Among the regulations governing the development of renewable fuels are the various requirements in the U.S. and other countries around the world to have a new fuel certified as appropriate for sale and use. In most countries, these regulations are distinct from more recently-enacted laws under which a fuel might be certified as “renewable” or to be sustainably produced – these regulations apply to all fuels and fuel additives , both traditional and renewable. The goal of these fuel certification regulations are to ensure that a new fuel has the appropriate chemical composition and that it is suitable for use in the range of engine types for which it is intended.
In this entry and in the previous post, I’ve briefly summarized the regulations or other requirements that are in place in the U.S. for different fuel types. Today’s post will describe testing and registration requirements for fuels intended for military use, following the earlier post which covered requirements for testing and certification of fuels for commercial (civilian) use. I hope to cover regulations and other required procedures outside the U.S. in a subsequent post.
The U.S. military branches have, in recent years, been quite active in testing and promoting the adoption of alternative fuels, including biofuels and other renewables. Each of the branches described below has adopted overall energy strategies of which development of alternative fuels is a major component, with the U.S. Navy perhaps being the most aggressive to date in supporting internal and external activities in alternative fuel development. The motivations for this focus include the need to address the costs and logistics of obtaining and transporting the very large amounts of fuels the military branches use, as well as an interest in reducing the carbon footprint, especially for aviation fuels. In fact, Section 526 of the Energy Security and Independence Act (EISA) of 2007 requires that any alternative fuels the Defense Department purchases must have lifecycle greenhouse gas emissions less than or equal to conventional petroleum fuels. Unfortunately, these programs have not been immune from controversy, and the potential use of biofuels for military or civilian aviation, as well as the role of the military branches in supporting renewable fuel development, have been the subject of criticism and attack from the political right wing in recent years. I’ll be summarizing some recent developments on this front in an upcoming post in my Biofuel Policy Watch blog.
As mentioned in the previous post, these certification regimes involve oversight over at least three distinct components. These are fuel composition (chemical make-up and physical/chemical properties); engine suitability and performance testing; and health effects of the emissions from fuel combustion. A fourth criteria which comes into play for novel aviation fuels is a consideration of the production pathway used to create the fuel, to ensure consistency and quality of the manufactured fuel product. Fuel composition and properties are often ascertained through the use of standard testing protocols to confirm that the fuel meets the accepted specification. Both the standards and the test protocols are often those certified by ASTM International or the equivalent standards issued by military branches or other international organizations. Engine testing may not be required in all cases, especially where the fuel has been shown to meet the applicable chemical specifications so as to be identical to a previously approved fuel, but where it is required the needed testing is often extensive. Similarly, assessment of health effects of emissions may be required under certain laws such as the U.S. Clean Air Act, but these requirements may be waived for fuels whose composition is identical to fuels currently on the market.
In the remainder of this post, I’ll describe the programs and processes in place in the U.S. for testing and certification of motor vehicle fuels and aviation fuels for military use.
The following are the fuels covered in these posts:
|Fuel Type||Application||Agency/Military Branch|
|Ethanol, butanol, isobutanol||All (regulated as fuel additives)||EPA|
|Diesel, biodiesel, renewable diesel, renewable gasoline and other “drop-in” fuels||Civilian (auto, truck, nautical, small engines)||EPA|
|Military (ground, nautical)||Navy (including Coast Guard and Marines)|
|Jet fuel||Civilian (commercial aviation)||FAA, through the ASTM standards process|
|Military||Army*, Navy, Air Force|
*Note: the U.S. Army uses jet fuel for its ground transportation needs.
Each of the major U.S. military branches maintains its own program for testing and certification of transportation fuels. These programs are generally geared towards testing of aviation fuels, since all three major branches of the military (Army, Navy and Air Force) use aviation fuels, but it’s harder to draw bright lines between different programs: the Navy utilizes the same program for jet fuels as it does for the diesel fuels it uses in its ships, while the Army uses jet fuel in its ground vehicles, rather than traditional diesel fuel, and so maintains only a program for aviation fuel testing. I’ll therefore summarize the programs of each of the military branches, indicating which types of fuels might apply in each case.
U.S. Navy. The Navy has made a commitment to increased use of alternative fuels and renewable energy sources, as part of a major effort to improve energy security and address climate change across all its operations. Among several components of a strategic energy plan announced early in the Obama Administration, the Navy is aiming to reduce petroleum-based fuel use in its non-tactical fleet by 50% by 2015, and to achieve 50% utilization of alternative energy sources across the entire Department of the Navy, including its tactical fleet.
This has led the Navy to develop a comprehensive program for testing and certification of alternative fuels for its own use and for use by the Marines and the Coast Guard. The Navy’s fuel certification program is managed by the Naval Air Systems Command (NAVAIR) at its fuel laboratory in Patuxent River, Maryland, often in close collaboration with the Naval Sea Systems Command (NAVSEA). The Navy’s process to certify alternative fuels is conceptually similar to the ASTM process described in the previous post for civilian aviation fuels – an alternative fuel produced from a new pathway must undergo an approval process that includes analytical testing and engine testing, and which requires stakeholder approval. However, the Navy does not require a formal balloting process as does ASTM and furthermore the Navy maintains the right to approve fuels that deviate from spec to some extent, if deemed necessary or desirable in the case of any given fuel.
The Navy uses NATO specification F-76 (MIL-DTL-16884) as its standard for its shipboard diesel fuels: this standard is similar to the ASTM D-975 diesel standard but differs in certain ways that reflect the intended use of the fuel aboard nautical vessels, including the requirement for a higher flash point and other features to reflect the need for long-term fuel storage aboard oceangoing vessels. Similarly, the Navy uses JP-5 (MIL-DTL-5624) as its standard for aviation fuels – this standard differs from JP-8 in requiring a higher flash point.
