ABFA – Advanced Biofuels Association. With action on climate change necessary for the future of our planet and the global economy, U.S. policy makers are encouraging a transition to an electrified transportation fleet. However, millions of personal vehicles are unlikely to be electrified for decades, and aviation, long-distance trucking and marine shipping are difficult to electrify, leaving an “electrification gap.”
Fuels derived from renewable, non-food biomass – which Congress established in 2007 as Advanced Biofuels – can help to close the “electrification gap.” These fuels are distinct from first-generation biofuels like corn-based ethanol because they deliver a greater reduction in greenhouse gases and are one-to-one replacement for gasoline, diesel, and jet fuels. Plus, liquid advanced biofuels require little change in fuel distribution infrastructure or the transport fleet and can therefore be rapidly deployed without significant taxpayer investment.
The feedstock growers, producers, distributors, and marketers that advanced biofuels are members of the Advanced Biofuels Association (ABFA), the leading voice of energy innovators working to decarbonize transportation fuel. Founded in 200X, ABFA’s members create low-carbon fuels to address the global climate crisis and reduce greenhouse gas emissions. ABFA members are committed to lowering the carbon footprint of the global transport system, produce 50% of the nation’s aviation fuel by 2050, and help America close the “electrification gap.”
ABFA – Advanced Biofuels Association
800 17th Street, NW
Washington, DC 20006
Advanced biofuels are defined by federal law as renewable fuels, other than corn starch ethanol, that achieve at least 50% lifecycle GHG emissions reductions compared to a 2005 fossil-based fuel baseline. Corn ethanol by law cannot qualify as an advanced biofuel.
Most of ABFA’s member companies provide fuels for use beyond the passenger vehicle space. End users of advanced biofuels often include mid- or heavy-duty transportation, including trucks, planes, and marine vessels. Even as passenger vehicles electrify, the use of advanced biofuels -in the light duty fleet is absolutely critical to achieve future net zero goals. Hard to electrify sectors, like trucks, planes, and boats will also need to transition to advanced biofuels to achieve net-zero within the transportation sector.
Generally, advanced biofuels are produced by one of three types of feedstocks:
- Fats, oils, and greases – ranging from agricultural products like soybean oil, or oil produced using specialty grasses and cover crops, to tall oil and used cooking oil
- Cellulosic material – cellulosic feedstocks include municipal solid waste, wood, and agricultural residues
- Gaseous waste streams – renewable gases can be sourced from wastewater treatment plants, bio-digesters, landfills, and industrial facilities via carbon capture
Advanced biofuels are derived from lignocellulosic biomass, nonfood crop feedstocks, agricultural and forest residues, and industrial waste.
First generation biofuels like corn-based ethanol are not a one-to-one replacement for gasoline, diesel, and jet fuels, and lack the environmental potential of advanced biofuels. Ethanol, and other simple yet widely used biofuels, can reduce greenhouse gas emissions by 19-48% compared with gasoline. While advanced or cellulosic biofuels deliver at least a 50% reduction in greenhouse gas emissions, and many of them deliver a reduction of 80%.
There are a wide range of fuels that can qualify as advanced biofuels, and these fuels can often provide innovative low-carbon solutions for specific use cases. The primary requirement is that any advanced biofuel attain a minimum 50 percent reduction in greenhouse gas emissions compared to the fossil based fuel it replaces. Many of these advanced biofuels are also fungible in existing infrastructure, allowing distribution and use without requiring any changes to the supply system. These are commonly termed “drop in” fuels. Examples of both drop-in and other advanced fuels that can be produced and/or blended include:
- Renewable diesel
- Renewable heating oil
- Sustainable aviation fuel (SAF)
- Cellulosic and sugarcane ethanol
- Dimethyl Ether
Congress enacted the Renewable Fuel Standard, first in 2005 and an updated version in 2007, to increase American energy independence, reduce greenhouse gas emissions, and boost the U.S.’s rural economy. The program, which mandates that oil companies blend a certain amount of renewable fuel into the transportation fuel supply annually, has successfully built an American advanced biofuels industry and helped America move toward each of these objectives.
The program has a multi-purpose design. It increases the development and production of renewable fuels from both crop and non-crop based feedstocks, supports the rural economy through the use of agricultural products, reduces greenhouse gases by delivering lower carbon fuels into the liquid transportation fuels system, and increases domestic energy security.
Without any statutory changes, EPA could tweak the RFS program to better incentivize and reward better-performing fuels. By statute, advanced biofuels must deliver 50% or more GHG emissions reductions compared to a 2005 fossil-based baseline. However, many of ABFA’s members produce fuels that far exceed those minimum levels of carbon reduction, and EPA could modify the RFS program to better reward those reductions.
EPA has at its disposal a number of regulatory options to achieve this goal. For example, the Agency could provide additional compliance credit value for better performing fuels, drop-in fuels, or sustainable aviation fuel. Additionally, the Agency could expedite review and approval of more low-carbon fuel pathways for both new feedstocks and technologies to enable more RFS-compliant production of low-carbon renewable fuels.
