Thank you for the opportunity to comment on the agency’s proposed particulate matter (PM) emission standards and test procedures for jet engines. Growth Energy is the largest renewable fuel organization in the world representing 89 of the most innovative biofuel producers and thousands of biofuel supporters. Our diverse membership is committed to reducing emissions from aviation and is energized by this new aviation frontier to help the U.S. meet aggressive climate and pollution reduction goals in the hard to electrify sector.
As the proposal and studies show, there are numerous negative health and environmental impacts from PM emissions from combustion in mobile sources. Low-carbon, plant-based biofuels are among the best and most cost-effective options for reducing both PM and greenhouse gas emissions in mobile sources including the aviation sector.
U.S.-based airlines used more than 18 billion gallons of jet fuel in 2019
. Accessing the aviation
market through ethanol to sustainable aviation fuel (SAF) provides America’s bioethanol industry
the opportunity to be utilized in more than just light-duty cars and trucks all while contributing to
the rural economy and improving air quality.
As we have already seen with higher biofuel blends and light-duty vehicles, the use of
sustainable aviation fuel (SAF) holds tremendous potential for reducing air pollution and
improving our air quality. Ethanol to jet fuel as SAF has the potential to replace 50% of the
petroleum used in jet fuel. While, thus far, the discussion has focused on the ability of SAF to
“Airline Fuel Cost and Consumption (U.S. Carriers – Scheduled),” Bureau of Transportation Statistics: OST_R | BTS |
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significantly reduce greenhouse gas emissions to address climate change. However, there has
been a great deal of research to show the reductions in other harmful pollutants through the
expanded use of SAF including for this comment, PM emissions.
A recent project from the Airport Cooperative Research Program for the National Academies of
Science, Engineering, and Medicine on alternative jet fuel emissions, compiled SAF emissions
data from 51 technical publications and then validated the expected results.
analysis shows that at a 50% blend, SAF can reduce PM emissions by nearly 70%, sulfur by
37%, and carbon monoxide by 11%. These are meaningful reductions that would be a win-winwin for our environment, human health, and for our rural economy.
Source: National Academies of Science, Engineering, and Medicine: “State of the Industry Report on Air Quality
Emissions from Sustainable Alternative Jet Fuels”
With the appropriate investment in critical research and development, and the right policy
environment, our industry can work to remove these harmful emissions from our aviation fleet.
However, to achieve the Biden Administration’s goal of three billion gallons of SAF production by
2 National Academies of Science, Engineering, and Medicine, “State of the Industry Report on Air Quality Emissions from
Sustainable Alternative Jet Fuels”, April 2018: State of the Industry Report on Air Quality Emissions from Sustainable
Alternative Jet Fuels | Blurbs New | Blurbs | Publications (trb.org)
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2030 and 35 billion gallons by 2050 to achieve net-zero GHG emissions in aviation, we will need
To make our emission reduction goals a reality, we need a healthy and thriving biofuel industry
to be able to make the long-term investments in research and development. Specifically, we
offer several important recommendations for the agency:
1. A strong and growing Renewable Fuel Standard (RFS): To reach the volumes being
discussed, it is critical to have the solid foundation of the RFS. As we recently outlined in
our submission, the agency must move as quickly as possible to fix the flaws and finalize
its proposed renewable volume obligation (RVO) for 2020 – 2022 and continue robust
growth in renewable fuels into the future.3
2. Accurate life-cycle emissions modeling: We strongly support the use of the Department
of Energy’s Argonne National Laboratory’s GREET model which appropriately accounts
for innovations in American agriculture and biofuel production. Use of the GREET model
is best suited to assess American-made SAF from bio-based feedstocks.
3. Prioritizing Fuel Quality: As the agency considers PM emission standards for aircraft
engines, it should examine and prioritize the benefits that can be achieved through the
use of SAF. As has been researched, simply working to expand and maximize the use of
SAF can significantly improve air quality and reduce PM emissions.
The biofuel industry stands ready to work with EPA and the Biden Administration to meet our
national commitments of aggressive emission reduction goals while supporting economic
development, working families, and renewable energy. With forward-leaning policies that
support innovation and access to new markets, our industry can provide aviation fuels that will
decrease emissions, create more clean energy jobs, and spur economic activity in rural
communities today and well into the future.
Thank you for your consideration