MOR E T HAN A MINERAL

of the technical steps that go into it, will now have to take place,” Buttenhoff says.

The primary outlet for undenatured ethanol is SAF, Buttenhoff explains, and the goal is to get the QAP process worked out so that ethanol-to-jet is workable from a regulatory standpoint.

Hurdles of Implementation

The biointermediates provision has its benefits; however, those opportunities also come with a significant amount of hurdles. One of these hurdles is the complexity around RIN generation, such as that the renewable fuel producer needs to identify each biointermediate supplier’s feedstock. “There are also some physical handling rules around the feedstock, so the biointermediate feedstock has to be physically segregated from any other feedstocks or products, in its own tank and separate from anything else,” Buttenhoff says.

The rules in place around biodiesel producers using these other feedstocks are challenging, she further explains. “To segregate feedstocks from a biodiesel perspective—everybody co-mingles—it’s almost impossible,” she says. “There are a lot of hurdles from the biodiesel side to actually make this work, which is probably an industry that’s very much in need of additional feedstocks with all the renewable diesel facilities coming up.” Buttenhoff explains that this hurdle may be less of a problem for ethanol producers supplying undenatured ethanol as a biointermediate to a renewable fuel producer.

Another future hurdle may be the shortage of available third-party QAP providers, providers is that … we have to develop what our processes will be for our biointermediates, and then we have to submit that to EPA, and they have to approve the procedures that we’re actually going to complete in order to audit or Q-RIN that particular product,” she says.

In the past, putting together and getting EPA approval for initial QAP plans took roughly a year and a half, going a little faster for approval of additional plans. The first biointermediate producer will probably take a while to get through the QAP pathway approval process, Buttenhoff explains, because there will probably be some back-and-forth conversation between the EPA and the auditor in establishing the first procedures for biointermediates.

Buttenhoff adds that should the EPA’s RFS set rule pass in June 2023 in its current form, which outlines mandatory QAP for waste feedstock suppliers and biodiesel companies, it could cause the strain on QAP pro-

Herman agrees that the speed of adoption is tempered by the QAP process, since many producers have never been through the process before, and some may not find it worth it for the volume of fuel they would be able to produce.

“I think we’re waiting for the first movers to act,” Buttenhoff says. “It is difficult to be the first one going through a new regulatory process like this one.”

Buttenhoff adds that she hopes in the future, further conversations with the EPA will help tweak the process to be more workable as implementation begins.

Biointermediates may not be the silver bullet that will open the feedstock floodgates, at least not yet. However, the opportunities available may encourage companies such as LanzaJet to begin walking down the long road to biointermediate utilization and RIN generation from fuels that use them.