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Combating the Existential Threat of Climate Change with Sustainable Aviation Fuel: Strategies for the Department of Defense to Overcome the Statutory Limitation on Procurement of Alternative Fuels

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The Department of Defense (DOD) has described climate change as an“existential threat” to national security. Yet, the DOD is the world’s single largest institutional producer of greenhouse gases (GHG). While the DOD has vowed to “meet the threat,” the 2022 National Defense Strategy does not list combating climate change as one of the four national Defense priorities. It is imperative that DOD find ways to reduce its GHG emissions without compromising its strategic priorities. Jet fuel consumption is a major source of DOD’s GHG emissions. As the civil aviation industry looks to become net-zero by 2050, it anticipates that sustainable aviation fuel (SAF) will provide up to 65 percent of the industry’s GHG emissions reductions. SAF reduces lifecycle GHG emissions by up to 80 percent and has performance characteristics that are virtually identical to those of petroleum-derived jet fuel. SAF can be used without any changes to aircraft or fueling infrastructure. Accordingly, SAF provides DOD a significant opportunity to reduce its GHG emissions while still accomplishing its mission. The Department of the Navy (DON) first tried to make an institutional shift to alternative fuels in 2009, but biofuels were much more expensive than conventional fuels. Frustrated by the DON’s expenditures on biofuels, Congress enacted a statute that precludes DOD from making bulk purchases of alternative fuels unless they are costcompetitive with conventional fuels. This paper recommends strategies to help DOD overcome this statutory restraint in order to make a meaningful contribution to the fight against climate change.

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