SAF Blending and Logistics

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Sustainable Aviation Fuel

Blending and Logistics

NREL/TP-5400-90979 • September 2024

Kristi Moriarty and Robert McCormick


Sustainable Aviation Fuel
Blending and Logistics
Kristi Moriarty and Robert McCormick
National Renewable Energy Laboratory

Suggested Citation: Moriarty, Kristi, and Robert McCormick. 2024. Sustainable Aviation Fuel Blending and
Logistics. Golden, CO: National Renewable Energy Laboratory. NREL/TP-5400-90979. https://www.nrel.gov/docs/
fy24osti/90979.pdf.

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Preface
This report is an update to the 2021 report from the National Renewable Energy Laboratory, U.S.
Airport Infrastructure and Sustainable Aviation Fuel (www.nrel.gov/docs/fy21osti/78368.pdf).
The previous report was prepared at a time when there was a single production facility and
provided recommendations for blending. As more production plants have come online, as well as
more commitments from the aviation industry, the report was updated to address current market
needs. This report is focused on the United States market.

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List of Acronyms
ATJ alcohol-to-jet
COA certificate of analysis
EIA U.S. Energy Information Administration
EPA U.S. Environmental Protection Agency
FAA Federal Aviation Administration
FT Fischer–Tropsch
HEFA hydroprocessed esters and fatty acids
IATA International Air Transport Association
ICAO International Civil Aviation Organization
PADD Petroleum Administration for Defense District
RCQ refinery certificate of quality
SAF sustainable aviation fuel
SKA synthetic kerosene with aromatics
SPK synthetic paraffinic kerosene

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Executive Summary
Decarbonizing aviation requires a multipronged approach in both alternative fuel use and
efficiency to meet emissions reductions and sustainability requirements and goals. In 2022,
aviation accounted for 2.1% of human-induced carbon dioxide (CO2) emissions and 12% of
transportation CO2 emissions (ATAG 2024). About 80% of aviation emissions are from flights
longer than about 930 miles (ATAG 2024). Aviation was also responsible for 9% of domestic
transportation greenhouse gas emissions in 2022 (EPA 2022). The United States has a significant
commercial aviation sector accounting for nearly 28% of global jet fuel use (IATA 2024b, EIA
2024g).

Sustainable aviation fuel (SAF), made from nonpetroleum feedstocks, significantly reduces
aviation emissions. SAF must be blended with petroleum-based jet fuel prior to its use in
aircraft. 1 SAF is a commercially available fuel in its early stages of production development.
There are three domestic plants and one international plant supplying the U.S. market as of mid-
2024. Numerous pilot- and demonstration-scale plants in the United States and globally are
demonstrating the ability to make SAF from multiple feedstocks and technology pathways.
Public data for the Renewable Fuel Standard show significant growth in the domestic market
over the past few years, with 26 million gallons in 2023 and nearly 62 million gallons January
through July 2024. This report explores background information on jet fuel use, quality standards
and practices, and options for blending and delivery to airports.

Jet fuel quality standards and certification documents are essential to fuel performance,
operability, and safety (Holladay et al. 2020). All parties involved—including from production,
supply chain, the airport, and aircraft—are responsible for maintaining the quality and
traceability of jet fuel and SAF. Jet A fuel meets ASTM D1655, Standard Specification for
Aviation Turbine Fuels (ASTM International 2022). 2 ASTM D7566, Standard Specification for
Aviation Turbine Fuel Containing Synthesized Hydrocarbons, describes the specifications that
the various forms of SAF must meet prior to blending with Jet A, as well as requirements for the
final blend (ASTM International 2024). After meeting these requirements, the blended fuel is
then redesignated as meeting the conventional jet fuel standard ASTM D1655 and can be
transported in pipelines and used in aircraft.

Each batch of petroleum jet fuel produced at a refinery generates a batch number and undergoes
a full conformity test to generate a refinery certificate of quality (RCQ). A certificate of analysis
(COA) is generated for each batch of jet fuel as it moves through the supply chain, requiring
retesting of key fuel properties. SAF plants generate a certificate of quality, which documents
conformance with the appropriate annex of ASTM D7566. A COA is also generated at the point
where Jet A and SAF are blended and for each movement in the supply chain, as a blended fuel
may move between multiple terminals.

The method of moving fuels throughout the country depends on the location of production, fuel
type, and volume. The modes of transport for fuels include barge/tanker, pipeline, rail, and truck.
Jet A moves primarily by pipeline, whereas biofuels produced at stand-alone facilities are moved
by rail, barge, or truck (small volumes) and rarely by pipeline. SAF/Jet A blends have moved
1
SAF in this report refers to the neat fuel/100%. SAF must be blended with Jet A prior to use in aircraft.
2
Standards are continuously updated; check the ASTM website for the latest version.

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through pipelines. SAF co-processed at a petroleum refinery would be certified as ASTM D1655
and would travel by pipeline to terminal(s) and onward to airports by pipeline on truck,
depending on the airport fuel receipt infrastructure. 3

SAF produced at a stand-alone facility or biofuels facility (several plants also produce renewable
diesel) require more consideration of where and when to blend with Jet A. The requirements of
quality control point toward blending of SAF from a stand-alone facility with Jet A upstream of
an airport at a terminal. Terminals are equipped with blending equipment, software, and staff as
they are currently designed to blend on-highway transportation fuels. The terminal could be
directly connected to an airport via pipeline or thousands of miles away to address the needs of
fuel producers, suppliers, and end users. Neat SAF from two different annexes (pathways) cannot
be commingled into the same tank for blending with Jet A (ASTM 2024, Energy Institute 2022).

There are a few methods for storing and blending SAF, and the selected method may be
determined by fuel handling requirements, terminal operations, and fuel supplier and/or end user
preferences. The method in practice today stores SAF and Jet A in separate tanks, where they are
both tested for compliance with ASTM D7566 and ASTM D1655, respectively. SAF and Jet A
are delivered in the desired ratio to a third blending tank, where the fuel is tested and certified as
ASTM D1655. A second option, not in use today, would deliver SAF into a Jet A tank, where the
fuel is blended, tested, and certified to ASTM D1655. It is a recommended best practice that
SAF use dedicated infrastructure for this blending option (EI 2022). This option may be more
economical for small volumes of SAF. Both options result in business as usual at airports, where
they receive the SAF/Jet A blend by the same pipeline and trucks as they do today. It is
recommended that tank mixing equipment be deployed for either option to ensure homogenous
fuel and to account for density differences between batches of fuel.

Figure ES-1. Current method of blending Jet A and SAF at a terminal

3
There are a few domestic airports connected to refineries directly by pipeline; therefore, the coprocessed SAF/Jet
A would go from the refinery to the airport via the pipeline.

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Figure ES-2. Alternative option for blending Jet A and SAF at a terminal
Several other blending locations were evaluated. Each of these options is technically feasible, but
there are practical considerations that make them less viable than blending at terminals.

