The US Federal Aviation Administration (FAA) has announced $291 million in new grants to accelerate air transport decarbonisation, backing projects ranging from production, storage and distribution of sustainable aviation fuels to new aircraft, propulsion and flight planning technologies. The funds have been provided under Fueling Aviation’s Sustainable Transition (FAST), a programme which supports initiatives to help achieve net zero carbon emissions by 2050. The grants, made possible under the Inflation Reduction Act, coincide with increasing global concerns that aviation will fail to meet its climate targets without more policy support from governments. “The Biden-Harris Administration is committed to enhancing the safety of our national transportation system and reaching our mid-century target of net-zero emissions,” said Secretary of Transportation Pete Buttigieg. “These grants will help put the world on a path toward decarbonising aviation while fostering economic growth and ensuring the US retains its global leadership in aviation.”

The latest grants support 36 projects in 22 states, with the largest proportion – $244.5 million, or 84% – dedicated to producing, transporting, blending or storing SAF, or for studies to determine infrastructure requirements for the low carbon fuels. The remaining $46.5 million has been committed to projects which develop, demonstrate or apply low-emission aviation technologies.

“These grants will reduce carbon pollution, improve aircraft fuel efficiency and increase SAF use,” announced the FAA, adding that all the organisations to be awarded grants were based in the US. But some are also significant players in global markets, or aspiring to be so, supporting not just US aviation but also international partners and customers.

The FAST funding was allocated via four channels – SAF Tiers 1 and 2 and Low Emission Categories 1 and 2 – to a mix of existing and startup fuel producers, logistics and supply chain companies, state and local governments, airport authorities, universities, and both established and evolving manufacturers of aircraft, powerplants and components.

SAF Tier 1 projects, of which there are seven, are focused on supply chain studies to identify SAF infrastructure needs, while Tier 2 projects, of which there are 15, are for the construction of infrastructure to produce, transport, blend and store SAF. There are also 13 Low Emission Technology Category 1 projects, each developing new decarbonisation technologies, and one Low Emission Technology Category 2 project to develop test capabilities to advance new measures.

The largest single grant was $50 million to Martinez Renewables, a joint venture between Marathon Petroleum and global SAF producer Neste, to help fund upgrades at the company’s renewable fuels plant in California to enable production of SAF as synthetic paraffinic kerosene (SPK). The repurposed facility is expected to produce 100-350 million gallons of SAF per year from 2027.    

Among other major recipients of grants for SAF, BP Products North America secured $26.76 million to produce and blend 10-25 million gallons per year at its Cherry Point refinery in Washington State; Buckeye Terminals was awarded $24 million to upgrade SAF storage and distribution capacity at four facilities in Michigan, Illinois and Indiana; World Energy secured $21.96 million to install and integrate pipeline components to enable SAF delivery to Los Angeles International Airport; and Phillips 66 secured a total of just under $23 million to upgrade or develop four of its locations in California and Oregon to produce, blend and store SAF.

Additionally, Equilon Enterprises was awarded $17.9 million to install infrastructure to receive and blend neat SAF at the Shell Carson Terminal in southern California, with an annual output target of 151 million gallons; Gevo secured $16.8 million to convert a Minnesota facility to produce alcohol-to-jet SAF; Colonial Pipeline Company in Louisiana attracted $16.5 million to increase SAF storage and blending capacity; Arcadia eFuels was awarded $14.6 million for front-end engineering design to build a new SAF plant in Texas; Marquis R&D Energy secured just under $10 million for production, blending and storage infrastructure for ethanol-to-jet SAF; and LanzaJet received $3 million to expand infrastructure to enable delivery of an additional 518,300 gallons of SAF per year.

