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APPENDIX I Regulatory Considerations There are three general regulatory elements that should be considered in the evaluation of an alternative jet fuel project. For each one of these elements, this section details the main and asso- ciated information that the airport should consider when evaluating alternative jet fuel projects. The main regulatory elements are: 1. FAA policies and regulations, 2. Environmental reviews and permitting, and 3. Energy policy. The following subsections outline and present the important points associated with these three regulatory elements. I.1 FAA Policy and Regulatory Framework The FAA compiles and maintains a number of documents, including FAA Advisory Circu- lars, FAA Orders, and references to other documents that must be considered when assessing the viability of alternative fuel infrastructure. The following subsections identify these docu- ments and provide key excerpt material, when appropriate, to provide the reader with an overview of the policy and regulatory framework pertaining to conventional and alternative jet fuels in the airport setting. I.1.1 FAA Advisory Circulars, Orders, Regulations, and Peripheral Documentation FAA policies and regulations largely control what can and cannot be done in the airport set- ting. The construction and operation of alternative jet fuel infrastructure is no exception. The FAA compiles and maintains a number of documents, including ACs, Orders, and references to other documents that should be considered when evaluating the feasibility of placing alternative jet fuel infrastructure in the airport setting. In addition, given the complex technical issues sur- rounding fueling system and airfield design, engaging an aviation consultant engineer familiar with these topics may be advisable to assist with locating a processing facility. The FAA and FAA-related documents most likely to be relevant for alternative jet fuel projects are as follows (see Section 6 for more information): · FAA AC 150/5070-6B, Airport Master Plans · FAA AC 150/5200-33, Hazardous Wildlife Attractants on or Near Airports · FAA AC 150/5230-4A, Aircraft Fuel Storage, Handling, and Dispensing on Airports 100
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Regulatory Considerations 101 RUNWAY RUNWAY OBJECT FREE PROTECTION AREA (ROFA) ZONE (RPZ) BUILDING RESTRICTION LINE (BRL) RUNWAY CONTROLLED ACTIVITY AREA (CAA) NOT TO CENTRAL SCALE RPZ Figure 15. Controlled activity area. Source: Fig. 2-3, FAA AC 150/5300-13 (FAA 1989). · FAA AC 150/5300-13, Airport Design · FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Projects · FAA Order 5190-6b, Appendix R, Airport Compliance Manual · FAA Order 5190-7, Minimum Standards for Commercial Aeronautical Activities · FAA Order 1050.1E, CHG 1, Environmental Impacts: Policies and Procedures, Paragraph 304 · Title 14 of the Code of Federal Regulations (CFR) Part 77, Objections Affecting Navigable Airspace · Title 14 of the Code of Federal Regulations (CFR) Part 139, Certification of Airports · National Fire Protection Association (NFPA) 407, Standard for Aircraft Fuel Servicing · Best Practices for Environmental Impact Statement (EIS) Management · Environmental Desk Reference for Airport Actions As with any airport facility, fuel production and storage facilities must comply with FAA AC 5300-13, Airport Design (FAA 1989), which contains definitions for RPZs and ROFAs (see Figure 15 and Figure 16). This AC prohibits objects nonessential to air navigation or ground RUNWAY OBSTACLE FREE ZONE (OFZ) HORIZONTAL SURFACE 150 FEET ABOVE INNER TRANSITIONAL AIRPORT ELEVATION OBSTACLE FREE ZONE (OFZ) 1 3 or 6 HEIGHT SPECIFIED BY EQUATIONS (PARAGRAPH 306, FAA AC150/5300-13) NOT TO SCALE RUNWAY DETERMINED BY AIRCRAFT CATEGORY AND CROSS APPROACH PRECISION SECTION Figure 16. Obstacle free zones around runways. Source: Fig. 3-5, FAA AC 150/5300-13 (FAA 1989).