• Airports: Blending at an airport is not preferred for several reasons, including that it
would be the first instance of certifying the SAF/Jet A blend as ASTM D1655; significant
capital investment to add blending equipment, software, and additional off-spec tanks;
impacts to airport tank farm insurance; increased truck traffic to airports for SAF
delivery; and additional staff and testing/certification of the fuel.
• Refineries: In limited instances it may be possible to deliver and blend SAF and Jet A in
refinery storage. Each refinery design is unique, and their short-term storage is generally
sized for the refinery capacity. A refinery would need off-loading equipment to receive
fuel, most likely by truck and less likely by barge and rail. The blended fuel would
require recertification before moving by pipeline to terminals and airports.
• Greenfield/brownfield sites: Establishing a new blending site near an airport or
concentrated SAF production area is possible. It would be more costly than using existing
terminals, and permitting a new blending facility and any associated pipelines could take
a considerable amount of time. This option would likely only be considered for
geographic areas with significant capacity constraints for existing fuel infrastructure.

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Table of Contents
Executive Summary .................................................................................................................................... v
1 Sustainable Aviation Fuel Background and Motivation ................................................................... 1
1.1 Jet Fuel Supply, Consumption, Trade, and Enplanements ............................................................ 2
1.2 SAF Production and Consumption ................................................................................................ 5
2 Jet Fuel Quality Standards .................................................................................................................. 8
2.1 Jet Fuel ASTM Standards and Other Standards ............................................................................ 8
2.2 Certification of Quality ................................................................................................................. 9
3 SAF Logistics and Blending .............................................................................................................. 11
3.1 Jet A and SAF Logistics .............................................................................................................. 12
3.1.1 Jet Fuel Movements: Pipeline, Rail, Barge, Tanker, and Truck..................................... 13
3.1.2 Airport Infrastructure and Fuel Management ................................................................. 15
3.2 SAF and Jet A Blending .............................................................................................................. 16
3.2.1 Terminal Information ..................................................................................................... 19
3.2.2 Airline, General Aviation, and Airport Roles ................................................................ 21
3.2.3 European SAF Logistics and Blending .......................................................................... 21
4 Conclusions ........................................................................................................................................ 23
5 References .......................................................................................................................................... 24

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List of Figures
Figure ES-1. Current method of blending Jet A and SAF at a terminal ...................................................... vi
Figure ES-2. Alternative option for blending Jet A and SAF at a terminal ................................................ vii
Figure 1. International flights and offsetting requirements. .......................................................................... 1
Figure 2. U.S. jet fuel consumption and enplanements................................................................................. 3
Figure 3. U.S. jet fuel consumption by PADD. ............................................................................................ 4
Figure 4. U.S. jet fuel trade. .......................................................................................................................... 5
Figure 5. Estimated domestic SAF supply. ................................................................................................... 7
Figure 6. Estimated monthly SAF supply. .................................................................................................... 7
Figure 7. SAF and jet fuel supply chain...................................................................................................... 11
Figure 8. Petroleum jet fuel movements between PADDs (2023). ............................................................. 12
Figure 9. Major U.S. Pipelines Carrying Jet Fuel. ...................................................................................... 14
Figure 10. Current method of blending Jet A and SAF at a terminal ......................................................... 18
Figure 11. Alternative method of blending Jet A and SAF at a terminal .................................................... 18

List of Tables
Table 1. SAF Plants Supplying the U.S. Market. ......................................................................................... 6

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1 Sustainable Aviation Fuel Background and
Motivation
Airplane manufacturers increase the fuel economy by approximately 20% with each new
generation of aircraft; however, that and other increases in efficiency are not sufficient to meet
international agreements and individual industry company environmental and sustainability
goals. Sustainable aviation fuel (SAF) is a near-term option to help the aviation industry meet
requirements and goals. SAF is defined as sustainable fuel made from a feedstock other than
petroleum fuels. 4

The global aviation industry has several initiatives to reduce emissions and SAF is expected to
be a significant contributor in meeting these requirements and goals. In 2016, the International
Civil Aviation Organization (ICAO), a specialized agency of the United Nations, adopted the
Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) to cap net
CO2 aviation emissions at 2020 levels through 2035. Compliance began in 2019 for airlines
exceeding 10,000 tonnes of annual emissions, with a requirement to record fuel usage for the
purpose of calculating CO2 emissions (IATA 2024a). Offsetting requirements, met through a
variety of activities, began in 2021 for flights between voluntary countries, and full
implementation will occur in 2027. 5 The International Air Transport Association (IATA), a trade
association representing 330 airlines, adopted the Fly Net Zero initiative in 2021 to achieve net-
zero carbon by 2050 (IATA 2024c).

Figure 1. International flights and offsetting requirements.


Source: ICAO 2023. Note: International flights between participating (green) countries began in 2021 and expand to
flights to and from blue countries in 2027. International flights to and from yellow countries are exempt.

4
SAF is sometimes referred to as “biojet,” and the U.S. Environmental Protection Agency (EPA) uses the term
“renewable jet fuel.”
5
Many countries volunteered to start implementation early ahead of the 2027 requirement. Lower economic status
countries and those with limited air traffic are exempt though many opted to participate (ICAO 2023).

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The European Union and several countries have SAF mandates:

• European Union: ReFuel EU, the European Union SAF mandate, was passed in October
2023. The requirement escalates over time beginning with 2% in 2025, 6% by 2035, and
70% by 2050 (U.S. International Trade Administration 2024). The regulation allows the
European aviation industry to use book-and-claim—a practice of decoupling the fuel
credit from where it is used—until 2035, after which SAF must be physically supplied at
European Union airports. There are financial penalties for fuel suppliers not meeting the
requirement. Sweden and France previously established SAF mandates of 1% in 2021
and 2022, respectively.
• United Kingdom: The SAF mandate requires 2% by 2025, 10% by 2030, and 22% in
2040 (UK Parliament 2024). The mandate caps the common hydroprocessed esters and
fatty acids (HEFA) production pathway and requires power-to-liquid fuels. There is a
buyout price for fuel suppliers unable to secure supply.
• Norway: A SAF mandate of 0.5% has been in place since 2020 (Air BP 2019).
• Singapore: A SAF mandate of 1% begins in 2026, with plans to increase it over time
(S&P Global 2024).
The Sustainable Aviation Fuel Grand Challenge is a joint effort from the U.S. Department of
Energy, U.S. Department of Transportation, U.S. Department of Agriculture, and other
government agencies working to expand domestic SAF production, reduce costs, and enhance
sustainability. 6 The production target of neat SAF is 3 billion gallons by 2030 and 35 billion
gallons by 2050. Developing the entire supply chain inclusive of logistics and blending is an
activity under this program. While there is not a SAF mandate, there are regulatory motivations
and financial incentives to enable the market. SAF qualifies for both the federal Renewable Fuel
Standard and various state low-carbon fuel standards, and the compliance and credit mechanisms
of those programs help reduce the impacts of higher production costs. The Inflation Reduction
Act of 2022 enacted Section 40B, providing a SAF-specific tax credit for both domestic
production and imports of up to $1.75/gallon between Dec. 31, 2022, and Jan. 1, 2025
(Alternative Fuels Data Center 2024b). In 2025, the Inflation Reduction Act’s 45Z Clean Fuel
Production Credit replaces 40B, which provides up to $1.75/gallon for SAF meeting the various
requirements (Alternative Fuels Data Center 2024a). Unlike 40B, the 45Z tax credit is not
available to imported SAF. There is also the Federal Aviation Administration’s (FAA’s) Fueling
Aviation’s Sustainable Transition (FAST) Grant Program, with $244.5 million to support SAF
production, transportation, storage, and blending (FAA 2024b).