Using its own protocols the Navy utilizes a four to five step testing process. The first step involves analytical chemistry to ascertain whether the fuel meets the applicable specifications. Second is fit-for-purpose testing. Third is compatibility testing on engine components. The fourth step is full-scale engine testing, and finally, there would be a test run in a Navy ship or aircraft, as applicable. The entire process might take 2-3 years. The Navy would generally undertake all testing of a new fuel themselves, but its Fuel Lab has limited capabilities and cannot carry all fuels through the entire process. The Lab is committed to performing the initial testing (analysis and fit-for-purpose testing) at its own expense for all companies that can provide approximately 5-10 gallons of fuel for testing, but not every fuel would then be accepted for further testing at Navy expense, depending on their projected testing capacity and availability of fuel storage. For those fuels selected for further testing at the Navy’s expense, the Navy would either contract to purchase sufficient fuel from the company developing the fuel, or would enter into a Cooperative Research and Development Agreement with the developer, who would then provide the fuel free of cost. At the conclusion of testing for a fuel produced by a new pathway, the Navy lab will issue a qualification report, which would then be referred to stakeholders with a recommendation to incorporate the new pathway into the appropriate ASTM specification.
In recent years, the Navy has been very aggressive about testing alternative fuels and has conducted a number of test runs of renewable fuels in aircraft and ships. The use and testing of alternative fuels has been a part of the Navy’s “Great Green Fleet” program, which is an ambitious effort to transform naval operations in several ways to be more energy efficient and/or to reduce the program’s carbon footprint. In fact, the Navy has been one of the federal agencies that has most aggressively supported renewable fuels, at least until such programs began to attract the wrath of
U.S. Air Force. The Air Force is also operating under aggressive strategic energy goals: under a 2009 Energy Management policy (USAF Policy Directive 90-17), the Air Force set a goal of certifying all its systems to operate on 50/50 blends of JP-8 with synthetic jet fuel (either meeting the Fischer Tropsch or the HRJ specifications) by 2013, and then to acquire 50% of its fuel needs from domestic synthetic or renewable fuels by 2016. The Air Force’s fuel certification program is run by its Alternative Fuels Certification Office (AFCO), with assistance from the Air Force Research Laboratory (AFRL), both located at Wright-Patterson Air Force Base. The Air Force conducts its testing in accordance with the procedures in Military Handbook 510, and generally seeks to certify fuels that can be drop-in replacements for JP-8 (in accordance with MIL-DTL-83133 or ASTM D-1655 ). The Air Force test program entails several discrete stages, beginning with a “gap analysis”, to determine possible information needs or data gaps, followed by engine testing and flight testing. In the short term, the USAF testing program is dedicated to certification of the use of 50/50 blends of either HRJ or FT alternative fuels with JP-8 in all the aircraft in its fleet, but the Air Force has conducted flight tests with blends incorporating different types of alternative fuels, including those derived from Camelina and other biomass. The Air Force lab has also tested other alternative fuels, including Gevo’s alcohol-to-jet fuel. AFCO has an arrangement with the Federal Aviation Administration and the Commercial Aviation Alternative Fuels Initiative (CAAFI) to certify HRJ fuel – under this arrangement, AFCO provides the fuel, and FAA and CAAFI provide funding for the testing.
U.S. Army. The Army’s energy strategy was laid out in a 2009 plan entitled “Army Energy Security Implementation Strategy”, which calls for 50% of the department’s fuel needs for the training base for its tactical mobility fleet (both surface and air) to be met by alternative fuels by 2028, with stepwise targets in the years leading up to 2028. The Army uses JP-8 jet fuel (meeting the ASTM D-1655 or MIL-DTL-83133 standard) for all its surface and air needs, including ground transportation, although it will sometimes use diesel fuel for ground transportation depending on regional availability. Although the Army cooperates with the Air Force for evaluation of jet fuel alternatives, the Army has also developed testing facilities of its own, housed in the National Automotive Center (NAC), co-located in its Tank Automotive Research, Development and Engineering Center (TARDEC) and its Tank Automotive and Armaments Command (TACOM). TARDEC maintains several centers and laboratories where alternative fuels testing takes place, including its Fuels and Lubricants Research Facility, located at and operated by Southwest Research Institute in San Antonio, and the recently-opened Ground Systems Power and Energy Laboratory. The Army testing program is also a multi-step process, including testing of fuel properties, followed by component testing, engine testing, and finally testing the fuel in a complete system (e.g. tanks or other vehicles).
D. Glass Associates, Inc. is a consulting company specializing in government and regulatory affairs support for renewable fuels and industrial biotechnology. David Glass, Ph.D. is a veteran of over thirty years in the biotechnology industry, with expertise in industrial biotechnology regulatory affairs, U.S. and international renewable fuels regulation, patents, technology licensing, and market and technology assessments. Dr. Glass also serves as director of regulatory affairs for Joule Unlimited Technologies, Inc. More information on D. Glass Associates’ regulatory affairs consulting capabilities, and copies of some of Dr. Glass’s prior presentations on biofuels and biotechnology regulation, are available at www.slideshare.net/djglass99 and at www.dglassassociates.com. The views expressed in this blog are those of Dr. Glass and D. Glass Associates and do not represent the views of Joule Unlimited Technologies, Inc. or any other organization with which Dr. Glass is affiliated. Please visit our other blog, Biofuel Policy Watch.