to corn cropping results in carbon sequestration. GREET’s default module to determine emissions from land conversion is the ‘Carbon Calculator for Land Use Change from Biofuel Production’ (CCLUB). This module finds carbon sequestration from such land conversion. In contrast, the models employed under the ICAO CORSIA methodology assume carbon is lost during this conversion, producing significantly higher estimated emissions. The favorable assumption employed in CCLUB differs from academic literature, including a June 2020 academic article by Malins10 which suggests CCLUB underestimates carbon emissions from biofuel production. The GREET tool does provide the option to use ICAO CORSIA’s estimates, however opting for this would calculate less optimistic estimations of lifecycle emissions from corn ethanol.
A second difference between GREET and ICAO CORSIA is the accreditation of carbon sequestration in soil from the use of agricultural management practices, such as cover crops, no-tillage agriculture, and improved fertilizer practices, during SAF production. To consider agricultural management practices, GREET includes a tool that allows producers to select the relevant practices used, often reducing the final estimation. There is a risk that this would enable producers to select practices that reduce SAF’s calculated emissions despite the estimated benefits not being reflected in real life (See section 1.2), particularly as sequestration is often reversed by climate variability and land use. The GREET tool does not mandate the use of monitoring, reporting, or verification (MRV) protocols, which, in the absence of it is impossible to ensure permanence or additionality of carbon sequestration.
In comparison, the ICAO CORSIA methodology sets default values and MRV protocols to safeguard against the misuse of reduced estimates. Under the ICAO CORSIA methodology, 1st generation biofuels, such as corn ethanol, have to comply with ‘Low Land Use Change (LUC) Risk Practices’ criteria to reduce estimated lifecycle emissions from agricultural management practices. This protocol sets measurable criteria which ensure SAF production avoids demand-induced land use change and accounts for any decrease in the available feedstock for food and feed purposes. From 2024, SAFs must also meet additional sustainability criteria (including land use rights, water, soil, and food security). IATA, the global industry association for airlines, describes the ICAO CORSIA criteria as a “key point of reference to identify viable feedstock for SAF”.
| GREET | ICAO CORSIA | |
|---|---|---|
| Cropland pasture to corn cropping conversion | The default module finds carbon sequestration during land conversion | Assumes carbon losses during land conversion |
| Carbon sequestration from agricultural management practices | Producers input the practices used, altering estimated emissions by the assumed sequestration. Monitoring, measurement, or verification protocols are not mandated. | To credit sequestration, producers must meet measurable criteria to ensure SAF production avoids demand-induced land-use change and a loss of food-and-feed crops. |
This chapter analyzes the climate policy engagement of the companies and industry associations covered in this analysis. The chapter summarizes how industry has stated top-line support for carbon neutrality and SAFs while opposing real-world policies to decarbonize aviation and protect land-based carbon stocks.
InfluenceMap's methodology uses seven publicly available data sources to gather evidence of company and industry association engagement on a range of climate and land-use-related policy streams. This analysis results in 5 metrics describing each entity's overall policy engagement.
Performance band (A+ to F): a full measure of a company's climate policy engagement, accounting for its engagement and that of its industry associations. A+ indicates full support for Paris-aligned climate policy, with grades from D to F indicating increasingly obstructive policy engagement.
Engagement Intensity (0-100): measures the level of policy engagement, with scores above 12 indicating active engagement, and scores above 25 indicating strategic engagement.
Relationship score (0 to 100): expresses how supportive or obstructive the company’s industry associations are towards climate policy aligned with the Paris Agreement, with scores under 50 indicating misalignment.
Organization score (0-100): expresses how supportive or obstructive the company is towards climate policy aligned with the Paris Agreement.
Land-Use Engagement Score (Red, amber, and green): expresses how supportive or obstructive the company is towards land-use policy aligned with IPCC science, with red indicating negative engagement, amber representing mixed, and green indicating positive engagement.
