Industry Insights with Graham Noyes, Low Carbon Fuels Coalition – SAF’s place in U.S. politics
Graham Noyes
Executive Director
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Low Carbon Fuels Coalition
Graham Noyes, the Executive Director of the Low Carbon Fuels Coalition, and an expert in state-level SAF policy, California in particular, shares his views on how SAF fits into the U.S. political agenda, and the importance of credit stacking to create ‘SAF hubs’.
Can you tell us a bit about yourself and your role?
I have long been fascinated with the expansion of the biofuels industry and policy. My first role in the industry was a commercial one- I led up the development of the biodiesel market in the western US for World Energy beginning in 2001. I went on to lead sales and business development first for World Energy and then for Imperium Renewables. Industry veterans will recall that Imperium was the company that supplied 20% biojet fuel made from coconut oil and babassu to Sir Richard Branson’s Virgin Atlantic 747 test flight in 2008. Later that year, the U.S. biodiesel industry faced tremendous challenges when Europe imposed countervailing duties on biodiesel and the Great Recession began.
At that time, I joined the law firm of Stoel Rives in Seattle to provide regulatory analysis to biofuels and bioenergy companies and to assist in project development work. After returning to California in 2015, I established my own firm focused on California’s Low Carbon Fuel Standard (LCFS), other environmental attribute programs and state-level SAF Policy. In particular, I worked with airlines, airports, other stakeholders and CARB and DEQ on behalf of my SAF clients to bring alternative jet fuel into the California LCFS and the Oregon Clean Fuels Program on an opt-in basis.
What do you believe will be the biggest contributor to decarbonizing the aviation industry in the next 20 years?
Due to the vital importance of SAF to the aviation industry’s decarbonization and the airlines’ broad willingness to rapidly transition to SAF, the good news is that we have a motivated customer. The challenge remains the green premium associated with SAF as compared to fossil-based jet fuel. The biggest contributor to decarbonization will be the public’s growing recognition that the impacts of climate change ultimately cost us far more than the green premium. Once consumers and policy makers have recognized the true costs of petroleum fuels and the SAF industry has had the opportunity to scale multiple feedstocks and technologies, SAF will be the dominant fuel. It’s extremely difficult to predict how long that will take.
Do you see SAF and aviation decarbonization fitting into the political agenda, either in the USA or globally?
Our political agenda must embrace SAF and economy-wide decarbonization in time to slow and ultimately reverse the warming of the earth and the resulting catastrophes. These catastrophes have real-world health, safety and economic consequences. I live in the foothills of California where wildfires have destroyed entire communities. The loss of lives and property caused by these fires is increasingly driving homeowner’s insurance costs through the roof or making homes uninsurable.
Tragically, it seems to be the case that more people will need to suffer the costs and catastrophes of climate change in order to gain broad support for the strong science-based policies required to first slow climate change and ultimately to restore equilibrium. The good news is the decarbonization technologies in the energy sector have scaled and become more cost-effective than anyone anticipated and are now saving consumers money. The on-road sector is making great progress with both electrification and biofuels, and I see tremendous potential for future SAF expansion.
How important is public and political support in the acceleration of SAF production, does one come before the other?
Public and political support are both essential to the scaling of SAF. The U.S. is one of the world’s leading producers of SAF yet the U.S. Energy Information Administration reported U.S. capacity at the beginning of 2024 was just over 30 million gallons per year. To meet the SAF Grand Challenge goal of 3 billion gallons a year by 2030 requires a 100x scale-up in five years. There is already good public support for SAF production in the abstract but there is not the level of consensus and urgency necessary to enable such rapid scaling of sustainable feedstock sourcing and SAF production capabilities. What remains lacking as the foundation for policy is sufficient public recognition of the causation and costs of climate change and the need for strong policies. Once those links and costs are recognized and accepted more broadly as they already are in the younger generations, the knowledge and fear of the adverse consequences of climate change will drive politicians to act upon it.
In 2024 almost half the global population has, or will, vote, with elections held notably in the USA, Brazil, the UK, the EU, and Australia. What impact do you think changes in political leadership could have on the funding and development of SAF production?
In the U.S., there remains a strong resistance to acknowledging the inconvenient truth of climate change. The lack of recognition is perpetuated by well-funded media and public relations campaigns and a political system that allows unfettered and even untraceable spending by special interests. However, there is a growing experience of real-world climate change impacts and broadening understanding of the need for climate action. Elections this year and in future years will determine whether we slow or accelerate the rate of climate change and ultimately accelerate or diminish the resulting health impacts and climate disasters.
What are the current political and policy challenges in advancing SAF?
The aviation industry has done a fabulous job of the science of SAF: establishing multiple process technologies that can utilize a wide range of feedstocks to produce SAF than can be uplifted into aircraft at up to a 50% blend level today. The political challenge is to convince people that the green premium actually is a good investment that saves us money in the long run as compared to business as usual. The technological challenge is to scale and drive down the green premium. The policy challenge is to build stackable policies to reduce the green premium sufficiently to enable achievement of the SAF Grand Challenge goals in 2030 and 2050.
Selecting a region of your choice, what do you believe needs to happen in policy to enable the aviation industry to meet net zero by 2050?
My practice focuses on expanding state-level SAF policy. The opportunity in individual states is to build stackable policies that create multiple vibrant U.S. SAF hubs by the late 2020’s to meet the goals of the SAF Grand Challenge. These SAF hubs will drive airport competition as the hubs will attract more airlines that recognize the imperative of SAF- and must comply with CORSIA, meet corporate sustainability goals and steward the future of the aviation industry.
To properly design all levels of policy, we need to use the tremendous data-gathering, economic analysis and scientific capabilities that our society has developed to inform life cycle analysis. This effort can leverage one of the great opportunities that exists in state-level policy development: robust public processes with stakeholder input to inform complicated and evolving policies crafted by experienced and dedicated personnel who staff and manage energy and environmental agencies. It is only through such a rigorous approach that we can ensure that the various feedstocks and finished fuels are scored from a carbon intensity standpoint as accurately as possible. We also need to enhance engagement with SAF skeptics to understand their critiques and concerns.
Through constructive engagement, we all need to ensure that SAF can be scaled without adversely affecting food security, biodiversity, and other global economic and social values.
Would you like hear directly from policymakers about federal and state level SAF incentives?