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102 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting maneuvering purposes in ROFAs and states that fuel storage facilities may not be located in the RPZ. FAA Order 5190.6B, Airport Compliance Manual (FAA 2009), reiterates that fuel storage facilities are a prohibited RPZ land use but mentions an exception for underground fuel storage tanks in controlled activity areas, which are the portions of the RPZ outside the central RPZ. Additionally, 14 CFR Part 77, Objections Affecting Navigable Airspace (FAA 1993), establishes standards for determining obstructions to air navigation by defining criteria for imaginary sur- faces that must not be pierced by any structure, including fuel production and storage facilities. Another consideration is that the proposed project must be shown on the airport layout plan, as indicated in FAA Order 5190-6B (FAA 2009). An unconditional ALP approval is required for the construction of an alternative jet fuel production facility on an airport. FAA AC 150/5230-4A, Aircraft Fuel Storage, Handling, and Dispensing on Airports (FAA 2004), states that NFPA's 407 Standard for Aircraft Fuel Servicing (NFPA 2007) lists specifications for the design, operation, maintenance, and location of fuel storage areas and aircraft fueling devices. Gen- erally, it requires that fuel pumps and storage tanks and facilities be at or below ground level. How- ever, NFPA 407 itself does not give many specifics on the design and siting requirements of fuel facilities. NFPA 407 allows the authority having jurisdiction to establish these requirements. The authority having jurisdiction may be a federal, state, local, or regional department or individual. The constructions of alternative jet fuel facilities on or proximate to an airport will require an environmental review to adequately assess and disclose the potential for impacts to the environment from such a facility. FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implement- ing Instructions for Airport Projects (FAA 2006b), provides information relative to the environmen- tal review process that may be required. Order 5050.4B specifies three types of reviews: categorical exclusions, environmental assessments, and environmental impact statements. The type of review required will be determined by the responsible FAA official with jurisdiction over the project. The type of review will also depend on the estimated significance of the impact of the project on the environment. In some cases, the extent of government agencies' review expands depend- ing on the circumstances that are likely to be highly controversial on environmental grounds. Both FAA Order 1050.1E and FAA Order 5050.4B stress the importance of early contact with the FAA to avoid delays in the NEPA process. Alternative jet fuel processing plants located outside of the airport limits are not subject to the FAA policies and regulations governing on-airport facilities; however, near-airport and off- airport facilities must still comply with 14 CFR Part 77. For example, objects such as light poles, trees, construction cranes, and even tall buildings (sometimes miles away from the airport) can be in violation of 14 CFR Part 77 and would, therefore, present a potential hazard to aircraft operating in the area. Form 7460-1, Notice of Proposed Construction or Alteration, needs to be completed and filed with the FAA prior to construction for an airspace analysis and determina- tion for on- or off-airport projects. In addition to the FAA documents discussed previously, it is important to indicate other resources available to jet fuel handlers. For example, the American Transport Association publishes ATA Specification 103: Standard for Jet Fuel Quality Control at Airports (ATA 2009c). This doc- ument includes recommended specifications that have been developed to provide guidance for safe storage and handling of jet fuel at commercial airports. While these recommendations are not mandatory, they are very closely followed by all major airlines and airports in the United States. I.1.2 Airport Improvement Program Applicability Any costs associated with alternative jet fuel production are not AIP eligible. Refining and manufacturing of aviation fuels, whether from conventional or alternative feedstocks, are not aeronautical activities. The handling, storing, and delivery of jet fuel into an airplane may be con-
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Regulatory Considerations 103 sidered an aeronautical activity as long as 100% of the fuel is delivered to aircraft on the airport and not distributed elsewhere. Therefore, on-airport fuel storage is eligible but only using non- primary airport entitlements. Furthermore, since the production of alternative fuels is not an aeronautical activity, any leases will need to be at fair market value. Ancillary project elements, such as site preparation and utilities, may be eligible for AIP funding. The following sections present more information on possible AIP applicability for certain fuel- related projects at airports. They are meant to illustrate some details of how AIP funding works and how it can relate to alternative jet fuel. For more information, airports are encouraged to contact their local FAA office. Contact information for the FAA regional offices is available at http://www. faa.gov/about/office_org/headquarters_offices/arp/regional_offices/. Fuel