Emerging aircraft manufacturer JetZero secured an $8 million grant to develop technologies for its new Blended Wing Body aircraft, in particular lightweight composite materials; Otto Aviation Group secured just under $7 million for wind tunnel tests of a transonic super laminar aircraft, designed to achieve twice the efficiency of conventional models by improving airflow over the plane’s surfaces; hydrogen propulsion company ZeroAvia was awarded $4.2 million to progress development of a suite of hydrogen fuel cell powertrains; Heart Aerospace, California, secured $4.1 million to develop hybrid-electric systems for new zero emission planes; Wright Electric received $3.3 million to develop an ultra-high energy battery for zero-emission aircraft; and Boeing received $2.6 million for a new system to more accurately measure fuel loads.

Initiatives delivering incremental reductions in emissions were also recognised in the FAST programme, with a $5.6 million grant to Green Taxi to design, manufacture and certificate an electric nosewheel motor for zero-emission taxiing, initially for installation on Embraer E175 aircraft; Seattle-based Apijet secured $4.5 million for flight planning software enabling airlines to optimise routes with real-time information on operating constraints; and Aersale was awarded $757,400 to develop initiatives to reduce aerodynamic drag on Boeing 737 windscreens, including vertical parking of windshield wipers. 

The universities of Virginia, Illinois and Michigan received funds to advance a range of programmes including supply chain modelling for airport SAF deliveries, flight operations using low-emission technologies and development of a test facility for zero emission electric aircraft systems. The cities of Atlanta and Philadelphia and the Alaska Department of Transportation were variously funded to explore feasibility or means of delivering SAF or increasing its uptake in their jurisdictions. The FAA said no further grants or funding opportunities were under consideration.

Photo (Los Angeles World Airports): SAF producer World Energy secured $21.96 million under FAST to install and integrate pipeline components to enable SAF delivery to LAX

Tony Harrington

Correspondent

• Linkedin

US aircraft and engine manufacturers have called on the new Biden administration to provide sustained government support to help achieve its climate goals. In an open letter to Transportation Secretary Pete Buttigieg, FAA Administrator Steve Dickson, Climate Envoy John Kerry and National Climate Advisor Gina McCarthy, the US Aerospace Industries Association (AIA) said action should be taken in three key areas: measures to accelerate the production and use of sustainable aviation fuels (SAF); enhancement of public-private partnerships to accelerate development of next-gen aircraft and engine technology; and delivery of national airspace modernisation. The letter says that while AIA members would be contributing to climate targets through more efficient aircraft technology, it calls for a “holistic approach” to tackling aircraft CO2 emissions through short-term tools such as SAF, operational improvements and market-based measures. The AIA recommends the administration supports a blender’s tax credit that would incentivise greater SAF production. The blender’s tax credit is a policy option included in the Sustainable Aviation Fuel Act legislation introduced in November by California Democrat Congresswoman Julia Brownley. Meanwhile, Boeing is seeking to intervene on behalf of the Environmental Protection Agency, which is being sued by 12 US states, the District of Columbia and three NGOs over the agency’s recent decision to finalise aircraft GHG emissions standards.

SAF, says the AIA, offers the most effective way of reducing the environmental impact of flying in the short-term but is not being produced currently in sufficient quantities to be an economically viable option for airlines today. As well as a blender’s tax credit, it recommends government support for SAF be provided through increased R&D funding, the adoption of policies to encourage sustainable fuel production specifically for aviation and increased military procurement and use of SAF by the government to help grow the market.

Although the FAA had already made significant progress in delivering enhancements to the National Airspace System, says the letter, the administration is asked to prioritise realisation of the improvements, which it says are expected to deliver 2.8 billion gallons of fuel savings through until 2030. This, it says, can be achieved by implementing performance-based navigation (PBN) routes to enable aircraft to fly shorter, more direct routes, and ensuring PBN implementation is complemented by continued efforts to promote community involvement in changes to airspace structure, “which will deliver improvements in both noise and climate impacts.”

The US aerospace industry was exploring a range of technologies for next-generation aircraft in the 2030s that would offer improvements in fuel efficiency of 15-25% compared to current aircraft, says the AIA, but “to realise these benefits, US aviation manufacturers will require support to remain competitive, given the impact of Covid-19 and the billions of dollars European governments are providing their industries to support similar efforts.”