Industry is negatively engaged on measures to protect and enhance land-based carbon stocks. Company and industry associations' low land-use engagement scores highlight their obstructive engagement on the sustainability criteria for SAFs under US policy. InfluenceMap found no evidence of engagement on land-use by JetBlue.
| Entity | Performance Band | Engagement Intensity (Global) | Relationship Score | Organization Score | Land-use Engagement Score11 |
|---|---|---|---|---|---|
| Renewable Fuels Association | C | 32 | K.A. | 63 | |
| Southwest Airlines | C | 10 | 39 | 66 | |
| JetBlue Airways | C- | 14 | 41 | 62 | |
| American Airlines | C- | 26 | 40 | 68 | |
| United Airlines | D+ | 32 | 37 | 57 | |
| Delta Air Lines | D | 26 | 35 | 51 | |
| Airlines for America | D- | 34 | K.A. | 40 |
11 While InfluenceMap has analyzed lobbying around this issue, the final scores only minimally contribute to entity's Organization Score. InfluenceMap is in the process of increasing this contribution in 2023.
Recently, the US aviation sector and Renewable Fuels Association (RFA) have expressed top-line support for net-zero carbon emissions by 2050, while promoting SAFs as a critical source of aviation’s decarbonization to reach these goals.
All companies and industry associations support carbon neutrality targets. A4A applauded ICAO for endorsing a 2050 net-zero goal for international aviation emissions in an October 2022 press release. In July 2022 consultation responses, RFA expressed support for New York’s 2050 carbon neutrality goal and California’s 2045 carbon neutrality target. JetBlue, Delta, United, American, and Southwest have also expressed support for 2050 carbon neutrality goals.
Industry strongly supports the use of SAFs. An April 2022 joint letter, signed by Southwest, JetBlue, American, Delta, United, A4A, and RFA, described SAFs as “the most critical driver of aviation decarbonization”. In a May 2023 joint letter to policymakers, A4A, RFA, United, Delta, JetBlue, and Southwest advocated for increased investment into bio-SAFs. Airlines also adopted internal voluntary SAF targets; A4A set a shared goal with the Biden Administration of making 300 billion gallons of SAF available by 2030, American, Southwest, JetBlue, and Delta intend to replace 10% of their jet fuel with SAF by 2030 and United plans on tripling SAF use in 2023 to 10 million gallons. A4A, American, Delta, Southwest, and United also work with fuel producers and the Federal Aviation Administration on SAF deployment through the ‘Commercial Aviation Alternative Fuels Initiative‘ (CAAFI). The initiative aims to promote SAFs that offer environmental advantages, energy security, and favorable costs to fossil-based jet fuel.
Airlines appear critical of many other stringent decarbonization policies. In its 2022 10K report, published in February 2023, United appeared to leverage support for SAF incentives to oppose other policies, stating that it would allow more cost-efficient decarbonization than “a patchwork of regulatory requirements, particularly those that require airlines to reduce flights”. In March 2023, Delta supported a lawsuit against the Dutch government’s proposal of an annual flight cap at Schiphol Airport and A4A applauded the court’s decision to reject the Dutch government’s proposal in an April 2023 press release. A4A also advocated for the repeal of the US jet fuel tax on its corporate website in 2021 and questioned the legality of an extension of the EU Emissions Trading Scheme to all flights departing the European Economic Area (EEA) in a June 2022 press release. Furthermore, in an April 2023 consultation response, A4A urged the exemption of airline advertising from the US ‘Green Guides’, which counsels against greenwashing by advising that environmental benefit claims are substantiated and not deceptive.
This chapter summarizes how industry has advocated for amendments to federal policies with the potential to undermine the integrity of sustainability criteria for SAFs, alongside opposing more ambitious reforms to state-level low-carbon fuel standards.
Under the Biden Administration’s 2022 Inflation Reduction Act, the US government proposed two provisions related to SAFs: the SAF-blenders tax credit and the Clean Fuel Production Credit.