Facilities and AIP The AIP provides grants to public agencies and, in certain circumstances, to private owners and entities to plan and develop public-use airports (FAA 2010b). An airport improvement project must meet numerous requirements before becoming eligible for funding. In general, projects related to enhancing airport safety, capacity, security, and environmental concerns are eligible for AIP funding. On the other hand, projects related to airport operations and revenue-generating activities are usually not eligible for AIP funding. Projects related to fuel infrastructure are typically ineligible for AIP funding, but there are cer- tain circumstances under which they become eligible. For example, Paragraph 515(a) of the Air- port Improvement Program Handbook states that new fuel farms at non-primary airports may be eligible for AIP funding provided that financing for other airfield projects with higher priority has been secured (FAA 2005b). Furthermore, the FAA Vision 100--Century of Aviation Reauthoriza- tion Act included a provision to allow for revenue-producing facilities such as hangars and fuel farms to obtain AIP funding if certain conditions are met (U.S. Congress 2003). The intent of the policy is to "support the construction of new facilities which add additional revenue producing capability for the facility." Before any AIP funding is allowed under this provision, a number of conditions must be met, including (a) a determination by the FAA that the airport's airside needs have adequate funding, (b) verification that current FAA Safety Area and Runway Protection Zone standards are being met, and (c) that the federal share of these facilities is funded with non-primary entitlements (FAA 2010b). These provisions refer specifically to fuel storage; however, AIP funding for alternative jet fuel production is not eligible. Refining and manufacturing of aviation fuels, whether from conven- tional or alternative feedstocks, are not aeronautical activities. Definition of Aeronautical Activities and Its Relationship to Alternative Fuels Production The definition of an aeronautical activity as defined in AC 150/5190-7 includes "any activity that involves, makes possible, or is required for the operation of aircraft or that contributes to or is required for the safety of such operations" (FAA 2006a). Furthermore, AC 150/5190-7 states that aeronautical activities include "any other activities that, because of their direct relationship to the operation of aircraft, can appropriately be regarded as aeronautical activities." Common aeronautical activities include but are not limited to general and corporate aviation, air taxi and charter operations, scheduled and nonscheduled air carrier operations, and sale of aviation petroleum products. The handling, storing, and delivery of jet fuels into an airplane may be considered an aero- nautical activity as long as 100% of the fuel is delivered to aircraft on the airport and not distrib- uted elsewhere. Therefore, on-airport fuel storage (but not production) may be eligible but only using non-primary airport entitlements.
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104 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting Other Considerations Regarding AIP and Alternative Jet Fuel Facilities In addition to the items discussed previously, there are other considerations related to AIP and associated mechanisms that should be considered, including: Section 25, Airport Revenues of the FAA's Airport Sponsor Assurances, specifies require- ments for those airports having to meet grant assurances (FAA 2005c). One of the provisions states that "all revenues generated by the airport and any local taxes on aviation fuel . . . will be expended by it for the capital or operating costs of the airport; the local airport system; or other local facilities which are owned or operated by the owner or operator of the airport and which are directly and substantially related to the actual air transportation of passengers or property; or for noise mitigation purposes on or off the airport." Consequently, revenues from the sale of alternative jet fuel would have to be re-invested in the airport or airport system in order to meet grant assurances. The Airport Grant Assurance Compliance Certification Form provides further support to this interpretation. Section K, Utilization of Airport Revenue, states that airports subject to any fed- eral agreement are obliged to "apply revenue derived from the use of airport property toward the operation, maintenance, and development of the airport. Diversion of airport revenue to a non-airport purpose must be approved by the FAA" (FAA 2005a). Other questions regarding compliance with grant obligations and other funding mechanisms for those areas of alternative jet fuel production and distribution for which implications to grant assurances are new in nature or otherwise unclear are best handled by coordinating with the appro- priate local Airport District Office. In addition, adherence to items in the Airport Sponsor Assur- ances (FAA 2005c) and Airport Grant Assurance Compliance Certification Form (FAA 2005a) will provide the best avenue for compliance. I.2 Environmental Reviews and Permitting Environmental reviews and permitting will be requisite activities in the planning process for any alternative jet fuel production