Commercial Engagement Readiness Level

A record of progress, not a list of announcements

The CERL questionnaire and the CERL workbook were built last year, and the effort stalled before a single developer completed either one. The CERL tool is the new work: software that replaces the workbook, keeps the questionnaire exactly as written, and makes the case for restarting.

Proposal · not yet seen by CAAFI

Three things are named in this document, and they are kept strictly apart.

THE CERL QUESTIONNAIRE — sixty questions across six categories, on a signed form. Built last year. Unchanged, and staying unchanged.

THE CERL WORKBOOK — the Excel file that scores the questionnaire and draws the radar charts. Built last year alongside it. The effort stalled before any developer completed a submission, and the workbook has not been used in the field.

THE CERL TOOL — software that replaces the CERL workbook while keeping the CERL questionnaire verbatim. Described throughout this document and embedded in section 10. Nobody at CAAFI has seen it.

Everything the CERL tool does is set in this colour throughout, so what is being proposed can be told apart from what already exists at a glance.

01  /  THE PROBLEM

Nobody can tell which announced gallons are real

Every published SAF forecast is assembled from press releases. Two credible sources describing the same 2030 horizon can differ by nearly an order of magnitude, and neither can show its work.

688M
gallons of announced neat SAF intentions, CAAFI's own estimate where production slates aren't specified
3.4B
gallons per year from 29 US facilities by end of 2030, on an equivalent Argus dataset
3B
gallons per year — the SAF Grand Challenge target both figures are measured against

The gap isn't a disagreement about arithmetic. It's a disagreement about what counts. Argus counts announcements; CAAFI counts announcements it has reason to believe. Neither number is attested to by the developer, dated, or backed by documentation, so neither can be interrogated.

The CERL questionnaire already asks the right questions — sixty of them, across six domains, signed by a named officer of the company. The instrument is not the problem. What is missing is a way to collect the answers at scale, keep them clean as they accumulate, and turn them into a number that can be republished every month without anyone retyping anything.

Collection at scale is the CERL workbook's weakest ground: one file, one editor at a time, no history, no way for a developer to submit directly, and no mechanism for anything to happen once an answer changes. The CERL questionnaire is sound and worth keeping exactly as it stands. The CERL workbook cannot carry what has to come next, which is why the effort stalled the first time.

02  /  THE CERL TOOL

Five stages, one record

The CERL questionnaire is unchanged — the sixty items in the CERL tool are verbatim from the signed form. Everything downstream of the questions is new.

01
SubmitDeveloper answers the sixty items against a specific site, attests, and links supporting documentation.
02
RegisterAnswers land against a permanent project number. Near-matches are flagged as they are typed, without blocking anyone.
03
ScoreSix category scores and a readiness-weighted volume, recalculated on every submission and kept as a dated snapshot.
04
RouteThe first unmet item in each category becomes a named ask, held until the introduction can actually succeed.
05
MatchRegistered value chain partners are alerted anonymously when a project crosses into their range.
03  /  SCORING

Two numbers, because they disagree and the disagreement is informative

The CERL questionnaire says evaluation may stop at the first No. The CERL workbook adds up every Yes. The two rules produce different answers, and each is right about something different.

Try it — click to toggle answers
Ladder
Sum
Stranded

The ladder is the headline. It is how far a project has actually walked, in order, and it is what an offtaker or a lender means when they ask where a project stands. It cannot be inflated by answering the easy questions.

The sum is kept in the detail view, because out-of-order progress is real. A project can have a signed feedstock contract before its sustainability certification is complete. Discarding out-of-order progress discards information.

The gap between them is a diagnostic. A project with several Yes answers stranded above a No is either genuinely working out of sequence — worth understanding — or has misread a question, which is worth a phone call. Neither scoring rule alone surfaces that.
04  /  DATA MODEL

The duplicate problem is a missing layer, not a matching problem

The CERL workbook records companies and sites at the same level in its entity table. One level for two different kinds of thing guarantees collisions, and several are already sitting in the data.

What's in the data nowWhat it actually is
DG Fuels appears in twelve rowsOne company, twelve distinct refineries
"Cinergic Energy" and "Lafayette Renewable Fuels, LLC — Cinergic Energy"One project, two records, same contact person
"Fidelis New Energy — Gron Fuels" and "Grön Fuels"One project, same city and pathway, diacritic variant
"SAFFiRE" and "Saffire Renewables"Possibly two real projects at different sites — a human has to decide

No matching algorithm resolves that last row, which is why the CERL tool does not try to. Records separate into three tiers — organization, project, dated submission — which is enough structure to stop a company and a site being confused for one another.

Developers create their own projects, and nothing stands in the way

An earlier version of this required a developer to search the registry, claim an existing record, and wait for approval before a new one could be created. That was the wrong trade. Nobody has submitted anything yet; the binding constraint is getting people to engage at all, and an approval queue between a developer and their first entry is exactly the friction that ends the attempt.

So creation is open. As a developer types a site and state, anything close already in the registry surfaces underneath — "this looks like project 46, is that yours?" — and they can claim it in one click or carry on. If they carry on and it turns out to be a duplicate, it is a duplicate that gets merged later, with both submission histories preserved. A duplicate is a small, fixable problem. A developer who gave up at the registration screen is not recoverable.

Submissions are snapshots, not updates

The CERL workbook overwrites: every prior state of every project is lost the moment a cell changes. Under snapshots, an update writes a new dated record and the old one stands, which produces year-over-year movement for free — which projects advanced, how far, and how long each gate took to clear. Snapshots are the one capability the CERL workbook structurally cannot have, and they are the basis for every trend view in section 10.