SAF-blenders tax credit: Starting in 2023, the SAF-blenders tax credit will award airlines blending SAFs with jet fuel with a monetary credit. To achieve the base credit ($1.25/gallon) SAFs must achieve a lifecycle GHG reduction of at least 50% compared to conventional jet fuel. Fuels achieving GHG reductions exceeding 50% will receive greater tax credits of up to $1.75/gallon, incentivizing the use of fuels with lower calculated lifecycle emissions. Lifecycle GHG emissions are calculated per ICAO’s CORSIA methodology, or “any similar methodology”. To demonstrate compliance, producers must have a valid certificate from an ICAO-approved sustainability certification scheme. This audit will ensure that calculations are per ICAO’s CORSIA methodology (including ILUC emissions) and that the fuel satisfies ICAO’s CORSIA sustainability criteria.
Clean Fuel Production Credit: From 2025-2027, the Clean Fuel Production Credit (CFPC) will replace the SAF blenders tax credit, crediting SAFs with less than 50 kilograms of carbon dioxide equivalent per million British thermal units (CO2e per mmBTU). Lifecycle emissions are calculated by ICAO’s CORSIA methodology, or “any similar methodology”. The base credit is $0.35/gallon for aviation fuel, multiplied by the "emissions factor" of the fuel, such emissions factors will be published by Treasury. SAFs with lower lifecycle emissions will thus receive larger credits. Similarly to the SAF-blenders tax credit, to demonstrate compliance, producers must have a valid certificate from an ICAO-approved sustainability certification scheme.
Both the airline and renewable fuels industry stated support for federal SAF credits while appearing to advocate for methodologies that are more likely to make corn-ethanol eligible. This is despite the IPCC highlighting the climate risks of 1st generation biofuels.
Industry supports federal SAF tax credits. In a November 2022 Roundtable discussion, an RFA Senior Executive stated support for the federal tax credits and A4A strongly supported both tax credits in a February 2023 US public consultation response. Southwest, JetBlue, American, Delta, United, A4A, and RFA signed a joint letter to policymakers in April 2022 which described the SAF blenders tax credit as the “most important action Congress can take to support the decarbonization of the aviation sector”.
Industry advocated for GREET to be recognized as a “similar methodology” to ICAO’s CORSIA. In a February 2023 consultation response, RFA stated that GREET “clearly meets the intent of Congress” regarding other methodologies that are as robust as ICAO’s CORSIA. RFA echoed this position, describing GREET as the “best choice” in a December 2022 consultation response. A4A advocated for Treasury to allow GREET because it is a “similar methodology” in December 2022 and February 2023 consultation responses.
| GREET | ICAO CORSIA | |
|---|---|---|
| Cropland pasture to corn cropping conversion | The default module finds carbon sequestration during land conversion | Assumes carbon losses during land conversion |
| Carbon sequestration from agricultural management practices | Producers input the practices used, altering estimated emissions by the assumed sequestration. Monitoring, measurement, or verification protocols are not mandated. | To credit sequestration, producers must meet measurable criteria to ensure SAF production avoids demand-induced land-use change and a loss of food-and-feed crops. |
In an April 2023 Reuters article, RFA President, Geoff Cooper, stated that the ethanol industry must look for “new uses and new markets…to grow our industry and its value”. Following years of stagnant demand for corn-based fuel, aviation offers a potential new market. Yet to gain subsidies from federal policy, ethanol must fall below the GHG emissions threshold, with additional emissions reductions achieving greater tax credits. Many airlines and fuel producers have ethanol-based SAF agreements. Gevo, which produces SAF using corn feedstock, has large offtake agreements with American and Delta. United Airlines has partnered with Virent, a subsidiary of Marathon Petroleum, which uses corn, among other feedstocks, to produce SAF. However, corn-based SAF is unlikely to meet the policies' thresholds through the ICAO CORSIA methodology which calculates similar lifecycle emissions for corn grain-based SAF and fossil jet fuel.
The aviation and biofuel industries appear to be working together to push a coordinated advocacy response to federal SAF policies through the ‘SAF BTC Coalition’, whose membership includes American, Delta, Southwest, United, A4A, and RFA. See Appendix B for a full list of members, including CAAFI members.
