Published on September 8th, 2021

The legal procedure of Environmental Licensing is an essential step for most construction enterprises, including the sustainable aviation fuel production plants promoted by the ProQR project in Brazil. To stimulate knowledge and dialogue on the subject, ProQR hosted a webinar on “Environmental Licensing for SAF Production Plants – Challenges and Perspectives” on the 24th of August with stakeholders across Brazil involved in the topic.

The webinar aimed to disseminate the study “Preliminary Environmental Assessment for the Licensing of Renewable Aviation Fuel Production Plants Near Remote Airports in Brazil” (in Portuguese) produced by ProQR in 2020. The speakers offered a general, technical and multi-sectorial overview on environmental licensing of Sustainable Aviation Fuel (SAF) production plants. As the environmental licensing process is the responsibility of individual states, two proposals from Ceará and Bahia – states at the forefront of energy innovations in Brazil – were presented. The dialogue was introduced to offer an overview of the topic, identify challenges, and to attract security partners and possible investors.

In the following paragraphs, we present the presentation summaries from each of the speakers:

  • Maria Angélica Garcia, author of the study
  • Fued Abrão Junior, Infraero’s Environment Superintendent
  • Waslley Maciel, Manager of Environmental Licensing at the Secretariat of the Environment of the State of Ceará
  • Ítalo Taeno, Secretary of Environment of Ceará
  • Leonardo Carneiro, Brazilian Association of State for Environmental Entities

ProQR Vision

At the event, Maria Angélica Garcia pointed out the main guidelines of the study:

“To propose effective and feasible actions to guarantee the bureaucratic rites of a safe environmental licensing from a legal, social and environmental point of view. The big point is the reduction of emission and greenhouse gases”.

In this context, the Maria addressed the advantages of SAF for aviation compared to fossil fuels to reduce greenhouse gas emissions from aviation.

What are the Major Advantages of SAFs Compared to Fossil Fuels?

Garcia pointed out that firstly, SAFs reduce GHG emissions in production and do not emit gases containing sulphur. In addition, the blend of Jet Fuel (QAV, abbr, in Portuguese) used in aircraft is already allowed (50%) according to resolutions nº778 and 779/2019 of the ANP. The use of water in the process is also significantly lower and more attractive from an environmental point of view.

Finally, for the ease of the licensing process, Maria reiterated the importance of environmental analysis to best understand to best understand the short and long-term impacts of the process.

Airport Vision

Fued Abrão Junior, Infraero’s Environment Superintendent, presented the airport perspective on the production of SAF. To better understand this part of the process, he stressed the importance of a firm grasp of airport management.

As for aircraft emissions and the emissions from the airport itself, there are two international agreements aimed at reductions: the Carbon Off Setting International Aviation (CORSIA) Scheme, and the Airport Carbon Accreditation (ACA). The ACA deals specifically with airports and the emissions generated at the airport itself. There is also a National Air Plan (2018-2038) that establishes the production of sustainable fuels on a commercial scale as a strategy to ensure competitiveness and sustainability in the airline sector in the medium and long-term.

Regarding the installation and operation of SAF plants, Fued mentioned that:

“First we have to consider the context, the airport is a highly regulated environment and there are several measures that need to be considered or executed to ensure the implementation of a SAF plant is feasible.”

A handful of those measures include: the issue of a protection zone and height restriction for a landing and take-off airfield. The plant also needs to be in accordance with the Airport Master Plan. Fued reiterated the importance of a synergy between the National Agency of Oil and Gas (ANP), National Environment System (Sisnama) and the National Civil Aviation Agency (ANAC).

In addition, he said that the SAF plant when installed will correspond to a commercial area concession, so everything needs to be internalised in the contractual aspect.

Still, to contextualize the local production of SAF, Fued described the inefficient distribution of jet fuel in Brazil, especially in the northern region of the country, and stressed the potential of isolated systems of SAF production.

Vision of the Licensing Body

Waslley Maciel, Manager of environmental licensing at the Secretariat of the Environment of the State of Ceará, presented the vision of the Environmental Licensing Agency. This included the Applied Environmental Legislation and the tasks needed to undertake it. He anticipated that the documents needed to grant environmental licenses would include: the Environmental Viability Study (EVA), a risk analysis, and an emergency and contingency plan.

Regarding fuel storage, Ítalo Taeno from the Secretariat of Environment for the State of Ceará, pointed out the need to evaluate potential environmental risks from the installation of tanks – such as the risk of fuel leakage. The management of waste generated by the plant was also highlighted as a key issue for the licensing processes.

Leonardo Carneiro da Cruz, the Director of Regulation for the INEMA Bahia, predicted that sustainable aviation fuel (SAF) production plants would be easy to license in the state of Bahia. He mentioned that due to the solar power potential at Salvador Airport, the installation of a SAF Production Plant would require only an extension of the existing license. Leonardo also mentioned Bahia’s experience and interest in this type of enterprise. Challenges include the need for adequate training of licensing agents – a hurdle that online trainings like this aim to tackle.

Contributor to this article is Ruth Barbosa

Presentations

The speakers’ presentations are available in Portuguese:

To access the recording of the Webinar, click here (Portuguese only).

Environmental Licensing Training (Portuguese Only)

Deepening the content of the event, ProQR invites interested parties to a full-day training event in Environmental Licensing. This will occur over the coming weeks in two editions. The facilitation is going to be held by Consultant Maria Angélica Garcia and colleagues:

  • First Edition 30/09 and 01/10 (morning)
  • Second Edition 14/10 and 15/10 (morning)

Language: Portuguese.

Interested? E-mail: proqr@giz.de, with the subject line “Capacitação Licenciamento Ambiental“.

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