RFA Offers Recommendations for SAF Emissions Modeling

Cindy Zimmerman

With the deadline to update the GREET model looming on March 1, the Renewable Fuels Association is offering recommendations for ensuring that the best available science and data are used in determining eligibility for the sustainable aviation fuel (SAF) tax credit established in the Inflation Reduction Act.

RFA sent a letter today to an interagency administration working group containing detailed comments and recommendations, including analysis of the strengths and weaknesses of different modeling tools, methodologies, and data sets being considered by the IWG for inclusion in the soon-to-be-updated “40B GREET model.”

“One of the most promising forms of SAF involves the conversion of ethanol to jet fuel,” wrote RFA President and CEO Geoff Cooper. “Ethanol has key advantages as a feedstock for SAF, as it is cost-competitive with petroleum-based fuels and is by far the largest-volume biofuel produced in the U.S, with output of nearly 16 billion gallons per year.”

RFA also urges the administration to ensure the new model is informed by actual observations and empirical data from the post-2005 period of biofuel expansion and said it should also take a practical approach to integration of climate-smart agriculture practices.

“In order for the full potential of the IRA to be realized, it is imperative that the proper lifecycle analysis modeling framework be adopted by the Treasury and IRS,” the letter concludes. After slight modifications are made by the IWG to include more current data and information, “…the resulting 40B GREET should be determined to satisfy the CAA section 211(o)(1)(H) criteria.”

Click here to read the letter.

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