The SAF BTC Coalition appeared to support amendments favorable to crop-based SAFs by advocating for producer-determined emissions estimates, calculated through GREET, which does not mandate the use of monitoring, reporting, or verification (MRV) protocols, which, in the absence of it is impossible to ensure permanence or additionality of carbon sequestration. In a December 2022 consultation response on the Clean Fuel Production Credit, the SAF BTC Coalition advocated for the GREET tool, alongside recommending that Treasury “simply approve” producer-determined values for fuels when producers can “demonstrate better lifecycle emissions reductions” than published pathways determined by Treasury. Through GREET these lower values may be achieved through crediting agricultural practices (Appendix A, Table 1) or CCLUB (which results in optimistic estimations of corn-based SAF's emissions, which deviate from ICAO CORSIA estimations).
In a February 2023 consultation response on the SAF blenders tax credit, the coalition again promoted GREET, advocating for methodologies that “recognize farm-level reductions from biofuel feedstocks”, suggesting support for the accreditation of agricultural practices. Lower estimations of a fuel's emissions may meet policy thresholds and translate to larger tax credits under federal policy, thus incentivizing the fuels. The accuracy of such estimates and the permanence of carbon sequestration is uncertain, however, through their advocacy for GREET, the coalition appeared to support a system lacking MRV or additionality and permanence safeguards, as required under ICAO’s CORSIA methodology.
While both tax credits require third-party certification to audit and ensure producers comply with the policy’s sustainability requirements, the coalition appeared to advocate for programs with compliance standards that differ from ICAO-approved sustainability certification schemes. The coalition stated certification requirements should be interpreted “broadly” and allow the use of “non-CORSIA programs administered by RSB, ISCC, and others”, in February 2023 and December 2022 consultation responses. Audits and certification by non-CORSIA programs by the Roundtable of Sustainable Biomass (RSB) and International Sustainability and Carbon Certification (ISCC) do not require the same criteria as the ICAO-approved programs run by these organizations, namely the programs don’t appear to explicitly audit ILUC or some principles under ICAO’s additional sustainability criteria. RSB clarifies that in its criteria for meeting a 50% GHG reduction relative to fossil fuel emissions, the lifecycle analysis only includes direct land-use change, excluding ILUC. Furthermore, the advocacy for “other” certificates may incentivize a race to the bottom, as certification, and therefore eligibility of fuels under federal policy, is more likely in programs with weaker criteria.
RFA appears to support amendments that are favorable to crop-based biofuels and diverge from the methodology agreed upon by ICAO. In a December 2022 consultation response on the Clean Fuel Production Credit, RFA appeared supportive of the Carbon Calculator for Land Use from Biofuel Production (CCLUB) model, asserting that CCLUB has “advantages over other approaches”. CCLUB employs a more optimistic assumption to ICAO’s CORSIA methodology by assuming carbon is sequestered during the conversion of cropland pasture to cropland, reducing corn’s calculated emissions. This is demonstrated in RFA’s February 2023 consultation response on the SAF blenders tax credit, in which RFA stated that SAF production provides a “major new market opportunity for ethanol producers” and emphasized that CCLUB estimates corn ethanol’s ILUC emissions at 5.4 grams of CO2 equivalent per Megajoule (gCO2e/MJ). This value is significantly lower than through ICAO’s CORSIA methodology, which was approved by the ICAO Council consisting of 36 member states, and calculates US corn grain ILUC emissions as 22.1-25.1 gCO2e/MJ. Using CCLUB, corn ethanol is far more likely to meet the SAF blenders tax credit’s 50% GHG reduction threshold than ICAO’s CORSIA methodology, which finds that corn grain’s total emissions are almost equal to fossil jet fuel. Therefore, despite promoting GREET as a similar methodology to ICAO’s, RFA is promoting an advantageous assumption under the GREET model that produces widely different results.