The AIA calls for four areas of support:

• Advancing NASA’s work in enabling technologies for next-gen aircraft, such as new airframe and engine architectures, improved aerodynamics, advanced propulsion (including electrification), advanced manufacturing and lightweight materials;
• Accelerating the timetable of a NASA subsonic demonstrator ‘X-plane’ incorporating these innovations to ensure US companies can bring these technologies to maturity ahead of European competitors;
• Increasing funding for the FAA’s Continuous Lower Energy, Noise and Emissions (CLEEN) Program to accelerate near-term fuel efficiency improvements in conjunction with reductions in noise and other emissions that manufacturers need to balance; and
• Developing a comprehensive, long-term research agenda to secure US leadership in transformational aviation technologies, leveraging partnerships between industry and government agencies such as NASA, the Department of Transportation, Department of Defense and Department of Energy.

The AIA also stresses the importance of government, industry and NGOs working together through ICAO, and notes ICAO is continuing to assess the feasibility of a new long-term goal for international aviation emissions.

“To build upon achievements to date, we urge the administration to continue to prioritise multilateral solutions and maintain the leadership the US government has demonstrated in these activities,” says the letter, which mentions the aircraft CO2 standard established by ICAO in 2017 and now implemented by the Environmental Protection Agency (EPA) into domestic law.

“Following the finalisation of the EPA rule, we ask that the FAA develops regulations this year that will allow US manufacturers to certify their aircraft to the global CO2 standard.”

During the final days of the Trump administration in late December, the EPA finalised emissions standards for airplanes used in commercial aviation and large business jets that align them with the ICAO standards. Without the rulemaking, said the EPA, US manufacturers would have been at a significant disadvantage and could be forced to seek CO2 emissions certification from another country in order to market and operate their airplanes internationally.

However, the ruling is being challenged in an appeals court in Washington by the attorneys general from 12 Democrat-led states, including California, Illinois, Pennsylvania and New York, plus the District of Columbia, who contend it would not result in actual reductions of greenhouse gas emissions and is therefore unlawful.

The three environmental groups taking action are the Center for Biological Diversity (CBD), Friends of the Earth and Sierra Club, which are being represented by Earthjustice. They say the rule will not apply to in-service airplanes and will not apply to new in-production airplanes until 2028, when the EPA expects all airplanes to already comply with the standards or be phased out.

“We’re confident that we’ll stop this rule in court and we look forward to serious, science-based standards from the new Biden administration,” said Clare Lakewood, Legal Director of CBD’s Climate Law Institute.

According to a Reuters report, Boeing has asked the appeals court for approval to intervene on behalf of the EPA, noting that US participation in the work towards the ICAO CO2 emissions standard on which the ruling is based began under the Obama administration, in which Joe Biden was Vice President.

Boeing said in a statement it was essential rules should be reasonably achievable “given the billions of dollars it costs to design, build and certify new airplanes.”

It added: “Attempts to overturn regulation directly aligned with successful cooperative international efforts to combat climate change, supported by more than 190 countries, will only discourage future international agreements.”

In its ruling, the EPA said: “The ICAO Airplane CO2 Emission Standards have been adopted by other ICAO member states that certify airplanes. The action to adopt in the United States GHG standards that match them will help ensure international consistency and acceptance of US manufactured airplanes worldwide.”

It conceded though: “EPA’s assessment includes the expectation that existing in-production airplanes that are non-compliant will either be modified and re-certificated as compliant, will likely go out of production before the production compliance date of January 1, 2028, or will seek exemptions from the GHG standard. For these reasons, the EPA is not projecting emission reductions associated with these GHG regulations. However, the EPA does note that consistency with the international standards will prevent backsliding by ensuring that all new types design and in-production airplanes are at least as efficient as today’s airplanes.”

The Sustainable Aviation Fuel Act legislation introduced by Julia Brownley aims to incentivise SAF production and help the aviation sector reduce its carbon emissions. As well as creating a new blender’s tax credit for SAF, linked to carbon reductions, it would authorise $1 billion in federal funding for US projects that produce, transport, blend or store SAF and a further $175 million in research funding “to push the limits” of existing SAF technology. It would also require the EPA to establish an aviation-only Low Carbon Fuel Standard (LCFS) similar to California’s transportation-wide LCFS.

