Federal guidance on the US Inflation Reduction Act's (IRA) 45Z production tax credit will be a lifeline for domestic renewable fuels producers and a key determinant of production splits from 2025 onward, with the largest awards currently earmarked for aviation fuels.
Although preliminary guidance and registration protocols were released earlier in 2024, the industry awaits the impending signal that will replace the IRA's section 40B blender's tax credit.
The expiring blender's tax credit (BTC) was instrumental in the ramp-up of US renewable diesel production in recent years. Renewable diesel comprised about 65pc of California's overall diesel pool by the first quarter of 2024, but that growing availability has come at the expense of the value of several of the fuel's financial incentives.
Valuation of California's prompt Low Carbon Fuel Standard (LCFS) credits has trended lower across the past four years. Prices in May reached an almost nine-year low of $41/t and remained depressed through the summer, during which both renewable diesel imports and domestic production hit all-time highs.
Preliminary guidance on the 45Z credit proposes aviation fuels earn $1.75/USG while the maximum for road fuels would reach only $1/USG. Fuels with lower carbon intensity measured by the complete production process will receive greater rewards, in contrast to the expiring blenders tax credit (BTC). This new opportunity, originally announced in 2022, signaled the possibility of increased SAF production and innovation.
A flurry of developers have moved forward with SAF projects since, while major renewable fuel producers eye converting RD capacity to SAF. With similar refinery tooling, catalysts, and feedstock requirements, the ability to produce both fuels and toggle between the two has the potential to re-inflate producers' margins.
Another opportunity enabled by SAF production as opposed to road fuels is the ability to monetize SAF certificates (SAFc) as a part of the production process. To offset the costs associated with production and act as an added profit generator, existing SAF producers partner with corporate clients and public sector entities looking to offset emissions from business activities like air travel. Under SAFc agreements, a producer will sell the physical fuel to the air carrier, while the environmental attributes go to the corporate client. The physical commodity and certificates are decoupled using a "book and claim" scheme, which creates a digital registry that tracks associated emissions.
Renewable diesel production is for now concentrated among biorefineries throughout the US Gulf coast, Midwest and west coast. US capacity trended higher in 2024, largely on the back of conversions, and the supply balance from 2025 onward will likely hinge on domestic output as the new credit scheme removes key incentives for imports.
Global Clean Energy in mid-December reached commercial operations of about 5,900 b/d of RD at its Bakersfield, California, conversion. But some refiners have begun to pump the brakes on renewable diesel expansion, citing a degradation in economics that could worsen without the BTC's guaranteed $1/USG. Vertex Energy in the third quarter finished reverting a renewable fuels hydrocracking unit back to processing fossil fuel feedstocks at its 88,000 b/d Mobile, Alabama, facility. Renewable diesel market participants otherwise expect refiners will bring forward into early 2025 planned maintenance, and potentially curb output, as the market overall awaits clarification on 45Z eligibility and award levels.
As of 2024, the US Environmental Protection Agency's monthly reporting of renewable fuel production through RIN generation data breaks out renewable jet fuel. The data show a three-fold increase in the amount of SAF produced in the US versus 2023, but also a large boom in imports, mostly from Asia to the US west coast. The expiring BTC enabled the influx of imports, as refiners were able to bring finished neat SAF onshore, blend it with conventional jet fuel, and receive the tax credit, valued at roughly $1.50/USG. With no BTC, import trade flows will be in jeopardy, because new policy aims to support domestic production. In the short term, this would drastically reduce the amount of SAF available in the US, with imports making up roughly 62pc of supply in 2024.
These new domestic producers, padded by a new SAF production tax credit, will have ample opportunity to meet US market demand. As airlines look to buy SAF in areas beyond California, having an expansive infrastructure and logistical framework including producers across the US will keep airlines well positioned to increase SAF consumption.