RFA appears to advocate for weaker safeguards on crediting land management practices. Despite significant scientific uncertainty on the measurement of soil carbon changes resulting from agricultural practices, in a December 2022 Clean Fuel Production Credit consultation response, RFA argued that producers should be able to submit their own estimated values (rather than values published by Treasury) that include “upstream emissions reductions resulting from the use of more efficient agricultural practices”, asserting that such practices can be “accurately documented” through GREET. Regarding the SAF blenders tax credit, RFA appeared to advocate for weaker safeguards on the accreditation of agricultural practices than ICAO’s globally approved methodology, which sets default values, and specific criteria to ensure claims are permanent, additional, and undergo MRV. In a February 2023 consultation response, RFA advocated for GREET, because it allows producers to “submit unique, differentiated data” on feedstock production and “evaluate” the emissions reduction potential of production pathways, rather than an “overly generalized ‘one size fits all’ approach”. Importantly, GREET does not mandate MRV. Therefore, regardless of uncertainties surrounding carbon sequestration (see Section 1.2), RFA appeared to advocate for producer-determined values that credit agricultural management practices. This will likely reduce calculated emissions, potentially enabling fuels to meet policy thresholds without needing to comply with MRV protocols.
Advocacy by industry could result in the expansion of fuels with significant land-use change risks. A retrospective study by Lark et al12 on the Renewable Fuel Standard (RFS) (which necessitated fuels achieve a 20% GHG emissions reduction relative to gasoline) found the policy led to a rapid expansion of US corn production, causing large land-use change related GHG emissions, compared to a scenario without the RFS. The study concluded that incorporating more conservative estimates of ILUC emissions annulled or reversed the GHG advantages posed by corn ethanol.
The incentivization of corn ethanol through federal SAF tax credits, which according to calculations made by the biofuel industry is more likely through CCLUB and accreditation of agricultural practices, may compound these consequences by adding to global corn demand. This outcome has been cautioned by ICAO which concluded that “promoting crop-based SAF may encourage cropland expansion and cause GHG emissions from land use change…which may become a global phenomenon that goes beyond the regions expanding biofuels production”. This is alongside the IPCC’s assertion that 1st generation biofuels have limited climate change mitigation potential, exacerbated by high expansion rates (AR6 WGIII, 12.5.3, 1299- 1300). Therefore, underestimating emissions may result in the expansion of fuels that fall short of the policies’ intended GHG savings and potentially cause land conversion and consequential GHG emissions, which take a long time to be re-sequestered in natural resources 13. Yet, industry appeared to advocate for methodological practices which are more likely to underestimate GHG emissions from fuel production.
12 Lark, Tyler J., Nathan P. Hendricks, Aaron Smith, Nicholas Pates, Seth A. Spawn-Lee, Matthew Bougie, Eric G. Booth, Christopher J. Kucharik, and Holly K. Gibbs. “Environmental Outcomes of the US Renewable Fuel Standard.” Proceedings of the National Academy of Sciences 119, no. 9 (March 2022): e2101084119.
13 Susanne Becken, Brendan Mackey, David S. Lee. “Implications of preferential access to land and clean energy for Sustainable Aviation Fuels.” Science of The Total Environment, 886 (2023) . https://doi.org/10.1016/j.scitotenv.2023.163883.
In comparison to the US, European airlines have advocated for more stringent sustainability criteria for biofuels. The ReFuelEU Aviation initiative promotes SAFs by incrementally increasing a SAF blending mandate and an additional sub-mandate for synthetic e-kerosene. In June 2022, the European Parliament proposed an expansion of ‘green jet fuel’ to biofuels produced from animal fats or distillates and recycled carbon fuels, from the Commission’s classification which includes electro-fuels and 2nd generation biofuels. Food-and-feed-based biofuels are excluded due to concerns regarding their contribution to international deforestation. According to a June 2022 Euractiv article, Airlines for Europe (A4E) expressed concerns that the expansion could “lead to the inclusion of non-sustainable feedstock for another decade”, undermine support for SAFs, and erode confidence in the aviation industry’s decarbonization efforts. A4E further tweeted in April 2023 that SAFs “cannot be produced at the expense of food supplies for people or animals or damage the environment through deforestation”. In July 2022, easyJet signed a joint letter calling on Parliament to exclude fuels with links to deforestation and food price increases, and advocated for the more stringent European Commission’s definition to be applied.|
On a global scale, the eligibility of SAFs under CORSIA (the only measure to apply to international aviation), is determined by the methodology devised by ICAO. IATA appears supportive of this criteria. In an April 2023 blog post, IATA stated that 1st generation feedstocks face “challenges to prove and uphold the industry’s identified sustainability criteria” and that industry is “intent on ensuring feedstocks associated with deforestation, food-chain competition and biodiversity loss, are not incorporated within its viable feedstock mix”.