“As a member of the House Select Committee on the Climate Crisis and the House Transportation and Infrastructure Subcommittee on Aviation, I know the importance of, and challenges to, decarbonising the aviation industry,” said Brownley. “Aviation alone contributes 9% to US greenhouse gas emissions from the transportation sector and is therefore a critical target towards achieving our climate goals. Sustainable aviation fuel will go a long way to reducing aviation sector greenhouse gas emissions but it needs a focused federal response to make it a reality.”

Photo: Boeing

US environmental groups say the proposal by the Environmental Protection Agency (EPA) to adopt the ICAO CO2 standards for aircraft into US regulations violates the nation’s Clean Air Act because it fails to reduce greenhouse gas emissions despite the EPA’s findings that such emissions endanger public health and welfare. Moreover, they say, the proposal’s failure to consider the statutory factors laid out in the Act or analyse the costs and benefits of a range of possible emission standards, and refusal to select an alternative based on the evidence before the agency was “arbitrary and capricious”. The groups were responding to a public comment period just closed on the proposal, which has been largely supported by US aerospace and airline sectors. Although the majority of aircraft will not be subject to the standards until January 2028, the industry is calling for finalisation of its domestic adoption by the end of this year.

The aircraft CO2 standards were adopted by the ICAO Council in March 2017 and are contained in Annex 16 of the Chicago Convention. It applies to new aircraft type designs from 2020 and to aircraft type designs already in production as of 2023. Those in-production aircraft which by 2028 do not meet the standards will no longer be able to be produced unless their designs are sufficiently modified. The EPA and FAA represented the United States on ICAO’s environmental protection committee CAEP, which drew up the standards.

After legal challenges by environmental groups, in 2016 the EPA issued findings that within the meaning of section 231 of the Clean Air Act, elevated concentrations of greenhouse gas (GHG) emissions in the atmosphere endangered the public health and welfare of current and future generations, and that GHG emissions from certain classes of engines used in certain aircraft are contributing to the air pollution that endangers public health and welfare.

As such, the EPA is proposing to regulate GHG emissions from covered airplanes through the adoption of domestic GHG regulations that match ICAO’s international CO2 standards. Covered airplanes are civil subsonic jet aircraft with a MTOM greater than 5,700 kgs and larger civil subsonic turboprop airplanes with a MTOM greater than 8,618 kgs. It proposes to adopt the ICAO CO2 metric, which measures fuel efficiency, for demonstrating compliance with the GHG emissions standards. The metric is a mathematical function that incorporates the specific air range (SAR) of an airplane/engine combination – a traditional measure of airplane cruise performance in units of km/kg of fuel – and the reference geometric factor (RGF), a measure of fuselage size.

To measure airplane fuel efficiency, the EPA is proposing to adopt the ICAO test procedures whereby the SAR value is measured in three specific operating test points, and a composite of those results used in the metric to determine compliance with the proposed GHG standards. In order to be consistent with the current annual reporting requirement for engine emissions, the EPA is also proposing to require the annual reporting of the number of airplanes produced, airplane characteristics and test parameters.

The EPA says US manufacturers have already developed or are developing technologies that will allow affected airplanes to comply with the ICAO standards, in advance of its adoption, and it anticipates nearly all affected airplanes to be compliant by the respective dates for new type designs and for in-production airplanes. This includes the expectation that existing in-production airplanes that are non-compliant will either be modified and re-certificated as compliant or will likely go out of production before the production compliance date of 1 January 2028.

“For these reasons, the EPA is not projecting emission reductions associated with these proposed GHG regulations,” it states in the executive summary of the proposed rule.

The EPA held a virtual public hearing on September 17, with participation from aircraft and engine manufacturers, aerospace and airline industry associations, environmental organisations and other interested parties. Over 120 written public comments have been submitted in response to the proposal by the October 19 closing date.

