Growth Energy sent a letter to the U.S. Department of the Treasury on implementation of Inflation Reduction Act of 2022 (IRA) tax credits for sustainable aviation fuel (SAF). In her letter, Growth Energy CEO Emily Skor calls on regulators to ensure that policies reflect the most updated and accurate science-based lifecycle carbon assessment (LCA) methods, specifically those in the U.S. Department of Energy’s Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) model.
“Harnessing the U.S. ethanol industry – which at 17.4 billion gallons per year accounts for over 80% of biofuels production capacity in the U.S. – will be necessary to achieve these goals because ethanol is one of the few readily available feedstocks for SAF production,” wrote Skor. “Growth Energy appreciates Treasury’s consideration of this input as it implements the IRA’s tax credit provisions in a manner that ensures the best available science is used to calculate eligibility for and amount of credits.”
“Indeed, several provisions of the IRA mandate use of GREET to calculate the LCA for other transportation fuels, such as hydrogen. Notably, these provisions require the use of GREET for other transportation fuels and hydrogen reference the same definition of ‘lifecycle greenhouse gas emissions’ under the Clean Air Act as the IRA’s SAF provisions. In addition, EPA utilized GREET, along with other models, to implement the RFS program’s major expansion in 2010. Multiple states that lead the nation on climate change regulation, including California and Oregon, also use GREET for evaluating lifecycle emissions of biofuels,” wrote Skor.
Unlike GREET, the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) which has been adopted by the International Civil Aviation Organization (ICAO), does not reflect the latest science.
“Modeling techniques have improved considerably in recent years due both to improvements in the models and improvements in the accuracy of inputs. For example, older LCA models failed to account for the ability of intensification (increasing crop yield) rather than extensification (increasing crop acreage) to meet increases in demand,” she wrote.
“U.S. tax policy should not tie itself to international aviation safety organizations that are far less experienced and sophisticated in biofuels LCA modeling than the U.S. Department of Energy’s National Laboratories,” concluded Skor.
The full letter to Treasury is available here.