California’s Low Carbon Fuel Standard (LCFS) and Oregon’s Clean Fuels Program (CFP) are technology-neutral market-based mechanisms that aim to reduce the lifecycle carbon intensity of the transportation fuel mix. Each year, a level of carbon intensity for transportation fuels is set, which is annually lowered. Only fuels with lower lifecycle GHG emissions would meet the yearly threshold. Fuels exceeding the annual threshold generate credit deficits, while fuels falling below generate surplus credits. Producers generating deficits must purchase credits to offset emissions exceeding the benchmark. Both measures originally applied to diesel and were subsequently extended to include jet fuel on a voluntary opt-in basis in 2019, setting a benchmark specific to SAFs. California and Oregon refer to SAF as ‘Alternative Jet Fuel’, which includes any fuel produced from petroleum or non-petroleum sources, with eligibility dependent on the threshold.
The ICAO, the UN body for international aviation, calculated a baseline for conventional jet fuel of 89 gCO2e/MJ.
California: SAFs are subject to a static benchmark of 89.37 gCO2e/MJ until 2023 (Appendix C), then the benchmark will begin to annually decrease. The California Air Resources Board (CARB) has periodically considered amendments to the LCFS, including a revision of the annual benchmarks, the mandatory inclusion of intra-state jet fuel, and a cap on biofuels produced from food crops.
Oregon: SAFs are subject to a static baseline of 90.8 gCO2e/MJ until 2024. In 2022, Oregon considered extending benchmark reductions beyond 2025. The draft proposal applied a 20% reduction to the benchmark by 2030 and a 37% reduction by 2035. The same incremental decreases are applied to diesel under the draft proposal, however, due to different initial baselines, SAFs would be subject to lower yearly baselines than diesel (Appendix D). In the notice of proposed rulemaking, the incremental reductions for SAFs had decreased, making yearly benchmarks equivalent to diesel’s higher annual benchmarks (Appendix D).
Despite initiating a “shared goal” with the Biden Administration of making 3 billion gallons of SAF available by 2030, A4A appears to oppose reforms to increase the ambition of state-level fuel policies.
A4A advocated for less stringent benchmarks for SAF in Oregon: In June 2022 comments on Oregon’s CFP Expansion, A4A opposed the 20% and 37% reductions, instead advocating for equivalent yearly benchmarks to diesel, increasing the yearly benchmarks for SAF (Appendix D). Consequently, SAFs with higher GHG emissions associated with their production would be eligible for credits. Following the adoption of A4A’s recommendations in the notice of proposed rulemaking, A4A supported the amended, weaker annual benchmarks for SAF (Appendix D), in July 2022 comments on Oregon’s CFP Expansion. The new benchmarks allow fuels with an additional 4.9-6.84 gCO2e/MJ each year to generate credits. A4A further advocated for higher benchmarks for SAF for 2023-2024 to equivalent benchmarks to diesel in July 2022 comments, increasing the baseline in both years to values further exceeding ICAO’s baseline for kerosene jet fuel, crediting fuels with higher emissions than that of fossil-based jet fuel (according to ICAO’s calculations).
A4A advocated for less stringent benchmarks for SAF in California: In comments on California’s 2022 draft scoping plan, A4A recommended “maintaining the static 2019-2022” benchmark for jet fuel substitutes of 89.37 gCO2e/MJ until 2029 (rather than annual reductions from 2023), due to the “tremendous” quantity of SAF required for decarbonization and lack of other alternatives. This would result in a higher yearly benchmark as compounding reductions would not be applied. As with Oregon’s CFP, this would allow fuels with higher GHG emissions associated with their production to generate credits. In 2029, fuels with an additional 7.75gCO2e/MJ could generate credits (Appendix E).