A coalition of environmental groups that first filed a suit against the EPA over a decade ago to force the agency to address GHG emissions from aircraft said the proposal violated section 231 of the Clean Air Act (CAA) as it failed to reduce GHG emissions from aircraft despite the EPA’s own endangerment findings.

“Moreover, the proposal’s failure to consider the statutory factors laid out in section 231, over-reliance on factors outside the statute, failure to analyse the costs and benefits of a sufficient range of possible emission standards, and refusal to select an alternative based on the evidence before the agency are arbitrary and capricious,” says the submission by Earthjustice, Center for Biological Diversity, Sierra Club, Friends of the Earth and Natural Resources Defense Council.

“These flaws cannot be remedied in a final rule. Instead, EPA must replace the proposal with one that meets its duties under the Clean Air Act. The final regulations must employ strong mechanisms to reduce emissions from aircraft and protect the public health and welfare and in doing so, EPA must consider the full panoply of available measures, including declining fleetwide emissions averages and operational and design improvements.

“To avoid catastrophic climate change, EPA must implement standards that far exceeds ICAO’s standards in both stringency and scope.”

The submission dismisses the EPA’s argument that US manufacturers would be at a competitive disadvantage if the US failed to adopt standards in line with ICAO’s. “EPA provides no legitimate basis for this assertion. Nothing prevents the US from adopting standards that are more stringent than ICAO’s and EPA has responsibility to do so if that is what public health and environmental protection require.”

Commenting on its own submission, Annie Petsonk, International Counsel for the Environmental Defense Fund, said: “As EPA’s own analysis indicates, the proposed standards will not drive emissions down. It simply embodies what the industry has already baked in. To justify its approach, EPA relied on a problematic estimate of the costs of doing nothing, arbitrarily ignoring the real costs of climate pollution that people across the country are facing every day.

“As the aviation industry tries to bounce back from Covid, it must put addressing the climate crisis at the core of its recovery, and government needs to lead the way. A stringent aircraft pollution standard would mean jobs building the aircraft and creating the fuels of the future. Instead, EPA’s proposed aircraft rule ignores the science and contravenes laws that require it to protect public health and the environment.

“We urge EPA to replace its proposal with standards that will actually reduce aircraft emissions, as one key element of a broader package of carrots and sticks to get the aviation industry to take real steps to cut climate pollution.”

In its submission to the EPA, the non-profit environmental research organisation International Council on Clean Transportation (ICCT) said its analysis showed new deliveries of commercial aircraft in 2019 were on average 6% more fuel efficient than required by the ICAO standards.

With some caveats, the industry response to the EPA’s proposal is supportive of legislation in line with ICAO CO2 standards, which it sees as meeting the criteria set out in the CAA’s section 231.

“Adopting the standards into US law will ensure US-manufactured aircraft and engines are available to US airlines, while fostering global competition and enabling our airlines to acquire aircraft and aircraft engines at market-driven, competitive prices,” says a joint submission by Airlines for America and the Air Lines Pilots Association International. “Especially given that, as the agency itself notes, other ICAO member states that certify airplanes have already adopted the ICAO CO2 standards, the agency needs to act to put US manufacturers on the same footing as their foreign counterparts.”

The two trade bodies said the ICAO standards would achieve GHG emissions reductions, support US policies to combat climate change and provide international uniformity. “Aircraft and the international airspace system simply could not function if aircraft and aircraft engines were subject to disparate regulatory requirements and standards.”

However, they asked the EPA to clarify in its rulemaking that the proposed US standards did not apply to in-service aircraft and disagreed with the agency’s conclusion that there could be no costs or benefits attributable to the standards.

A submission by the Aerospace Industries Association (AIA) said its members had already taken steps to ensure compliance with the proposed standards, including making plans to end production of the least fuel-efficient aircraft.

“The majority of aircraft will not be subject to the standards until 1 January 2028. Nevertheless, we urge the EPA to finalise the domestic adoption of these rules by the end of this year,” said the AIA. “Airlines purchase aircraft several years in advance. They are currently deciding on aircraft that will be delivered through the end of this decade. When making these decisions, airlines will require assurances that aircraft meet the standards to operate in international markets.