1.1 Jet Fuel Supply, Consumption, Trade, and Enplanements


U.S. jet fuel consumption exceeded 25.3 billion gallons in 2023, surpassing each of the past 3
years but not reaching levels prior to the COVID-19 pandemic (EIA 2024g). Figure 2
demonstrates that domestic jet fuel production closely aligns with consumption (EIA 2024c,
2024h). In 2023, the United States accounted for nearly 28% of the 92-billion-gallon global jet
fuel consumption (IATA 2024b, EIA 2024g). Figure 3 shows consumption by Petroleum

6
https://www.energy.gov/eere/bioenergy/sustainable-aviation-fuel-grand-challenge.

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Administration for Defense District (PADD), with PADD 1 (East Coast) and PADD 5 (West
Coast) accounting for 68% of consumption in 2023 (EIA 2024g). 7

The United States is generally a net exporter of jet fuel (EIA 2024a, EIA 2024h). About 74% of
2023 exports were to other North American countries, while 50% or more of imports came from
South Korea the past 5 years (EIA 2024a, 2024h). About 66% of imports arrive to PADD 5
(West Coast), and the remaining 34% to PADD 1 (East Coast), while 83% of exports are from
PADD 3 (Gulf Coast) (EIA 2024d, 2024e).

The FAA reports that enplanements (the number of passengers boarding an aircraft) have grown
from 760 million in 2014 to 939 million in 2023 (FAA 2024c). 8 Between 2022 and 2023,
enplanements and jet fuel consumption grew by 11% and 5.6%, respectively. The FAA projects
enplanement will grow 2.6% per year between 2024 and 2044 (FAA 2024a).

Figure 2. U.S. jet fuel consumption and enplanements.


Sources: EIA 2024c, 2024g; FAA 2024c

7
PADD 1: CT, DC, DE, FL, GA, MA, MD, ME, NC, NH, NJ, NY, PA, RI, SC, VA, VT, and WV. PADD 2: IA, IL,
IN, KS, KY, MI, MN, MO, NE, ND, OH, OK, SD, TN, and WI. PADD 3: AL, AR, LA, MS, NM, and TX. PADD
4: CO, ID, MT, UT, and WY. PADD 5: AK, AZ, CA, HI, NV, OR, and WA.
8
Enplanements included in this section are for primary airports, defined as commercial airports with 10,000 or more
passengers boarding each year.

3
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Figure 3. U.S. jet fuel consumption by PADD.
Source: EIA 2024g

4
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Figure 4. U.S. jet fuel trade.
Source: EIA 2024a, 2024h

1.2 SAF Production and Consumption


SAF production is in an early commercial development phase. There are three domestic plants
and an international producer supplying the U.S. market (Table 1). Three plants use the HEFA
pathway, and one uses the alcohol-to-jet (ATJ) pathway. All four of these plants also produce
renewable diesel and other renewable fuels and products. World Energy was the first domestic
conversion of a petroleum refinery to a renewables plant and began producing SAF in 2016.
They initially supplied United Airlines at Los Angeles International Airport, later expanding to
supply KLM, other airlines, business customers, and airports. Neste began supplying to San
Francisco International Airport and to Alaska Airlines, American Airlines, and JetBlue Airways,
and later expanded to serve additional airlines, customers, and airports (Neste 2020). Neste
exports fuel from their Singapore facility and has also upgraded a biointermediate into SAF at a
Houston refinery (Neste 2022). Montana Renewables, a petroleum refinery conversion to a
renewable fuels plant, began SAF production in the second quarter of 2023 (Voegele 2023).
LanzaJet started up SAF production in 2024 and is the first commercial-scale ATJ plant
(LanzaJet 2024). Phillips 66 converted their Rodeo, California, petroleum refinery to produce
renewable fuels, and current capacity is 800 million gallons. They announced plans to produce

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SAF in 2024 (Phillips 66 2024). There are numerous pilot facilities and other commercial
facilities under development worldwide. 9

Table 1. SAF Plants Supplying the U.S. Market.


Sources: LanzaJet 2024; EIA 2024h; Neste 2023

a Total renewable fuel capacity is shown; plants produce renewable diesel, SAF, and other biofuels/chemicals.

SAF domestic production and consumption volumes are not published. The best approximation
is derived from the Renewable Fuel Standard’s compliance mechanism, renewable identification
numbers. SAF supply has increased each year since its introduction in 2016 (Figure 5; EPA
2023). The first 7 months of 2024 are higher than 2023, with increased imports, and it is
anticipated to grow at a faster pace with the startup of both the LanzaJet and Phillips 66 plants.
(EPA 2023). Figure 6 shows the high variability of monthly SAF renewable identification
number generation, which may represent market dynamics of plants producing both SAF and
renewable diesel and potentially competition for foreign SAF or imported biointermediates
processed into SAF in the United States (Neste 2022). The demand for SAF exceeds supply, with
a significant number of offtake agreements for both airlines and business/private aviation. Many
businesses see the use of SAF as essential to meeting their corporate goals. While increased SAF
supply is a positive sign, it represented approximately 0.1% of domestic jet fuel consumption.
Worldwide SAF production was about 165 million gallons in 2023, with U.S. consumption
accounting for about 16% (IATA 2023; EPA 2023).

9
The International Energy Agency’s Bioenergy Technology Collaboration Programme maintains a global database
of biomass conversion plants: www.ieabioenergy.com/installations/.

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Figure 5. Estimated domestic SAF supply.
Source: EPA 2023; * 2024 data are January through July

Figure 6. Estimated monthly SAF supply.


Source: EPA 2023

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2 Jet Fuel Quality Standards
Jet fuel quality is carefully controlled through multiple harmonious standards adopted throughout
the world. The approval for SAF and technology pathways is rigorous to ensure the quality and
safety of the fuel. The FAA funded a report that provides detailed information on jet fuel quality
and associated test methods, and quality control throughout the supply chain (Miller et al. 2014).

Several entities, including the Energy Institute, the Joint Inspection Group, the American
Petroleum Institute, and SAE International, develop best practices to safeguard fuel quality
through the supply chain. The Energy Institute developed EI 1533, Quality assurance
requirements for semi-synthetic jet fuel and synthetic blending components (SBC), to define
quality control of SAF from the point of production to blending with Jet A, as well as required
and recommended practices throughout the entire supply chain (Energy Institute 2022). 10

ICAO, in collaboration with IATA, Airports Council International, and Airlines for America,
summarizes best practices in the Manual on Civil Aviation Jet Fuel Supply (ICAO 2012). This
document covers the entire supply chain including production, distribution, airport
storage/hydrant systems, and delivery to aircraft. It describes roles and responsibilities, required
documentation, lab sampling test methods, and requirements.

