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1 1 (December 11, 2024)

handle is hein.crs/goverpx0001 and id is 1 raw text is: Congressional Research Service Informing the legislative debate since 1914 0 December 11, 2024 Sustainable Aviation Fuel (SAF): Production Pathways Many in Congress have expressed an interest in sustainable aviation fuel (SAF)-a nascent industry. SAF may potentially provide market opportunities for both agricultural producers and biofuel producers; it meets international aviation requirements (e.g., ReFueIEU Aviation regulation); and it may satisfy consumer requests for more environmentally-friendly aviation fuel. With these potential opportunities comes potential challenges such as producing a large amount of SAF within a certain timeframe at a preferred cost, satisfying SAF tax credit criteria (e.g., domestic production criteria, lifecycle greenhouse gas emissions reduction criteria), and ascertaining what the primary feedstocks and production pathways for SAF in the United States will be for the near- and long-term. In 2024 both chambers of Congress formed sustainable aviation caucuses: the House Congressional Sustainable Aviation Caucus and the Senate Sustainable Aviation Caucus. SAF must be produced to qualify for SAF government programs, tax incentives, and more as explained in CRS In Focus IF12757, Sustainable Aviation Fuel (SAF): An Overview of Current Laws and Legislation Introduced in the 118th Congress. SAF production can occur in a variety of ways. This CRS product provides a general summary of SAF production pathways; it is not a technical or comprehensive explanation. SAF Production Pathways There are currently 11 ASTM International (ASTM)- approved SAF production pathways. There is an ASTM technical standard specification for sustainable aviation fuel (D7566) and petroleum-based jet fuel (D1655). ASTM reports that aviation fuel that meets the requirements of D7566, meets the requirements of D1655, and should be regarded as D1655 aviation fuel. In short, SAF must meet the requirements for D7566 to then satisfy the requirements for D1655 and be a substitute for petroleum-based aviation fuel (see Figure 1). ASTM developed a standard practice (D4054) for the evaluation of new aviation fuels (i.e., a process standard to evaluate SAF). ASTM reports that D4054 defines the process and D7566 defines the end product. SAF that meets the D7566 technical standard specification can only be blended with conventional fuel (D1655) up to an approved maximum blend limit (e.g., 50%). SAF is considered a drop-in fuel, i.e., it is a fuel capable of being used with existing infrastructure. Three of the 11 ASTM-approved SAF production pathways are co-processing pathways, all of which fall under ASTM D1655 Annex Al. In general, co-processing is when an existing refinery processes two or more feedstocks simultaneously, such as an approved renewable feedstock along with a petroleum-based feedstock. Co-processing advantages include potentially producing SAF more quickly by using existing refinery equipment and processes, with minor modifications. Co-processing disadvantages include a potentially lower volume of SAF needed due to the maximum blending rate (e.g., 5%) for the co-processing SAF production pathways compared to the other SAF production pathways. The National Renewable Energy Laboratory reports there are multiple additional SAF production pathways currently under review by ASTM. Also, the Commercial Aviation Alternative Fuels Initiative reports it is aware of a significant number of additional prospective pathways that are currently being pursued by multiple entities, but have yet to enter the ASTM Qualification Process. Figure I. Schematic of Jet Fuel and SAF Production Pathways ASTM 165 K ASTM 1655 Source: Climate Drift, The Sustainable Aviation Fuel (SAF) Solution Framework, May 21, 2024. ata Reporting As of September 2024, Argus reports there are three SAF facilities operating in the United States that have production capacities of 10 million gallons per year (MGPY) or more. Two of the three facilities use the HEFA-SPK pathway and the other facility uses the AtJ-SPK pathway (see Table 1). Some U.S. government agencies provide SAF production data. For example, the Environmental Protection Agency provides data on renewable jet fuel for the Renewable Fuel Standard. In addition, there is a federal interagency initiative-led by the Department of Energy (DOE), the Department of Agriculture, and the Federal Aviation Administration-to track SAF metrics, including actual and potential SAF production, to help meet the Sustainable Aviation Fuel Grand Challenge (SAFGC). SAF Production Pathway Considerations Federal policy could shape any potential contribution SAF may have towards meeting various energy, transportation, agricultural, and environmental goals. There is much Congress could consider regarding SAF federal policy. Four potential considerations include (1) which SAF production pathways show the most potential, and over

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