and distribution project. Jurisdictions at the federal, state, and local levels require permits for those activities or facilities that they view as affecting the environ- ment, safety, or equity of the surrounding population. Alternative jet fuel plants affect each of these three components. In general terms, the main categories of interest in the environmental review and permitting process tend to be the following: · Water quality, including environmental impact on drinking water, groundwater, wastewater, and surface waters including storm water, coastal areas, wetlands, or floodplains. · Air quality, including environmental impact of gaseous and other emissions. · Impacts to endangered species and historic, coastal, or other environmental resources by facility construction, operation, maintenance, or access. · Land quality, including solid waste disposal, hazardous waste handling and disposal, and spill prevention, reporting, and cleanup. · Land-use planning and zoning, including impacts to shared infrastructure such as roads and railways. I.2.1 Environmental Review At the federal level, alternative jet fuel projects need to comply with NEPA and applicable laws protecting sensitive environmental resources. NEPA outlines a process by which agencies are required to determine if their proposed actions have significant environmental effects. Depending on a number of factors, including the severity of the environmental effects, a CE, EA, or EIS may
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Regulatory Considerations 105 be required (see FAA Order 1050.1E for more information). Environmental effects that may need to be analyzed include growth-inducing effects related to changes in land use, population den- sity, and related effects on air and water and other natural systems, including potential impacts to ecosystems that an action may cause. In particular, the environmental issues addressed in the Envi- ronmental Desk Reference for Airport Actions (FAA 2007) or Appendix A of Order 1050.1E should be investigated during the NEPA process. This must occur thoroughly before FAA makes a deci- sion on approving an alternative jet fuel facility. For alternative jet fuel projects on-airport, airports should refer to FAA Order 1050.1E, which is the FAA's umbrella guidance for NEPA compliance. Installation of on-airport fuel facilities requires the FAA to issue an unconditional approval to an airport layout plan. This requires the FAA to complete its environmental analyses under NEPA and other special pur- pose laws (FAA 2007). At the state and local level, there is a high degree of variation in terms of environmental review and permitting requirements and regulations. Many states are developing review processes and integrated guidance materials on environmental review and permitting activities relative to infra- structure that may be applicable to alternative jet fuel projects (see Section 6.2). Furthermore, the EPA maintains a database of state-specific regulatory information at http://www.epa.gov/lawsregs/ states/index.html#state. Readers should consult this resource for guidance specific to their local conditions. I.2.2 Environmental Permitting This subsection provides an overview of federal, state, and local permitting processes to iden- tify the breadth of permitting requirements that might be expected in developing alternative fuel production, storage, and distribution infrastructure. This is not intended to be a comprehensive review since requirements and processes vary from jurisdiction to jurisdiction. There are various motivations for permitting. Environmental permitting encompasses numerous and detailed processes instituted to ensure protection of public health, safety, and environmental quality. These permitting requirements vary from state to state and also have local nuances with respect to county, city, and other jurisdictional requirements--and they apply to the production of alternative fuels as they do to any other facility. In addition, federal require- ments under NEPA and other federal regulations may be applicable to alternative jet fuel facili- ties depending on location and proximity to state or federal waters, endangered species, and historic and archeological resources. Most of the existing guidance issued by jurisdictions pertains to biodiesel facilities, not specif- ically to alternative jet fuel. However, the permitting process for biodiesel should be a reason- able approximation for that of alternative jet fuel. For example, the State of Washington has two publications pertaining to biodiesel permitting. One of them is a fact sheet that lists the permits, regulations, and tax benefits associated with a biodiesel plant (State of Washington 2010a). Another example appears at the State of Washington's Department of Ecology website (State of Washington 2010b). Table 19, taken from that website, lists the permits that a biodiesel manu- facturer should consider; furthermore, the department notes that these are the commonly required permits but that the permits needed are not limited to those listed in the table. This qualification confirms the uncertainty inherent in the permitting process. I.2.3 Land Use and Zoning in the Vicinity of Airports Being a good neighbor is often a principle that airports adopt since it can enable a mutually beneficial relationship between airport operators and surrounding developments and avoid