2.1 Jet Fuel ASTM Standards and Other Standards


As described by Rumizen (2021), the FAA establishes “airworthiness standards” for the design
and operation of aircraft. The fuel is considered an operating limitation for aircraft and engines,
rather than a physical part of the product. This means that the aviation fuels permitted for use are
identified by the engine and aircraft manufacturer, typically using an industry standard such as
from ASTM. ASTM International is a voluntary consensus standards organization composed of
aviation industry experts including airplane and engine manufacturers; fuel system equipment
manufacturers; fuel producers, suppliers, and users; and other interested parties. Industry experts
meet regularly to create, maintain, and continuously update fuel quality specifications and test
methods.

Jet fuel must meet ASTM D1655, Standard Specification for Aviation Turbine Fuels (ASTM
International 2022). 11 Aircraft and engine manufactures around the globe very commonly use
ASTM D1655 to define the fuels that can be used in their products. Jet A is the fuel type used in
the United States, and Jet A-1 in the rest of the world. The fuels are nearly identical, with the
primary difference in the freezing point: Jet A at a maximum of −40°C and Jet A-1 at a
maximum of −47°C.

ASTM D4054, Standard Practice for Evaluation of New Aviation Turbine Fuels and Fuel
Additives describes the process and guidelines for obtaining approval of a new fuel by the engine
and aircraft manufacturers. Currently, approval for blending up to 50 vol% is allowed. Once
approved, the new fuel (or fuel blending component) is added to ASTM D7566 Standard
Specification for Aviation Turbine Fuel Containing Synthesized Hydrocarbons.

10
This is a supplement to EI/JIG Standard 1530: Quality assurance requirements for the manufacture, storage, and
distribution of aviation fuel to airports (A4), publishing.energyinst.org/featured/1530.
11
Standards are continuously updated; check the ASTM website for the latest version.

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In 2009, ASTM D7566 was amended to allow Fischer–Tropsch (FT) fuels, which can be made
from biomass (ASTM International 2024). Synthesized hydrocarbons, synthetic fuels, or
synthetic blending components are all terms used to describe jet fuels or jet fuel blending
components that are not made from petroleum. All forms of SAF that have been approved to date
are synthetic blending components. ASTM D7566 contains all the requirements of ASTM
D1655, plus additional requirements that must be met by so-called semi-synthetic fuels that are
made by blending Jet A with a synthetic blending component listed in ASTM D7566. ASTM
D7566 fuel, when blended with Jet A in percentages outlined in D7566, also meets D1655
requirements and can be considered a D1655-complaint aviation fuel. Once a is D1655-
compliant, it can be used in in the fungible fuel distribution system. Approved SAF production
technology pathways are available in the D7566 specification annex, as are the specific testing
requirements for that pathway. ASTM imposes blending limits for each pathway, based on the
fuel molecule families produced by the pathway. At the time of this writing, the current version
of D7566 (D7566-24a) approves eight pathways (also referred to as annexes):

• FT fuels with synthetic paraffinic kerosene (FT-SPK), 50% maximum blend.


Coprocessing with petroleum feedstock is allowed at a 5% limit.
• HEFA fuels (HEFA-SPK), 50% maximum blend. Coprocessing with petroleum feedstock
is allowed at a 5% limit.
• FT fuels with synthetic kerosene with aromatics (FT-SKA), 50% maximum blend.
• Synthetic isoparaffin from fermented hydroprocessed sugar, formerly known as direct-
sugar-to-hydrocarbon fuels (SIP-SPK), 10% maximum blend.
• ATJ fuels (ATJ-SPK) produced from isobutanol and ethanol, 50% maximum blend.
• Catalytic hydrothermolysis jet (CHJ) produced from esters and fatty acids at a 50%
maximum blend concentration.
• Hydrocarbon HEFA (HC-HEFA) produced from esters and fatty acids at a 10%
maximum blend concentration.
• ATJ-SPK with aromatics (ATJ-SKA) from C2–C5 alcohols, 50% limit.
It is important to note that the blend percentages given are the maximum allowable, but D7566
fuel property requirements may limit blending to a lower level for a specific batch of synthetic
blending component. Multiple additional pathways are currently under review by ASTM. There
is future potential for a 100% SAF fuel, but there are no anticipated impacts on infrastructure, as
it will contain a minimum of 8% aromatics, which is within the range of Jet A aromatic content.

The U.K. Ministry of Defense maintains another commonly used jet fuel quality standard outside
of the United States, Defense Standard 91-091 (Def Stan 91-091), Turbine Fuel, Kerosene Type,
Jet A-1. The standard is nearly identical to ASTM D1655, with minimal differences for test
limits for acidity level and naphthalene content. Def Stan 91-091 includes a fuel traceability
requirement for semi-synthetic jet fuel such as SAF.

2.2 Certification of Quality


Jet fuel and SAF travel by multiple modes of transportation including pipeline (neat SAF
blendstock not currently shipped by pipeline), truck, barge, and rail (uncommon for Jet A). If the
tested fuel falls outside any ASTM limits at the refinery, SAF plant, or along the supply chain,
the batch must be segregated from other fuel and retested to determine if the fuel can be used.
Refinery certificates of quality (RCQs), certificates of quality, certificates of analysis (COAs),

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and recertification test certificates are used for quality control in contracts between buyers and
sellers.

• An RCQ is generated at a refinery for each batch of petroleum jet fuel produced. The
document includes batch number, quantity of the batch, refinery name, date,
documentation that the tested fuel meets ASTM D1655 (Jet A), and type and volumes of
additives. 12
• A certificate of quality is generated at a SAF facility and includes the same information
as an RCQ but tests to the appropriate annex of ASTM D7566.
• A COA is generated by a certified and accredited third-party laboratory downstream from
production at each transition point. COA documentation includes documentation that the
tested fuel meets ASTM D1655 or D7655, and related annex tables.
o A COA typically includes results from Airlines for America’s ATA Specification
103, Standard for Jet Fuel Quality Control at Airports. 13
o A COA is generated when SAF and Jet A are blended, certifying it as ASTM
D1655.
• A recertification test certificate is generated in instances where there is risk of fuel
contamination, such as after the jet fuel travels through a multiproduct pipeline or ocean
vessel or in other instances where this is a risk of contamination. Its documentation is like
an RCQ, though not as many fuel parameters are tested. The testing makes sure
specification limits are met and that there are no significant changes noted for each
property in the test certificate.
SAF is blended with Jet A at the percentage determined by the end user or up to the allowable
maximum percentage based on the technology pathway. A COA is generated based on testing
that demonstrates the fuel is compliant with ASTM D7566 Annex 1 Tables 1 and 2. Once
confirmed, the fuel is designated as ASTM D1655.

Best practices and standards differ in how to determine batch number and necessary fuel testing
when fuels are blended. The American Petroleum Institute’s Recommended Practice 1543,
Documentation, Monitoring and Laboratory Testing of Aviation Fuel During Shipment from
Refinery to Airport, states that if two batches of jet fuel are commingled at a storage facility, the
batch identity is lost. The pipeline industry has addressed this by generating batch numbers for
volumetric accounting, but this does not carry over the COA from the original batches that were
commingled, and the fuel is tested against ATA 103, which does not require full conformity
testing after commingling of batches (Miller et al. 2014).