As the RFS program moves beyond the statutory volume requirements set forth in the 2007 law, and moves to set new standards for 2023 and beyond, EPA has an opportunity to redesign its implementation of the program. ABFA has developed a framework of recommendations including provisions mentioned above, for the Agency to consider as it engages in this process of setting the future direction of the RFS program (termed the “Set” process). We encourage the Agency to evaluate all options to increase the production and use of cleaner fuels for the nation’s future.
ABFA’s first priority on this subject is advocating EPA rescind its current policy that prohibits the use of “biointermediate” feedstocks under the RFS program. Biointermediate feedstocks are derived from RFS-compliant feedstocks, partially converted at one facility, then transferred to another facility to be processed into a finished fuel. Under EPA’s current regulations, the act of moving this fuel from one place to another in an intermediary form prevents the fuel from generating RIN credits under the RFS program. If EPA were to remove this impediment, the industry would be able to upgrade biomass products and qualified wastes into biointermediates, then transfer those products to existing refineries or biofuel conversion facilities to be finished into drop-in fuels such as renewable diesel, jet fuel, or gasoline.
Additionally, ABFA has urged EPA to alter its regulations around wood residues. Currently, the regulations require tracking procedures for wood products that are incompatible with existing industry practices. Small changes to these regulatory requirements to permit the use of approved feedstocks, such as wood residue, on an aggregate basis using a mass-balance approach, would make millions of tons of available feedstock available for use under the RFS.
Founded in 2006, ABFA’s membership has grown over the last fifteen years to include companies that represent the full value chain of advanced biofuel production, blending, and distribution. From some of the world’s largest companies to small start-ups and technology providers, the organization’s strength comes from its members’ diversity within the fuel economy.
The members of the Advanced Biofuels Association collectively recognize the significant and growing challenge the world is facing from the impacts of climate change. Biofuels are needed to meet our carbon reduction goals, particularly in certain sectors where electrification is less well-suited. We welcome the responsibility and opportunity to be part of the solution as many of the world’s most innovative low-carbon liquid transportation fuel companies.
Indeed, we are firm in our belief that there is no one-size-fits-all solution for this global issue of reducing carbon emissions. Electrifying light-duty vehicles will make a significant contribution, but other transportation sectors – especially heavy-duty trucks, non-road vehicles, aviation and shipping – will require a different approach. The fuels of the future must also deliver the required power, range, and performance without sacrificing safety. To put it succinctly: we will need low-carbon alternatives for the full suite of liquid fuels.
While our goal is an all-of-the-above approach and we are fuel agnostic, ABFA recognizes a unique opportunity for advanced biofuels to help reduce emissions from those fuels hardest to electrify to provide low carbon transportation fuels for our future. By rewarding behavior in every sector, energy, electricity, autos, agriculture and manufacturing we believe we can find the solutions of the future to reduce the threats of climate change in the future of the world.
Our membership collectively represents production of more than 5 billion gallons of advanced biofuels annually. Our ranks includes some of the largest producers of fuel in the world and some of the world’s largest renewable diesel, biodiesel and heating oil producers, alongside their national distributors. We also represent the only two companies in the world who currently produce sustainable aviation fuel (SAF).
ABFA just sponsored a third party feedstock study which explored the availability of feedstocks that would be available to expand the production of Biomass based over the next 10 years. We set a target goal by 2030 of 9 billion gallons of biodiesel, renewable diesel, and renewable aviation fuels, referred to as SAF or synthetic aviation fuels. The study quantified that there is ample approved feedstock available from fats, oil, and greases to produce 9 billion gallons of fuels for use in the Biomass Based Diesel pool by 2030. The study excluded all required food use to determine whether enough feedstock existed to reach this goal without impacting the worlds food demand from these feedstocks. Longer term, it is anticipated that supplies from approved feedstocks would be able to support near 18 billion gallons by 2040 — all capable of achieving a minimum of a 50% carbon reduction as compared to the petroleum based diesel and aviation fuels.
As we move forward new conversion technologies and will emerge to support reducing the overall carbon intensity of our fuels. This will enable us to convert a wider array of feedstocks such as gaseous emissions from industrial facilities, the conversion of current existing ethanol production into renewable gasoline and jet fuel through fermentation, chemical and catalyst conversion techniques. Expanding the opportunities will allow us to produce and blend even larger volumes of low carbon fuels to significantly lower the carbon footprint. As the population of the world expands and the need for energy and food increases, it will be imperative to consider all avenues to not only supply the products, but for them to have significantly lower carbon intensity – including those for aircraft, Offshore Marine trade, and heavy duty trucks utilized which are critical for moving all of the worlds goods.
In the short term EPA has authority under the existing statute to make the changes necessary to achieve these goals. The removal of the bio-intermediates impediment, reviewing additional pathway submissions, allowing for additional feedstock apportionment provisions, and approval of supportive alternative test methods to consider conversion validation are all supportive under the existing law and would support appropriate flexibility to move this program forward enabling the expanded production and use of lower CI fuels.
Advanced Biofuels Association
800 17th Street, NW
Washington, DC 20006
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