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106 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting Table 19. Examples of commonly required permits (State of Washington 2010b). Jurisdiction Type of Permit City and Building county Preliminary/final plat Grading Water system Shoreline Right of way Utility Site plan review Septic system Floodplain development Variance (zoning, shoreline, etc.) Outdoor burning State Dept. of Fish and Wildlife Hydraulic project approval Bald eagle management Grass carp Shooting preserve Dept. of Natural Resources Forest practices Aquatic lease Burning (forest slash) Reclamation Dept. of Ecology Water rights Well drilling National Pollutant Discharge Elimination System (NPDES) Water quality certification Storm water Underground storage tank certification Dangerous waste Air Authority/Dept. of Ecology New source review, for a business or industry Notice of intent, for demolition projects Federal U.S. Army Corp of Engineers Section 10 (Navigable Waters) Section 404 (Fill in Waters) U.S. Coast Guard Section 9 (Bridges) National Marine Fisheries/U.S. Fish and Wildlife Endangered Species Act consultation potentially costly litigation. In order to avoid conflict with airport surroundings, land-use zon- ing must be done carefully in the areas near an airport. In general, zoning rules and regulations vary considerably from one jurisdiction to another, and it is not practical to summarize them in this document. Airports should consult ACRP Report 27: Enhancing Airport Land Use Compatibility (Ward et al. 2010) for a deeper discussion of this topic. Nevertheless, there are a few general observations that can help airports evaluate alter- native fuel projects with respect to zoning:
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Regulatory Considerations 107 · Obstacles to air navigation: The FAA requires that there be no object, man-made or natural outgrowth, that is 200 ft from the ground level of the airport and within a 3-nautical-mile radius of the established reference point of the airport. Other requirements are listed in FAR Part 77. · Noise assessment: If construction of alternative jet fuel facilities would require modifications to existing airspace procedures, a proper EIS is needed before the FAA could approve route changes when there is a significant noise impact on the affected population. See Section I.2.1 for more information on EISs. · Agricultural land near airports: The FAA recommends against using airport property for agricultural production because agricultural crops can attract wildlife during some phase of production (FAA 1997b). If the airport requires agricultural crops as a means to produce income necessary for the viability of the airport, it needs to follow the crop-distance guide- lines established in AC 150/5300-13, Appendix 17. Airports should be advised that the FAA may require a WHA or WHMP when specific triggering events occur on or near an airport, as specified in 14 CFR Part 139, Certification of Airports. Such events include an air carrier aircraft striking wildlife, an air carrier aircraft engine experiencing an engine ingestion of wildlife, or observing wildlife of a size or in numbers capable of causing an aircraft strike or engine ingestion. The WHA plan must be conducted by biologists with the appropriate train- ing and education specified in AC 150/5200-36. Agricultural land use is compatible with air- port operations from a noise sensitivity perspective (FAA 2001). I.2.4 Additional Notes on Permitting One significant risk with the permitting process is that it can stall a project's implementation or scuttle it entirely. Because of this risk, incorporating adequate lead time is absolutely neces- sary to meet all permitting requirements and not to incur delays in project coordination, plan- ning, design, engineering, site preparation, construction, and inspection necessary for the development of alternative fuel infrastructure. Front-end planning for permitting with appro- priate time buffers for areas of risk or uncertainty will allow for some flexibility in schedule adherence given the numerous permitting requirements that will inevitably vary with selection of a particular site. This section has emphasized the motivation, complexity, and uncertainty associated with per- mitting. Because each alternative jet fuel facility carries its own risks, the permitting process is almost customized to each situation. Therefore, an airport that seeks to install alternative jet fuel facilities of any type should refer to a consultant with expertise in this matter and incorporate the recommendations into the project plan. I.3 Energy Policy Support for alternative jet fuel projects comes from various entities and policies, including the federal government and NGOs. This section summarizes some of the most visible entities and policies and indicates how they may be helpful to alternative jet fuel projects: · White House energy policy The current administration in the White House has a policy framework that supports both biofuels production and the allocation of those funds to aviation fuel sources. These policies include but may not be limited to the following: On May 5, 2009, the biofuels policy framework established the USDA's commitment to allocate funds to biofuels development. USDA announced its approach to meeting that commitment in June 2009 (USDA 2009).