12
RCQ and COA are similar documents. The RCQ may include additional information such as type and quantity of
additives, and potentially the percentage of non-hydroprocessed, mildly hydroprocessed, or severely hydroprocessed
components. The refiner typically generates the RCQ but is allowed to use an independent laboratory to generate an
RCQ; the refiner is ultimately responsible for the laboratory results.
13
Airlines for America, formerly Air Transport Association, provides airlines with the ATA 103 standard, which
requires the following eight tests: visual appearance in a white bucket, gravity, distillation (10%, 50%, 90%, final
boiling point, residue, and loss), flash point, freezing point, water separation, copper corrosion, and existent gum. If
an airline incorporates ATA 103 into their maintenance/operating manuals, the airline must adhere to it under FAA
regulations.

10
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
3 SAF Logistics and Blending
Multiple modes of transit are used to move imported and domestically produced Jet A and SAF
(Figure 7). The modes or transport depend on where the fuel was produced or imported,
volumes, and infrastructure availability. It is more common for Jet A and SAF to arrive at
terminals where they are blended, certified to ASTM D1655, and delivered to an airport by
pipeline or truck for airports without pipelines. In limited instances, refineries are directly
connected to an airport by pipeline. There is future potential to produce SAF containing fuel by
coprocessing bio-derived components alongside petroleum feedstock at existing refineries and
limited future potential to deliver third-party-produced SAF to refinery storage for blending and
certification. Industry discussions have considered connecting SAF production facilities by
pipeline to terminals. Jet fuel quality is tested at every point it moves through the supply chain.
Figure 8 shows movements of petroleum jet fuel between PADDs by both pipeline and
tanker/barge.

Figure 7. SAF and jet fuel supply chain

11
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Figure 8. Petroleum jet fuel movements between PADDs (2023). 14
Source: EIA 2024c

3.1 Jet A and SAF Logistics


Jet A is moved primarily by pipeline, whereas biofuels produced at stand-alone facilities are
moved by rail or barge/tanker (large volumes) or truck (small volumes). Dedicated railcars and
trucks are strongly encouraged (Energy Institute 2022). Pipelines are multiproduct, and tanker
and barge vessels generally carry different fuels over time. In the future, if SAF containing fuel
is produced by coprocessing bio-derived components with conventional refinery streams to
produce Jet A at an existing refinery, an RCQ would be generated at the refinery, and the fuel
would flow through the supply chain in a business-as-usual model via pipeline directly to an
airport or, more commonly, by pipeline to a terminal and then by pipeline to an airport.

SAF produced at a domestic stand-alone facility currently travels by rail or truck to a fuel
terminal for blending with Jet A. As volumes grow, there is the expectation that SAF will move
by barge/tanker. There is the potential in the future to connect SAF production facilities to
terminals by pipeline. SAF imported from other countries would be delivered by tanker (a ship
designed for bulk petroleum transport) to a terminal. SAF movements from existing domestic
plants vary based on available infrastructure. Existing plants are using several shipping methods,
and these are shared as examples on how available infrastructure and location impact fuel
movements. The Montana Renewables plant ships SAF by rail to a Southern California terminal,
where it is blended and delivered to airports. LanzaJet’s SAF will be delivered by truck to
terminal(s) in the Savanah, Georgia, area; their facility does not have rail. World Energy moves

14
The arrows represent the movements from one PADD to another PADD; not between specific states.

12
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
SAF/Jet A blends by truck to airports. Neste’s imported fuel is delivered by tanker to California
water-based terminals or a nearly finished product is sent to a Houston area refinery where it is
upgraded to SAF and sent by rail to California (Schwanz 2023, Neste 2022). There are different
considerations for various transit methods.

There are constraints in the Jet A supply chain in some geographical areas, where demand for
pipeline shipments outstrips available space and growth in the number of flights at airports
results in fuel demand higher than an airport’s pipeline can accommodate. Airports without
pipelines have experienced issues with the availability of qualified truck drivers to deliver Jet A.
These same constraints could impact SAF movements.

3.1.1 Jet Fuel Movements: Pipeline, Rail, Barge, Tanker, and Truck
Pipelines are the preferred method for moving any fuel due to lower costs and less impacts from
weather events. Major multiproduct refined petroleum product pipelines transporting jet fuel are
shown in Figure 9. 15 Domestically produced and imported jet fuel is commonly moved
throughout the country by pipeline, passing through one or more terminals before delivery to an
airport by pipeline or by truck. Pipelines batch fuels based on fuel properties, and if dissimilar
fuels come into contact, a transmix or interface is delivered to a separate tank for reprocessing.
Fuel is batched through pipelines, and customers receive the specified volume of fuel; however,
they are not receiving fuel from a particular terminal or refinery. For example, an energy
company may ship their jet fuel on a pipeline to a terminal thousands of miles away and receive
the volume of fuel ordered, but it is not necessarily the fuel from their refinery. Fuels from
different producers all meet the same ASTM standards and once on the pipeline system are
considered fungible (or interchangeable). While possible, it is uncommon to use unique batch
identifiers to move specific fuels to a customer; this results in higher costs and administrative
burden. Jet fuel competes with other refined petroleum products for pipeline capacity to move
fuel long distances and in some markets, there are pipeline constraints where demand outstrips
available capacity. Further, there are airports where the pipeline into the airport operates at
capacity and demand is met by truck deliveries and tankering—a practice of loading more fuel
than necessary at the airport of origin.

SAF/Jet A blends have been delivered by pipeline after being recertified as meeting ASTM
D1655. A demonstration was done with imported SAF blended at a Houston-area terminal and
moved via two pipeline systems to LaGuardia International Airport (Delta 2022). This shipment
was done using a unique batch identifier for the pipeline shipment. The Federal Energy
Regulatory Commission regulates fuels carried by pipeline, and their requirement for new fuels
is to publish rules in a pipeline’s tariff or shipper manual, where the pipeline company must
specify fuel requirements. Several pipeline companies have notified the Federal Energy
Regulatory Commission and provided information in their tariff or shipper manual for SAF/Jet A
blends meeting ASTM D1655. At this time, neat SAF blendstock is not being transported by
pipeline, but updates to pipeline company manuals with specific fuel quality requirements could
enable those shipments.

15
This graphic does not show smaller regional pipelines that carry jet fuel nor pipelines from terminals to airports.

13
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Figure 9. Major U.S. Pipelines Carrying Jet Fuel.
Source: Airlines for America 2021; used with permission

Rail is a common mode to move biofuels from production locations to population centers.
Railcars dedicated to SAF movements are strongly encouraged (Energy Institute 2022). Not all
terminals have rail facilities, and in those instances the biofuels are received at a transmodal
facility and delivered to nearby terminals by truck. Railcars are typically leased by fuel
producers and distributors and hold about 30,000 gallons each. Costs for shipping by rail vary
based on distance, competition, and whether it is a single car rate for trains with multiple
commodities or unit car rates for trains with about 100 railcars of the same commodity. As an
example, 2021 rail rates to move ethanol from multiple Midwest cities to Houston and Fort
Worth, Texas, averaged $0.29/gallon and $0.23/gallon for single car and unit car, respectively
(U.S. Department of Agriculture 2021).