Opposing the mandatory inclusion of intra-state jet fuel under California’s LCFS, questioning the legality of the measure: In June 2022 comments on California’s Draft 2022 Scoping Plan, A4A stated that the California Air Resources Board (CARB) cannot consider the integration of SAF as it conflicts with a superseding federal law, prohibiting CARB from subjecting conventional jet fuel to annually decreasing thresholds regardless of whether it is used for international, interstate or intrastate flights. Similarly, in March 2023 input on the February 2023 LCFS Public Workshop, A4A asserted that the state “lacks authority” to include jet fuel as a required fuel. This position was reiterated in August 2022 feedback on the July 2022 LCFS Public Workshop and January 2022 input on the December 2021 LCFS Public Workshop. Delta disclosed alignment with A4A on this position in its 2022 ESG report. This reflects a pattern of lobbying by A4A for the exemption of aviation from state-level policies, as was urged in October 2022 comments on California’s Advanced Clean Fleets Regulation.
Opposing a cap on crop-based biofuels: In August 2022 feedback on a July 2022 Workshop, A4A urged CARB to refrain from imposing a cap on crop-based biofuels. Similarly, in March 2023 input on a February 2023 Workshop, A4A opposed a cap on crop-based biofuels while acknowledging that “biofuel production must not come at the expense of deforestation or food production”. RFA similarly stated a cap on crop-based biofuels would “chill investment in lower carbon fuel technologies” and have “no impact whatsoever” on food prices, in comments on a July 2022 Workshop.
Advocating for a reduced emissions value for corn ethanol: In comments on a July 2022 Workshop, RFA stated that “the iLUC factor in the LCFS for corn ethanol is overstated and should be adjusted downward”. RFA appeared to advocate for lower values estimated through GREET to be used instead. While acknowledging that “roughly half” of ethanol’s carbon intensity is from agricultural production of the feedstock, RFA argued that agricultural practices “significantly” lower emissions of feedstock production and therefore should be incorporated into calculations of feedstock production, opposing California’s “one size fits all” approach which prohibits producers’ incorporation of such practices. RFA does not appear to advocate for MRV provisions, despite the uncertain impacts of agricultural practices.
State legislators in Illinois, a state with 13 corn-based biorefineries, appear to have first proposed a ‘SAF purchase tax credit’ in November 2022, which failed to pass. The proposal stated that the fuel must achieve at least a 50% reduction in lifecycle GHG emissions as determined by either ICAO’s LCA methodology or another methodology which includes the “the positive induced land use change values” alongside core lifecycle GHG emissions values.
Later in January 2023, a SAF purchase tax credit passed as an amendment to a broader budget bill, enacting a credit of $1.50/gallon for SAFs, which can be combined with the federal tax credit. Until 2028 non-domestic feedstocks can be accredited if the fuel is used in Illinois. However, unlike the November 2022 bill, the passed amendment specified that the fuel must achieve at least a 50% reduction of lifecycle GHG emissions values “utilizing the most recent version of Argonne National Laboratory’s GREET model, inclusive of agricultural practices and carbon capture and storage” and does not explicitly include ILUC emissions, weakening the sustainability criteria of the policy. American, United, and Southwest were proponents of the amendment. Notably, no identifiable representatives from the NGO or academic community were present at the hearing.|
In a February 2023 email to an Illinois Governor, obtained by Freedom of Information request, United stated that SAF usage “is now targeted for our Chicago hub because of the SAF credit”.
1 Adapted diagram from EUbioenergy
2 Lark, Tyler J., Nathan P. Hendricks, Aaron Smith, Nicholas Pates, Seth A. Spawn-Lee, Matthew Bougie, Eric G. Booth, Christopher J. Kucharik, and Holly K. Gibbs. “Environmental Outcomes of the US Renewable Fuel Standard.” Proceedings of the National Academy of Sciences 119, no. 9 (March 2022): e2101084119.
3 Susanne Becken, Brendan Mackey, David S. Lee. “Implications of preferential access to land and clean energy for Sustainable Aviation Fuels.” Science of The Total Environment, 886 (2023) . https://doi.org/10.1016/j.scitotenv.2023.163883.
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