About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

1 [1] (March 14, 2025)

handle is hein.crs/stanavnfu0001 and id is 1 raw text is: 





Congressional Research Service
Inforrning the legislative debate since 1914


Updated March  14, 2025


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., ReFuelEU
Aviation regulation); and it may satisfy consumer requests
for more environmentally friendly aviation fuel. With these
potential opportunities come potential challenges such as
producing a large amount of SAF within a certain time
frame 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  also 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 be blended with conventional fuel
(D1655) only up to an approved maximum blend limit (e.g.,
50%). SAF  is considered a drop-in fuel, that is, 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 simultaneously processes two or more
feedstocks, 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


                      ASM 16a
 Sustainable SAF
 Feedstock Producton  .oo,     ASTM   1655

                   ASTM 1655                       /


    F   * Refinery

Source: Climate Drift, The Sustainable Aviation Fuel (SAF) Solution
Framework, May 21, 2024.

Data   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 Synthetic
Aviation Fuel Grand Challenge (SAFGC), originally called
the Sustainable Aviation Fuel Grand Challenge when
introduced under the Biden Administration in 2021.

SAF Production Pathway Considerations
Federal policy could shape any potential contribution SAF
may  have toward 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
what time frames; (2) how many SAF facilities will come
online; (3) what impact existing policies will have on SAF
production over different time frames; and (4) whether


igross.gov

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Contact us for annual subscription options:

Already a HeinOnline Subscriber?

profiles profiles most