Barges are used to move fuels along rivers and inland waterways and along the costal United
States. Moving fuels by barge generally costs more than pipeline but less than rail or truck. The
Jones Act, a federal code, requires that all goods transported in U.S. waters be carried on U.S.
vessels. Tug or tow boats move multiple barges (fat-bottomed vessels) via inland waterways.
Capacity varies widely, with an inland tank barge ranging from 400,000 to 1.2 million gallons

14
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
and an oceangoing tank barge between 7 and 14 million gallons (National Oceanic and
Atmospheric Administration 2016).

Tankers, a type of ship designed for bulk transport of oil and petroleum products, are used to
move large volumes of fuel. Tankers are used for both international trade and to move fuel
between domestic PADD regions. Capacity varies based on vessel size and distance it is
designed to travel for refined petroleum products, with a range of 22–227 million gallons (EIA
2014). 16 If non-dedicated tanks are used to transport SAF or Jet A, individual tank history must
be recorded for last three products contained prior to loading and reviewed for any risks prior to
storing SAF or a SAF blend (Energy Institute 2022). Costs to move jet fuel by tanker will be
determined by distance, volume, and petroleum market dynamics. Rates show a high degree of
variability over time, from less than $10/barrel to more than $55/barrel between 2018 and 2022
(EIA 2022).

Trucks are used to move Jet A from terminals and refineries to airport tank farms where a
pipeline is unavailable. Trucks also move fuel from airport tank farms to aircraft if the airport
does not have a fuel hydrant system. Jet A trucks in the United States are dedicated and do not
transport other fuels to reduce any risk of contamination. Jet A truck capacities range from 3,000
to 10,000 gallons (Seidenman 2023). It is expected that the same trucks that transport Jet A today
will be used to transport SAF and SAF/Jet A blends. Ideally, trucks are used to move fuels short
distances.

3.1.2 Airport Infrastructure and Fuel Management


All commercial airports have on-site fuel storage—an area called the tank farm. A tank farm
comprises multiple interconnected pieces of equipment designed to safely receive, store, and
dispense fuel to a hydrant system or truck delivery to aircraft. Although not an all-inclusive list, a
tank farm consists of tanks; pipeline interconnection; equipment to control the flow of fuel and
vapors; meters to measure the volume of fuels into the tank farm and out to aircraft; filters to
remove contaminants; pumps to move fuel throughout the system; safety equipment to prevent,
detect, and contain leaks throughout the system; off-loading racks to fill fuel trucks; and hydrant
systems—underground pipes and hydrants. Generally, airports own the tank farm and lease it to
an airline fuel consortium or fixed based operator who manage it. Smaller airports may operate
under a different scheme in which the airport either operates the fuel system or hires a third party
to do so. Fuel is delivered to airplanes via a fuel hydrant system (underground pipes to each gate)
or by fuel truck. All airlines agree to allow the use of ASTM D1655 compliant jet fuel containing
SAF at an airport, as specific SAF blends would not be delivered to a particular flight or airline.
However, airlines and other aviation customers buying SAF would receive any benefits
associated with purchasing the fuel.

Airport tank farms size their fuel infrastructure to accommodate their peak week of the year and
allow for future growth. However, the growth in enplanements and jet fuel use has constrained
fuel infrastructure at some airports, and in some instances demand exceeds pipeline capacity.
This is compensated for by truck deliveries or fuel tankering—where an aircraft flies with more
fuel than required for its flight. Truck deliveries supplement pipeline deliveries but are not as

16
Based on deadweight in metric tons converted to million gallons based on a jet fuel density assumption of 6.7
pounds/gallon.

15
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
efficient, as deliveries are handled by the airside service contractor along with security
procedures for both the fuel truck driver and entry into the secure area of the tank farm.

The purpose of airline fuel consortiums, common at U.S. airports, is to pool resources and ensure
quality and timely delivery of jet fuel to all airlines through shared infrastructure. The airline
consortium model allows airlines to source fuel from multiple fuel producers. Airline fuel
consortiums do not buy or sell fuel but act as the operator of the fuel infrastructure. Airlines are
responsible for purchasing fuel and ensuring quality. The consortium may directly operate the
infrastructure system or contract out operations to a third party.

3.2 SAF and Jet A Blending


SAF from a stand-alone facility must be blended with Jet A prior to use in an aircraft. Several
possible locations for blending include existing terminals, airports, petroleum refineries, and
new/dedicated blending sites. While all the locations evaluated are technically capable of
blending fuel, there are practical considerations that make some locations less optimal. It is
preferable to certify the SAF/Jet A blend as ASTM D1655 and mitigate any potential fuel quality
issues upstream of an airport. All locations with require capital investment to add infrastructure.

• Terminals: Terminals are the optimal location for blending because they have existing
tanks, associated equipment, blending software, trained staff, insurance, and permits that
cover these activities. Nearly all terminals lease tanks and associated equipment to third
parties for storage and blending activities. Terminals have long provided blending as a
service for their on-highway transportation fuel customers. SAF storage and blending
could occur in existing tanks if available but may require new tanks in infrastructure
constrained areas.
• Airports: Blending at airports is not recommended. This would be the first instance of
certifying the SAF blend as ASTM D1655. An airport’s tank farm would require
significant capital investment to add tanks for SAF storage, blending, additional off-spec
tanks, associated equipment, software, and additional staff. There would be an increase in
truck traffic delivering SAF, which would impact larger airports accustomed to receiving
fuel by pipeline. Additional laboratory testing and paperwork are necessary for blended
fuel. Different insurance would be necessary to cover blending activities. EI 1533 states
that blending should only occur upstream of airports (EIA 2022). Def Stan 91-091 (fuel
quality standard used outside of the United States) prohibits blending at airport depots
(Energy Institute 2022). 17
• Refineries: Each refinery has a unique design. Refinery fuel storage is generally sized for
its capacity, with limited or no excess storage. A limited number of refineries could
receive third-party fuel into their fuel storage area, and off-loading equipment would be
needed. The refinery could receive the third-party SAF, blend with their Jet A, recertify,
and transport fuel in a business-as-usual scenario by pipeline and truck to airports.
• Greenfield/brownfield sites: It is feasible to establish a new site or repurpose an
industrial site to store and blend SAF. This would be a capital-intensive effort. Permitting
both the facility and any associated pipelines would take years. This option would likely

17
There is an exception for small volumes for development projects.

16
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
only be considered in geographic areas with severe capacity constraints for existing
infrastructure (terminals, pipelines, and rail).
Blending at terminals upstream of airports results in business as usual at airports; using the same
pipeline, trucks, tank farms, and hydraulic systems are used to deliver the SAF/Jet A blend to
aircraft. Blending can take place at a terminal directly connected to an airport by pipeline or
thousands of miles away and delivered by pipeline to terminals serving the airport(s) of interest.
The source of SAF, purchaser, end user, logistics, infrastructure availability, and cost are all
factors that could impact preferred terminal locations for blending. As an example, imported
SAF from Neste was blended in Texas and delivered to New Jersey via the Colonial Pipeline and
onward on the Buckeye Pipeline to LaGuardia International Airport to Delta Air Lines as a
demonstration (Delta 2022). The investment in infrastructure would occur at terminals, not
airports.

