Published on the 11th of March, 2022
Innovations in SAF production have implications for Environmental Licensing
The use of sustainable fuels in aviation, produced from renewable energy sources, has been consolidated in recent years as part of the global search to reduce greenhouse gas (GHG) emissions. Several countries, aiming to make this endeavor a reality, started to put into practice political and technological strategies in favor of clean aviation. In this sense, the ProQR – Alternative Fuels without Climate Impacts is an initiative founded from the cooperation between the governments of Germany and Brazil, which aims to enable the production of Sustainable Aviation Fuels (SAF) on Brazilian territory.
Currently, aviation is responsible for about 2.5% of GHG emissions worldwide. SAFs are fundamental to change this worrying scenario. However, it is not enough that they are produced and placed on the market, it is necessary that this production occurs in a way to cause the minimum environmental impact. Besides the use of renewable energies, ProQR defends the construction of small (modular) plants, close to airports, which will produce the fuel in its place of consumption.
Committed to making this disruptive proposal for the production and use of SAF in Brazil feasible with the least possible environmental impact, ProQR has established some priority agendas, including strategies for environmental licensing. This is an essential stage for construction projects in Brazil, making it necessary to analyze in advance the viability of SAF production plant projects that meet the regulatory, administrative and legal requirements of licensing agencies. Thus, in 2020, ProQR promoted the study “Preliminary Environmental Assessment for the Licensing of Renewable Aviation Fuel Production Plants Near Remote Airports in Brazil” (in Portuguese).
In 2021, the ProQR project held two participatory actions aimed at bringing to the public the discussions proposed by the study. The webinar “Environmental Licensing for SAF Production Plants – Challenges and Perspectives” and two training editions on the topic counted with over 50 participants, among them technicians in environmental licensing and representatives of the Brazilian airport sector, as well as of state licensing agencies. The dialogues developed between these three distinct areas helped enrich the panorama for the future of enterprises in this area. As a result, the following considerations were appended to the relevant baseline study.
SAF generates positive environmental effects
The study presents a detailed, though not exhaustive, approach to the most relevant and strategic issues for the licensing discussion. In this way, it discusses the advantages and disadvantages, from the environmental point of view, of the production and use of SAF in Brazil in comparison with conventional aviation fuel. The main arguments in favour of SAF are based on its contribution to the decarbonisation of Brazilian aviation, since Sustainable Aviation Fuels use CO2 as their main feedstock, have their production based on an electro-intensive process that uses exclusively renewable energies (solar and/or wind) and do not emit sulphur compounds in their production and consumption.
Another point raised in the study is that the ProQR approach for the production of SAF in a decentralised way is very relevant in the Brazilian territorial context. With the current distribution of airfields in Brazil, many of them in remote areas, they depend on other modes of transport to be supplied, especially road transport. The installation of SAF plants within the airport site has the potential to drastically reduce the release of GHG from the fuel used to move the tanker trucks.
In addition, the study analyses the SAF production steps proposed by ProQR and tracks the possible technical benefits and environmental impacts of the project to then make a comparison with conventional fuel. To this end, it describes the production routes of SAF and points out the by-products, residues and effluents that may imply impacts on the environment. Thus, such aspects may be taken into consideration during the planning of SAF plant projects, so as to present management alternatives or solutions at the time of environmental licensing.
Broad environmental licensing legislation requires an eye for detail
The background document also presents the legislation that governs the environmental licensing procedures applicable to SAF production plants. Today in Brazil there is no normative apparatus with specific guidelines for Sustainable Aviation Fuel plants. In this sense, every assessment at national, state or district levels, is based on the first Resolution of the National Environment Council (Conama) in 1986 and subsequent ones, in other words, on general norms directed to infrastructure undertakings, energy generation and fuel production. There are different types of licenses, however, Licensing agents are often faced with gaps that require special engagement to contextualize their analysis. In the case of SAF plants, ProQR publications provide relevant inputs.
Within the scope of ProQR events, the dialogues concluded in favour of the applicability of a “Simplified Environmental Licensing (LAS)” process. This process is applied to small enterprises with low polluting potential, a category in which the decentralised and modular approach to SAF, especially in remote areas, generally fits. On the other hand, depending on the origin of the feedstock, the source of energy used and the potential residues from the production of SAF, one may consider the three-phase licensing, which requires the elaboration of an Environmental Impact Study (EIA) to support the decision in stages, namely: Preliminary License (LP) and Installation Licenses (LI) and Operation Licenses (LO).
With the purpose of supporting and consolidating the licensing for the specific case of decentralized SAF plants, the baseline study elaborates several guidelines. One of them recommends detailing the planned installation in order to detect relevant environmental effects on related industries. The dialogues in the thematic events mentioned above showed that in this detailing the consideration of diverse feedstock that can integrate the life cycle of the SAFs is fundamental. For example, the use of biomass or so-called liquid and gaseous biofuels, such as ethanol and biogas/biomethane, requires greater attention during the licensing process. Also in this context, results of the ProQR study on the “Syngas Potential in Brazilian Industries”, indispensable input in the production of synthetic fuels, represents a relevant addition to the basic study: Depending on the origin of the feedstock, if resulting from activities considered to have a high potential of environmental impact or if the hydrogen obtained is not certified as green H2, the licensing cannot be simplified. This condition should be analyzed on a case-by-case basis and a three-phase licensing may be required.
It should be noted that depending on this framework, there could be a conceptual conflict, since the electro-fuels (SAFs), by definition, should be produced from renewable energy and/or CO2 captured from the atmosphere or from industrial processes, and it is possible that hydrogen as a source of heat and energy be declared as “green” in the process. The arrangement of this production chain influences the subsequent process of certification and final declaration of the fuel as SAF.
Collaborative practice among agents eases licensing processes
At the ProQR events, other guidelines exposed in the study were validated by the technical-scientific community, such as a reference environmental mapping for decision-makers, which contemplates remote airports, the ecosystems in regions with potential for SAF and the flows and actors of conventional QAV distribution. In addition, the proposal to establish a bureaucratic rite for simplified licensing was reinforced, relying on a participatory process of agents and decision-makers, as well as sectors of civil society involved. In this, it was evaluated as desirable the complementation of normative, bureaucratic and legal rites at state level (per Federation Unit), which also concern the norms, restrictions and regulations in force for airport spaces. In short, the licensing process is immersed in an interdisciplinary field. The environmental issue should be considered transversally in the business plan of these plants and should guide an agile and well-founded process. Thus, one can expect a greater legal security to the bureaucratic process under the responsibility of the Federation Units in Brazil.
While in Brazil the SAF production projects become progressively dynamic, the continuity of studies and articulations about the environmental viability of the plants and the interface with the agents responsible for licensing becomes increasingly important. ProQR catalyses initiatives that can enrich and expedite this dialogue, in order to continue supporting the country’s energy transition towards a more sustainable transport matrix.
Ruth Barbosa and Lucas Freire contributed to this article.