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108 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting In February 2010, the Biofuels Interagency Working Group issued its report highlighting aviation fuel deployment. The report specifically calls for using pre-established market out- lets and customer purchase commitments to stimulate production of feedstocks and bio- fuels (USDA 2010h). · The FAA Office of Environment and Energy sets policy and offers programs to monetize the benefits of using alternative fuels. Relevant initiatives sponsored by this office include: Next Gen Environmental Working Group. This group, part of JPDO, sets goals for car- bon and particle emission reductions. As part of NextGen, FAA and project contributors have the objective of finding ways for aviation to grow without increasing its environmen- tal impact. Much of the progress in quantifying the life-cycle carbon benefits of alternative fuel is a result of programs initiated to accommodate those goals. PARTNER Project 28: Environmental Cost-benefit Analysis of Alternative Jet Fuels. This project quantifies aviation-specific GHG levels for a range of alternative fuel options that may be proposed for adoption by airports and their stakeholders (PARTNER 2010c). The analysis includes effects of land use (direct and indirect) and provides uncertainty bands to set the range of possibilities for outcomes. PARTNER Project 20: Emissions Characteristics of Alternative Aviation Fuels. This project characterizes particle emission measurements for a series of alternative fuels (PARTNER 2010a). PARTNER Project 27: Environmental Cost-Benefit Analysis of Ultra Low Sulfur Jet Fuels. This project established the health effects of particles for use in conjunction with the FAA's APMT suite (PARTNER 2010b). The FAA has other programs that can be of interest to alternative aviation fuel projects. These include: Voluntary Airport Low Emissions Program: VALE was established in 2004 to help com- mercial service airports in designated air quality non-attainment and maintenance areas reduce airport ground emissions (FAA 2011b). VALE allows airport sponsors to use the AIP and PFCs to finance low-emission vehicles, refueling and recharging stations, gate elec- trification, and other airport air quality improvements. While VALE is restricted to ground emissions, it could still be helpful for alternative jet fuel projects. For example, airports that participate in VALE gain valuable experience structuring projects and handling alternative fuels that could be useful for alternative jet fuel projects. Furthermore, some stationary sources that contribute to ground emissions, such as back-up generators, could theoreti- cally use alternative jet fuel. Sustainable Master Plan Pilot Program: This program was recently introduced by the FAA. Participants evaluate ways to make sustainability a core objective at every airport (FAA 2011a). The program funds long-range planning documents at 10 airports around the country. These documents, called Sustainable Master Plans and Sustainable Man- agement Plans, will include initiatives for reducing environmental impacts, achieving economic benefits, and increasing airport integration with local communities. The pro- gram is projected to end in late 2012. This program may provide valuable information to airports interested in integrating alternative jet fuel projects into their sustainability initiatives. · Programs to fund studies and other nonrecurring investments in alternative fuels The following programs exist at the federal, state, or local levels: 2008 USDA Budget Authorization, section 9000 for renewable energy proposed rules asso- ciated with BCAP (USDA 2010c). Federal and state policies and programs for rural renewable project evaluation and devel- opments, such as value added grants and state enterprise grants (USDA 2010p; USDA 2010m).