How to blend the fuel is another consideration with cost and infrastructure availability
implications. Leasing more tanks increases costs; however, Option 1 (described below) is the
current and preferred method of blending SAF and Jet A at terminals. Inline (or ratio) blending—
in which both fuels are delivered to a tank at the same time—is preferred to sequential (or
splash) blending, in which fuels are delivered to a tank one at a time. A best practice is to add
mixing equipment to tanks to ensure a homogenous blend (Energy Institute 2022).

• Option 1: Off-load SAF to a terminal and store it in a dedicated SAF tank. Store Jet A in
separate tanks. Both SAF and Jet A batches are tested to ensure compliance with ASTM
D7566 and ASTM D1655, respectively. SAF and Jet A are blended at the desired ratio
into a third tank. Sampling from the third tank would follow the steps outlined in Section
2.2: Certification of Quality to generate a COA demonstrating that the blended fuel meets
ASTM D7655. If it does, the blended fuel is designated as ASTM D1655 and is ready for
shipment via pipeline or truck to airports. 18
• Option 2: This option is not in use and entails off-loading SAF into a Jet A storage tank
at a terminal (Figure 11). Sampling from the tank would follow the steps outlined in
Section 2.2: Certification of Quality to generate a COA demonstrating that the blended
fuel meets ASTM D7655. If it does, the blended fuel is designated as ASTM D1655 and
is ready for shipment via pipeline or truck to airports. For this option, it is a
recommended best practice to deliver SAF via dedicated infrastructure (EI 2022).

18
Blending that takes place at a terminal upstream of those connected to terminals would ship to downstream
terminals in a business-as-usual scenario, where it is tested to ensure compliance with ASTM D1655 and a COA is
generated.

17
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Figure 10. Current method of blending Jet A and SAF at a terminal

Figure 11. Alternative method of blending Jet A and SAF at a terminal

Neat SAF from two different annexes (pathways) cannot be commingled into a tank for blending
with Jet A (ASTM 2024, Energy Institute 2022). As an example, fuel produced from the HEFA
and ATJ pathways cannot be commingled in the same tank. SAF from two different annexes that
have been segregated and blended with Jet A and certified as ASTM D1655 can be blended. It is
important when blending such fuels that they do not exceed the allowable percent per ASTM
limits. SAF produced by the same annex can be commingled in the same SAF tank and blended
simultaneously with Jet A. For example, HEFA from two different producers can be commingled
in a tank.

Existing SAF plants typically move their fuel to terminals for blending. Montana Renewables
and Neste deliver neat SAF to California terminals for blending. LanzaJet is moving their neat
SAF to Savanah, Georgia terminals for blending. World Energy was the first domestic petroleum
refinery conversion and SAF plant and is located in close proximity to Los Angeles. Due to these
factors, they bring in Jet A, blend and certify on-site, and the blended fuel is delivered by truck
to area airports.

18
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Reported blend ratios have been about 30% SAF and 70% Jet A (Schwanz 2023, Signature
Aviation 2024). A terminal blending SAF in Crockett, California, takes additional steps to ensure
fuel quality. This terminal has a third-party testing company check incoming trucks to ensure
they do not contain any jet fuel. The inspection process also includes a check of the SAF
filtration system, SAF content, and water and ensures compliance with all regulations. After the
truck is loaded with the SAF blend and a 10-minute settling period, fuel is tested from each truck
compartment to ensure compliance with ASTM D1655 (Schwanz 2023). After demonstrating
compliance, the truck leaves the terminal to deliver the fuel to airport(s).

3.2.1 Terminal Information


Terminals receive, store, blend, and off-load fuels for their customers. There are approximately
1,200 terminals storing refined petroleum products in the United States, though not all of them
store jet fuel (EIA 2024f). Terminals receive a fee for leasing tanks and associated equipment,
storing and blending fuels for their customers. Lease terms vary but are generally at least 1 year
(and longer if capital improvements are necessary to accommodate a fuel and blending).
Terminals have several ownership types, including refinery owners (33%), midstream companies
with pipelines (36%), and midstream companies that may own one or more terminals (31%). 19

Oil and refinery companies own the fuel, though they also lease tanks and associated equipment
to third parties.

• Oil/refinery: Vertically integrated companies that explore and drill for oil and refine it
and companies that purchase crude and refine it. These companies may also own
pipelines. While these are purpose-built to store their fuels, they also lease space for
third-party fuel storage. The refinery companies with the most terminals (not necessarily
capacity) include MPLX (Marathon Petroleum Corporation), Philips66, and Shell
(inclusive of their investment in Equilon Enterprises and Motiva) (EIA 2024f).
• Pipeline: Midstream companies that own pipelines and lease storage space to customers
at their terminals. Buckeye Partners, Sunoco, Kinder Morgan, and Magellan account for
more than 70% of terminals in this category (EIA 2024f).
• Terminal: Midstream companies that own one or more terminals but do not own
pipelines or refineries. There is limited consolidation of ownership in this category.
The availability of tanks for lease changes over time as leases expire. Both the timeline and cost
to add SAF storage and blending activities at a terminal will vary. The lowest-cost and shortest-
timeline scenario is using existing tanks at terminals that currently store jet fuel. Terminals that
do not currently store jet fuel are also an option, and an inquiry should be made to determine if
available tanks could be converted for SAF and blending activities. Adding SAF to a terminal
not currently storing Jet A would have a longer lead time, and there would be a capital
investment to add dedicated associated equipment such as pipes, pumps, and off-loading
equipment. Another consideration is how SAF would be delivered to a terminal. If the SAF
would be primarily delivered by rail, terminals with rail infrastructure and secondarily terminals
near rail transmodal facilities will need to be identified.

19
This is a subset of data from EIA (2024g). The percent represent the number of terminals, not capacity. Terminals
that solely store crude oil, marine fuels, heating oil, and asphalt were removed.

19
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
In areas with geographical constraints, it is recommended to evaluate terminals upstream by
pipeline to find available tank and blending infrastructure. For situations where it is essential to
blend in a desired geographic area where tank infrastructure is constrained, there is the potential
to build new tanks. If terminals have space, they are generally open to adding new infrastructure
to support a customer, and the lease fees could accommodate the capital expenditure of the
terminal owner (or, less commonly, the fuel owner leasing the space pays the capital expense
upfront). EI 1533 has a section on SAF and SAF/Jet A blend design and handling equipment
(Energy Institute 2022).

While terminals can change fuels stored after a thorough cleaning, not all tanks would be
available to store jet fuel due to their configurations. For example, some diesel tanks have
external floating roofs that would not be used. Ideally, a customer storing SAF could lease two
existing tanks—one for neat SAF and one for blending with Jet A, with the assumption that Jet A
is already available and stored at the terminal. There would be costs for associated dedicated
equipment such as dedicated pipes, pumps, and other equipment.

