A North Star for Sustainable Aviation: Science, People and Nature.

By Pedro Piris-Cabezas and Glenda Chen

The Biden administration has worked to keep its promise to follow the science in dealing with challenges like housing, COVID, air pollution — and especially climate change. The next major test is coming soon. The Treasury Department is preparing to issue guidelines about which alternative fuels will qualify for federal refundable tax credits for sustainable aviation fuels created by last year’s Inflation Reduction Act.

Getting it right is crucial because aircraft emissions are a significant and escalating source of climate pollution — and because not all fuels are created equal. If the administration steers by its own evidence-based decision-making standards, the new tax credits could jumpstart a SAF revolution. But offering taxpayer-funded subsidies for the wrong biofuels could actually trigger a spike in unchecked greenhouse gas emissions, along with irreversible harm to people and nature.

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This is one of those moments where the details matter a lot. Using scientific rigor and a forward-looking mindset to get this decision right will have a decisive impact for decades to come. It’s crucial that federal tax credits reward only high-integrity fuels that contribute sustainably to mitigating climate change.

Relying on existing corn or other farm feedstocks to hurriedly scale up aviation biofuels could unleash more greenhouse gases than the resulting fuel would save. That’s because producing land-based fuels in the U.S. to meet fast-growing demand requires enormous volumes of agricultural products — which translates into massive destruction of forests and grasslands around the world as well as sweeping hunger and malnutrition that aggravate climate-induced migration. Far-reaching market forces will drive land competition between croplands and natural lands into a dangerous global phenomenon that proliferates beyond the borders of current biofuel-producing countries.

And offsetting the resulting surge in emissions by reducing other sources of lifecycle emissions with carbon capture and storage projects and the like — as some have proposed — won’t undo the devastating consequences to pristine ecosystems and vulnerable communities around the world. Nor will any dubious carbon credits, such as those relying on indirect book-and-claim accounting within the fuel’s lifecycle analysis; that accounting involves claiming environmental attributes unrelated to the fuel’s own physically embodied process inputs.

In other words, land conversion is a multi-headed beast: counting only its induced greenhouse gas emissions while ignoring its broader environmental and social impacts profoundly misses the point of the sustainability principles that are foundational to dealing with climate change. The SAF market needs to develop swiftly but not haphazardly.  Deploying alternative fuels without effective social and environmental safeguards would be a recipe for disaster, in the U.S. and around the globe.

Getting federal policy right today will also help encourage private sector research and development into breakthrough innovations that can propel climate-friendly fuel production at scale. Investing in transformative technologies with high integrity, rather than flooding the market with short-term production of the wrong biofuels, will open doors for the SAF supply to realistically meet mid-term and long-term demand. Rather than tipping the scales in favor of bio-based fuels that defeat their own purpose of climate action, we need to let ultra-low-carbon fuels gain a foothold in the market — like electrofuels that are manufactured from captured carbon dioxide and renewable electricity.

The Biden administration has a unique opportunity to take the reins in constructing a truly performance-based and future-proof standard that bolsters the U.S.’s track record of environmental leadership. Generating a level playing field for all pathways to compete on equal footing will pave the road for the aviation sector’s successful decarbonization.

But failing to capture the moment will lock vast volumes of harmful low-integrity SAF into the system for decades to come — a menace that we cannot afford, and an outcome counterproductive to the aviation sector’s own interests. To avoid falling twice on the same sword, the administration needs to take lessons learned from the past decade’s investment in ground transportation biofuels and shift the focus away from production pathways that have dangerous side effects.

The Biden administration’s chance to avoid a one-step-forward, two-steps-back mistake.

To implement the SAF tax credits, the IRA mandates that the Treasury Department develop a lifecycle assessment methodology — intertwined with a sustainability framework — to determine which fuels are eligible and quantify the dollar amount of the tax credit.

At all costs, the Treasury Department must not water down standards that are the central navigation compass for aviation’s climate efforts. Regulators need to reject misinformation that ignores scientific fundamentals and seeks to deflect responsibility. The Department’s task now is to honor Congress’s decision to codify guardrails against unintended adverse consequences — in order to avoid a glaring loophole that would frustrate the sector’s battle against climate change.

The Details Matter: Where policymakers need to focus now.

Getting it right entails no small number of issues. To secure a vital earth for all, federal regulators need to design guidance that considers the full array of environmental and social outcomes associated with SAF production. These three design elements are top priority:

  1. Prevent “domino effect” harm to vulnerable communities and ecosystems. Scaling up farmland from food to SAF production can’t be done at the expense of ecosystems and communities in the U.S. and around the world. If a thousand-acre farm in Wisconsin converts to SAF production as a result of IRA subsidies, we must avoid domino effects at the global scale that lead to the destruction of irreplaceable forest land, grasslands or wetlands, alongside food staples price spikes that rob food from communities already facing climate struggles. (And repurposing agricultural feedstocks from the road fuel sector to the aviation sector won’t magically erase those domino effects on a planet of population growth and rising food demand.) The good news is that operational screening tools and methods already exist to identify and mitigate such unintended consequences. For instance, U.S. policy makers could easily build on and enhance the existing methodologies under the international standard adopted by United Nations’ International Civil Aviation Organization, as the European Union has done.
  2. Check the credentials of wastes, residues and by-products. Another proposed alternative, scaling up SAF production by converting wastes, residues and byproducts,  would still require significant amounts of land-based feedstocks. Because these waste materials are currently used in products like pet food and cosmetics, the ripple effects of diverting them to SAF production will be a stepped-up use of virgin vegetable oils like palm oil, which have an egregious track record of rainforest destruction and peatland degradation. And in addition to this environmental and social exploitation, the associated greenhouse gases released can easily multiply net emissions several-fold compared to fossil jet fuel. The good news is that here too, operational methodologies and standards exist to curb these ripple-effect hazards. But the fuel producer should carry the burden of proof: only those who can demonstrate harm-free credentials should be entitled to fat taxpayer subsidies.
  3. Soil carbon and biomass sequestration credits aren’t ready for takeoff. Soil carbon and living-biomass credits reward farmers for enhancing soil carbon sequestration through practices such as crop rotation, no-tillage, cover crops, and perennial cultivation.  Done right, the practices can help cut agricultural emissions — but handing out public dollars for such non-permanent carbon storage right now would be premature, and there is not yet a standard approach to measuring soil carbon stock changes over time. No soil carbon sequestration or biomass sequestration should earn bonus points until a credible, cost-effective and consistent methodology addressing those uncertainties has been developed and approved.

Regulators, fuel producers, airlines, investors, companies and citizens can find more detailed guidance on these core issues in EDF’s High-Integrity SAF Handbook, a resource based on eight years of research and analysis. The Handbook was produced for this pivotal moment — to help decision makers create policies supporting high-integrity SAF without dangerous side effects, and to catalyze smart, foresighted steps for the aviation sector’s transition to cleaner skies.

We can’t afford to trade one environmental threat for another. With the right federal guidance, the guardrails written into the IRA can reinforce our collective responsibility to deliver on deep decarbonization and public health goals in harmony with ecological conscience, human rights, and equitable sustainable development aims.

The Treasury Department’s upcoming decision offers a golden opportunity to lay down the foundation for the high-integrity SAF needed to make real progress in transforming the aviation sector’s outlook for climate action. Reducing aircraft emissions is urgent, but the administration must navigate responsibly or risk veering dangerously off course. As it has before, the Biden administration needs to put sound science, nature and people first.

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