“Without domestic regulations in place, the FAA would be unable to certify an aircraft as meeting the ICAO CO2 standards. In this situation, US manufacturers would be at a serious competitive disadvantage if airlines were to seek greater regulatory certainty by opting to purchase aircraft manufactured elsewhere that meet the requirements of their certifying authority’s equivalent rules, which have already been implemented in some cases.

“If this was to occur, it could jeopardise tens of billions of dollars in sales for the US aerospace industry.”

Engine manufacturer GE said the proposed rule would provide the global aviation industry with much-needed certainty and consistency as it faced the Covid crisis and its adoption would satisfy US obligations under the Chicago Convention by ensuring compliance with ICAO standards.

GE also argued that more stringent GHG standards were not appropriate and would potentially violate the Clean Air Act.

“The CAA does not require the EPA to ‘technology force’ at the risk of flight safety,” said the submission. “[It] requires EPA to refrain from changing aircraft emission standards if such a change would adversely affect safety. To maintain the trust and confidence of the flying public, it is imperative that EPA not adopt standards that could in any way be perceived as sacrificing aviation safety. The perception of the flying public matters and EPA should endeavour to avoid any erosion of public confidence in the safety of aviation. This objective is best achieved by EPA remaining aligned with the ICAO analytical criteria of technical feasibility, environmental benefit, cost effectiveness and impacts of interdependencies, which have helped ensure the continuation of aviation’s impressive safety record.

“Moreover, when preparing this proposal, EPA carefully analysed the impacts of two more stringent alternatives. These analyses show that the alternatives would lead to minimal reduction in GHG emissions, while imposing significant costs associated with deviating from the ICAO standards. Consequently, EPA appropriately decided against proposing either of these alternatives.”

While supportive of aligning EPA regulations with the ICAO CO2 standard, both Boeing and Airbus are opposed to the reporting requirements laid out in the proposal. Boeing said they were unnecessary as they were duplicative of FAA reporting requirements, “and unwise because they pose unnecessary risks to Boeing’s confidential business information and potentially the nation’s security.”

The concerns are centred on fears the EPA could make public manufacturers’ specific air range data.

“SAR data is highly sensitive, treated by Boeing and other airplane manufacturers as a trade secret and protected zealously from disclosure to competitors and the public,” says the Boeing submission. “because of the strategic value of SAR data, it can also be subject to federal export controls and sanction regimes.

“There is also a risk that someone could wrongly argue that SAR data should be considered to be emissions data or ‘related technical information’ that EPA must disclose. EPA should not collect SAR data … and should not require reporting of that data. If it nonetheless requires reporting of SAR data then EPA must ensure that data is protected from public disclosure.

“EPA need not collect SAR data to track airplane CO2 emissions performance and verify compliance. ICAO agreed to the use and public reporting of an aircraft’s [fuel efficiency] metric value for this purpose because it is sufficient by itself to enable assessment of compliance with the CO2 emissions standard, while continuing to maintain the confidentiality of manufacturers’ SAR data. Significantly, ICAO does not require public reporting of RGF – an important element of SAR data – precisely because it can be used to derive an airplane’s SAR.”

Airbus too said SAR data and the reference geometric factor were highly commercially sensitive information. It also questioned the EPA’s authority to request such information when a large number of airplanes delivered around the world would never operate within the United States.

“ICAO is the right body to create international standards,” said the Airbus submission. “Airbus believes that in the absence of a worldwide harmonisation process, regional requirements could produce unintended consequences that would harm the aviation industry. We therefore urge the EPA to adopt the proposed ICAO rule with no additional requirements.”

The ICAO Aircraft CO2 standards are contained in Volume III to Annex 16 of the Chicago Convention and were adopted in Europe by the European Parliament and Council in July 2018 (Regulation (EU) No. 2018/1139). The European Union Aviation Safety Agency (EASA) published certification specifications concerning the standard in August 2019.

Photo: Boeing