Both the timeline and cost to add SAF storage and blending activities at a terminal will vary. The
quickest and lowest-cost option is expected to be at a terminal that currently stores jet fuel and
has available tanks for lease. It is anticipated that more time would be needed to add these
activities to a terminal that does not currently store jet fuel but has tanks available for lease. The
longest lead time and highest costs will occur where new tanks and associated equipment need to
be built to accommodate SAF and blending.

The implications, permits, and processes to add a new tank will vary widely based on location
and are reliant on local and state authorities. Existing terminals will be aware of the steps they
need to take to add new equipment and activities at their location. Air quality in an area
determines thresholds for permitting. Adding a new source of emissions from a tank could lead
to a New Source Review, a Clean Air Act program (EPA 2024b). The addition of SAF and
blending activities and any impacts on emissions, as well as location, will inform permit needs.
Changing fuels stored in existing tanks is less likely to trigger public notice requirements than
new tanks, but again depends on local jurisdictions having authority.

There are federal environmental laws that regulate activities and infrastructure at terminals. The
following is a summary of significant federal regulations that apply to terminals. This is not
intended to be a complete list. In many instances, states, territories, Tribal nations, and
municipalities manage federal environmental permits on EPA’s behalf (EPA 2024a).

• An EPA operating permit is required to ensure compliance with air emissions regulations
(40 CFR 1C, Parts 70 and 71).
• The purpose of the Spill Prevention, Control, and Countermeasure regulation is to
prevent discharges of petroleum into navigable waters and applies to facilities with
aboveground store tank capacity exceeding 1,320 gallons or underground storage
capacity exceeding 42,000 gallons (40 CFR 112; Defense Logistics Agency 2019). It
requires secondary containment for the largest storage tank and “sufficient freeboard to
contain precipitation” (40 CFR 112).
• The National Pollutant Discharge Elimination System ensures that stormwater does not
contain fuel. This requires monthly tank inspections to check for leaks (40 CFR 122).

20
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
• The International Code Council’s International Fire Code, generally adopted by state fire
marshals, contains design and operational standards for types of facilities, processes, and
materials for use at fuel terminals.
Terminals are also subject to state and local regulations. Local authorities having jurisdiction
refers to regulating organizations, offices, or individuals responsible for overseeing codes and
standards. Examples of authorities having jurisdiction include local fire marshals, state energy
and environment offices, air and water boards, and similar organizations or offices.

3.2.2 Airline, General Aviation, and Airport Roles


Many but not all airlines have entered into offtake agreements with existing and anticipated
future SAF producers. 20 Airlines are responsible for ensuring fuel supply for their aircraft by
working with airline consortiums at various airports and with fuel suppliers (both SAF and Jet
A), terminals, and distributors. Airlines have been involved in evaluating the logistics to move
SAF to their airport hubs. General and business aviation are other significant consumers of SAF
as a solution to meet both their and their customers’ corporate climate and environmental
requirements and goals. General aviation also enters into offtake agreements and determines
logistics for moving fuel to end users. Airlines share refueling infrastructure, and while one or
more airlines may purchase SAF/Jet A blends, all airlines must agree to its use, as specific fuel is
generally not directed toward a specific airline or flight.

Both airlines and general aviation are expected to participate in book-and-claim—an accounting
practice that enables an entity to purchase and gain SAF benefits regardless of where the SAF/Jet
A blend is used. Book-and-claim can help reduce costs by using the SAF/Jet A blend closest to
where it is produced, and the SAF claim is captured by the entity (e.g., airline, business
customer) who purchased it.

Airports do not purchase jet fuel, but they play an important role in preparing their location for
SAF/Jet A blend use. Airports have brought together airlines, fuel producers, suppliers,
terminals, and other entitles in the fuel supply chain to plan to enable SAF receipt and blending
in their geographic location and scale for future greater volumes. San Francisco International
Airport, Seattle-Tacoma International Airport, and Port Authority of New York and New Jersey
airports, for example, have prepared studies to determine the infrastructure in their area to bring
in and blend SAF for delivery to their airports.

3.2.3 European SAF Logistics and Blending


European aviation meets the same stringent quality standards as the United States. Europe does
not have airline fuel consortiums. SAF plants currently supplying European markets are largely
water-based, so neat SAF is more likely to travel by tanker or barge than truck or pipeline. It is
expected in the future that SAF will be transported by train and/or truck. Blending occurs at
either terminals or refineries. There are at least two petroleum refineries coprocessing SAF, and
in these instances the blending and certification occur at the refinery, and it is business as usual
throughout the supply chain (Eni 2023; TotalEnergies 2023).

20
ICAO maintains a list of publicly announced offtake agreements: www.icao.int/environmental-
protection/GFAAF/Pages/Offtake-Agreements.aspx.

21
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Neat SAF loaded onto ships is certified with a certificate of quality at the loading port, upon
receipt is checked for compliance with ASTM D7566 annex tables, and the Aviation Fuel
Quality Requirements for Jointly Operated Systems checklist is completed. Before off-loading
from a tanker, the previous documents are checked, a recertification test is conducted onboard,
and then a COA is done after the fuel is delivered to a dedicated SAF tank at the terminal. A
control check is performed on the dedicated SAF tank, and then it is pumped to a dedicated SAF
blending tank where Jet A is also pumped. After blending, testing is done to ensure compliance
with ASTM D7566 Table 1 Parts 1 and 2, and an Aviation Fuel Quality Requirements for Jointly
Operated Systems checklist is performed. If it passes, a certificate of quality is generated, and the
fuel can be delivered to the airport.

SAF/Jet A blend ratios range between 15% and 45%. At terminals, SAF generally requires more
dedicated tanks and segregation for blending, and there are constrains within the existing
European terminal infrastructure to lease and build new equipment. It requires significant capital
investment to retrofit existing facilities to accommodate new fuels. SAF/Jet A blends are largely
delivered by pipeline to airports—fewer European airports are serviced by truck. There are no
airline fuel consortiums in Europe—airport tank farms are either owned by airports or joint
ventures among fuel suppliers.

22
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
4 Conclusions
Both domestic and imported SAF volumes are increasing, and logistics and blending must be
considered. It is preferable to certify the SAF/Jet A blend as ASTM D1655 and mitigate any
potential fuel quality issues upstream of an airport. Therefore, existing terminals are the
preferred location for blending fuel due to existing infrastructure and blending equipment,
insurance, and experience for on-highway transportation fuels. Blending at terminals results in
business as usual at airports; the same pipelines, trucks, tank farms, and hydraulic systems are
used to deliver the SAF/Jet A blend to aircraft. Blending can take place at a terminal directly
connected to an airport by pipeline or thousands of miles away and delivered by pipeline to
terminals serving the airport(s) of interest. The source of SAF, purchaser, end user, logistics,
infrastructure availability, and cost are all factors that could impact preferred terminal locations
for blending. The lowest-cost and quickest-timeline scenario would be to use existing tanks at a
terminal. Costs increase if new tanks are added to an existing terminal, and the capital
investment would be significant and the timeline long to build a new terminal. It is business as
usual at airports using the same pipelines and trucks to deliver SAF/Jet A blends as to deliver
petroleum blends today. The capital investment in any infrastructure would be made upstream of
an airport.

23
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
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