• National Business Aviation Association

Coalition calls on EPA to expand sustainable aviation fuel feedstocks in updated RFS


The coalition of aviation groups says EPA should include woody biomass in the definition of biointermediates.

The General Aviation Manufacturers Association, Helicopter Association International, National Air Transportation Association and National Business Aviation Association, on behalf of the Business Aviation Coalition for Sustainable Aviation Fuel, urged the U.S. EPA Feb. 4 to provide greater opportunities for the development of sustainable aviation fuel (SAF) as it updates the federal Renewable Fuel Standard.


The coalition said that with the right changes, the RFS can go a long way to helping the U.S. meet the Biden administration’s “SAF Grand Challenge” goal of bringing 3 billion gallons of SAF to the market per year by 2030.


In a letter to EPA Administrator Michael Regan in response to a request for comments on a proposed RFS rule, the Business Aviation Coalition for Sustainable Aviation Fuel called on the agency to expand the list of eligible feedstocks, which would make new sources available for biofuels and SAF; approve new process technologies and biointermediate opportunities; and ensure that the volumes for advanced biofuels are set at levels that will allow greater supplies of those fuels.


“We hope EPA and this administration recognize the opportunity for SAF moving forward as part of the RFS program,” the coalition writes in its comments. “The growth in SAF will not happen if EPA does not responsibly improve the regulatory structure of the RFS — by finalizing biointermediates, by updating the opportunities for both feedstocks and technologies, and by increasing the RVO volumes accordingly.”


Click here to review the full letter.


EPA should ensure that municipal solid waste and woody biomass are included in the definition of biointermediates, according to the coalition.


On the volumes, the coalition asked EPA to ensure that cellulosic, noncellulosic advanced, and biomass-based diesel are set at levels that will increase the volumes of each of these fuels to help support the SAF market.


Congress created the RFS program in the Energy Policy Act of 2005 and later expanded it in the Energy Independence and Security Act of 2007 to reduce the nation’s reliance on imported oil and greenhouse gas emissions.


“The RFS has been driving growth from biofuels and accomplishing what creators of the program aimed for—deployment of domestic, ultra-clean renewable fuel,” the coalition writes. “For this success to continue, certainty must be provided to the market. Congress sought to provide this certainty through the RFS program and EPA should provide that certainty through the regulatory process.”


In addition to working with EPA, the coalition is collaborating with the White House, U.S. Department of Transportation, U.S. DOE, and Federal Aviation Administration on the “SAF Grand Challenge.” The coalition will continue its efforts to educate key government, industry, and community stakeholders on the value of SAF in achieving shared environmental goals.

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