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Regulatory Considerations 109 Organized state and local policies and coalitions to promote regional growth, for example the State of Georgia's Centers for Innovation (GCI 2011). Military Title III programs, which can enable initial plant construction for national defense priorities (Finnessy 2006). · Policies to allow recurring support for energy projects These policies can take a variety of forms, including tax incentives, insurance for crops, and tax credits for the alternative fuels. These programs exist at the federal, state, or local levels: Possible price supports for growers and price collars for buyers and sellers, similar to those available for food crops (USDA 2010k). Crop insurance similar to that available for food crops (USDA 2010f). DOD policies involving alternative fuel commitments, such as the plan to have 50% of continental U.S. military jet fuel consumption sourced from synthetic fuel blends (Andrews 2009). Tax credits, such as the one-dollar-per-gallon tax credit for biofuels (currently renewed on a year-by-year basis) (American Fuels 2010). · Nongovernmental, industry trade association stakeholder goals and policies IATA and its stated industry goal of carbon neutral growth by 2020 (IATA 2010). Air Transport Association policy on alternative fuels (ATA 2010c). ATA/AIA biofuel producer policy letter to President-Elect Obama (Altman 2010). Airport associations, such as Airport Council InternationalNorth America sustainability and business policies (ACINA 2010). Roundtable on Sustainable Biofuels best practices (RSB 2010). Growers association policies and plans: Projects such as value-added grants need to be sub- mitted for funding--in many cases through agricultural institutions. Therefore, the poli- cies of these organizations are relevant for planning purposes. One example of this process is afforded by a proposal made via the Ohio Soybean Growers Association (OHSOY 2010) for a brownfield plant conversion to produce alternative jet fuel. Environmental NGOs: Several environmental NGOs, such as the National Resources Defense Council and the World Wildlife Federation, have participated in alternative jet fuel forums at the request of CAAFI in the United States and SWAFEA in Europe. · Public/Private Partnerships and Coalitions Several organizations focused on the development and deployment of alternative jet fuels have been formed over the past few years. These include: Commercial Aviation Alternative Fuels Initiative: CAAFI is a coalition of government and private-sector organizations, including the FAA Office of Environment and Energy; AIA, representing manufacturers; ATA, representing airlines; and ACINA, representing airports (CAAFI 2010). CAAFI's 350 members represent nearly 250 separate entities, including some 17 U.S. government agencies. CAAFI is organized around four working groups covering qualification of fuels for safe use, environmental benefit calculation, research and development of all feedstocks and processes, and deployment. These working groups operate in concert with the ATA Energy Council of fuel buyers and some 50 energy company stakeholders. CAAFI seeks to facilitate deployment of alternative jet fuels, and its airline sponsor (ATA) has been involved with several ACRP problem statements related to alternative jet fuel. ATA/Defense Energy Support Center Alliance: In March 2010, ATA signed an agreement with the DLA (formerly DESC) to pursue joint policies for the purchase of alternative fuels. The alliance seeks to align purchasing policies, promote deployment, and pursue common economic policies (ATA 2010b). Farm to Fly: The Farm to Fly coalition of interest between the U.S. Department of Agricul- ture, the airline industry (ATA), and Boeing was formed in July 2010 as the result of dialog
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110 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting between the Secretary of Agriculture and industry representatives (ATA 2010a). It specifi- cally seeks to encourage deployment activity, initially working on bottom-up models for developing fuel supplies for aviation regions of the United States. The concept is beginning with studies in the Pacific Northwest and Hawaii. Regional coalitions: There are also regional initiatives focused on partnerships for the development of alternative fuel projects in specific geographic areas. Examples include the Georgia Center of Innovation for Energy (GCI 2011), the Hawaii Renewable Energy Alliance (HREA 2011), Clean Fuels Ohio (CFO 2011), and the Sustainable Aviation Fuels Northwest in the U.S. Pacific Northwest (SAFNW 2011a). SAFN just published a detailed report analyzing and evaluating the potential for alternative jet fuel production in their region (SAFNW 2011b).