The energy sector has had many recent advancements in developing new types of renewable fuels and innovative technologies for producing hydrogen as part of an overall approach to renewable and sustainable energy. Renewable fuels are synthetically produced alternatives to legacy fossil fuels that can act as drop-in replacements, allowing for easy distribution without the need for changes in the current infrastructure. They offer a promising path to decarbonizing sectors that are hard to electrify.

Renewable fuels include sustainable aviation fuel (SAF), renewable diesel (RD), and renewable naphtha (RN). Renewable and sustainable feedstocks such as used cooking oil, animal fats, vegetable oils, corn sugars, and other waste streams can be combined with low- and zero-carbon hydrogen to produce various types of renewable fuels. Hydrogen is a key component in producing many renewable fuels. Hydroprocessing involves catalytically contacting the renewable feedstocks with hydrogen gas to remove impurities and convert the feedstock to products with more desirable fuel properties.

Producing renewable fuels can present several challenges relating to environmental regulatory compliance and permitting. As these are novel processes, there is not much existing precedent for establishing regulatory applicability. Many facilities producing renewable fuels are utilizing sites and assets historically utilized for petroleum-based fuels production. As the feedstocks for renewables processes are not petroleum based, the regulations governing the petroleum industry are not always applicable to renewables processing. Instead, renewables production is more closely subjected to many of the regulations governing the chemical manufacturing industry.

Applicability can change depending on the specific type of feedstock used but also on the products and by-products that are produced. Any additives used in the process can also affect applicability. Depending on the Volatile Organic Content and Hazardous Air Pollutant content, many different rules can potentially be triggered including New Source Performance Standards (NSPS):

Each project needs to be analyzed individually to fully understand the regulatory applicability. A detailed analysis must be conducted on every renewables project to ensure all rules and regulations are appropriately followed.

As producing renewable fuels can be very hydrogen-intensive, identifying cleaner sources of hydrogen is a key component to sustainably producing renewable fuels. For ease of discussion, hydrogen is often classified by its means of production into three general types (Other types of hydrogen production are further classified, but these three types represent the current focus of production efforts). Gray hydrogen is what is traditionally used in manufacturing processes today and is derived from natural gas or other industrial fuel gas feedstocks. Gray hydrogen is produced via steam methane reforming or similar processes and is a significant source of carbon dioxide emissions. Green hydrogen is hydrogen produced from the electrolysis of water to separate hydrogen using electricity from renewable sources. Green hydrogen eliminates the production of carbon dioxide but is both energy and water intensive. Blue hydrogen uses the same production process as gray hydrogen but employs Carbon Capture Sequestration to reduce carbon dioxide emissions from the process.

Environmental permitting to meet the growing hydrogen demand from renewable fuels production presents unique challenges. Gray hydrogen is associated with significant natural gas combustion and generation of criteria pollutants, especially NOx (nitrogen oxides), can become problematic in the air permitting process. Green hydrogen production requires the availability of renewable electric generation and supporting infrastructure. It also poses challenges in areas with water scarcity and/or water intake requirements under Section 316(b) of the Clean Water Act. Blue hydrogen poses challenges in permitting the pipelines and infrastructure required to transport captured carbon dioxide to suitable injection well locations. Additionally, as federal funding continues to support investment in cleaner hydrogen production, this carries with it the need to evaluate National Environmental Policy Act (NEPA) compliance for these projects. This can become an onerous multidisciplinary effort.

Renewable fuels are a very promising alternative to traditional fuels with the potential to help decarbonize many processes. However, with the novelty of their development, there is much to learn about the environmental regulations that govern them. As new projects are completed, they will help set the precedents moving forward. For renewables projects, it is crucial that an in-depth regulatory applicability study is conducted.

For more information on how Trinity can support your organization’s renewables project, contact Inaas Darrat.