05  /  DISCLOSURE

Three tiers, and the middle one holds

Confidentiality is the condition on which developers submit anything at all. The CERL tool treats confidentiality as a hard constraint rather than as a setting.

Public

Numbers only

  • Project number, pathway, state
  • Six category scores
  • Volume band
  • No company name, no contacts, no answers
Value chain partner

Matches, anonymised

  • Only their own category
  • Only projects that opted in
  • Only within their stated range
  • Identity released separately, or not at all
CAAFI

Everything

  • Names, contacts, every answer
  • Documentation links
  • Full submission history
  • A log of every disclosure ever made

Nothing crosses a tier automatically. A partner who wants to talk to a project raises a request; CAAFI asks the developer; the developer decides. That single rule is what keeps the alerting described in section 07 from quietly becoming a lead list.

06  /  ROUTING

The first No is the ask

Routing is where the CERL tool stops being a scoreboard. Every project has exactly six unmet items — one per category — and each one names something CAAFI can do about it.

Where a project stopsWhat it needsHeld until
FRL 6Pilot facility or DOE BETO funding
FORL 8Grower co-ops and aggregatorsERL 3
ERL 4EPC firms with SAF experienceFRL 7
F$RL 8Project finance lenders, DOE LPOERL 8
OARL 3Airline or aggregator fuel teamFRL 6
EPCL 1Environmental consultants and lead agency

The third column is the part that matters. An introduction made too early is worse than none — it spends a connection that doesn't renew and costs the developer credibility with exactly the counterparty they most need. Pitching an offtaker before the fuel is past pilot, or a lender before FEED, does damage that a later, better-timed introduction can't undo.

That timing judgement currently lives in a few people's heads. Writing it down is most of the intellectual work in this build, and it is the thing no one else could replicate. The rules encoded in the CERL tool are a first draft and need CAAFI's correction.

Developers see their six asks and whether an introduction has been made. They do not see the holds, the queue, or their position in it. CAAFI keeps the discretion; the developer gets a reason to keep the record current.

What the developer gets back

Connection points, the same as the value chain side — six of them, one per category, updated every time they submit.

And visibility, on their own terms. A readiness score held by a neutral third party is worth something to a developer courting an offtaker, a lender or a state agency, because it states a level rather than an adjective. Each category can be opened or closed independently, at any time. Most will start closed.

The incentive runs the right way. A lower score means more unmet items, which means more introductions. The projects with most to gain from submitting are the ones furthest back — which is what stops the registry filling up with only the winners.
07  /  NETWORK

The half of the CERL tool that is genuinely new

Sections 02 through 06 are familiar in shape. Readiness ladders are CAAFI's own invention — FRL and FSRL have been in the field for years — and asking a developer to place a project on one is a well-understood idea, even though the CERL questionnaire has never been completed by a developer directly. The CERL tool makes that collection faster and cleaner. It does not make the underlying idea new.

Asking the value chain to declare its own criteria is the unfamiliar move, and it is worth being explicit that it has not been done in this industry. Today a catalyst lab, an EPC firm, a lender and an airline fuel team all find projects the same way: by hearing about them. Nobody has asked them to write down, in advance, the readiness range at which a conversation is actually worth their time. The information exists — every one of them has that threshold, and applies it in the first ten minutes of every call — it has simply never been collected.

Partners register once: which category they work in, what they provide, and the range they want to hear about. When a project crosses into it, an alert fires. A range rather than a floor, because the constraint runs both ways — a pilot facility has no use for a project already ASTM qualified, and a lender none for one that hasn't reached FEED. The upper bound is what keeps the alerts worth opening.

Matching changes what CAAFI is, slightly

Running an intake questionnaire is a convening activity. Operating a matching network is closer to running a marketplace, and it carries obligations the first does not: a vetting standard, because approving a partner is an implicit endorsement; a service expectation, because partners who register expect alerts to arrive; and a neutrality question, because CAAFI would be routing commercial opportunity between members.

None of those is disqualifying, and the upside is substantial — introductions stop being rate-limited by a handful of calendars. But they arrive the day this launches rather than later, which is why the vetting standard and the alert cap sit at the top of the decisions list rather than the bottom.

Registration is open, and says so plainly

Screening partners for quality would put CAAFI in the business of rating firms — fielding appeals from anyone turned down, and owning the outcome when an approved partner disappoints. The alternative is to check identity only, admit everyone, and be explicit that admission means nothing beyond identity:

Registration is open and self-declared. CAAFI does not assess, verify or endorse any registered organisation's capability, financial standing, track record or fitness for a project. Matching is automated: an alert is generated when a project's self-reported readiness falls within the range that organisation stated for itself. An alert is a data-handling result, not a recommendation. Parties remain responsible for their own diligence.

That holds up better than standard boilerplate because it names the mechanism. A reader can see that a range was compared and nothing was judged. Identity checking stays factual and cheap: a named individual, a corporate email domain, an organisation URL. Removal happens on complaint rather than by screening in advance.

Developers decide who may see them

A disclaimer covers competence but not motive. The registrant worth worrying about is not a weak engineering firm — it is a competing developer or a rival's commercial team registering as an advisor to watch the field advance in real time. Their credentials would be perfectly good, so no amount of vetting would catch them.

Two things already blunt that. Alerts are anonymised, so a watcher learns only that a project number crossed a level. And identity release runs through the developer, so no contact happens without permission.

The blocklist closes the rest. A developer names organisations that must never be alerted about their projects — typed in freely, no reason required, no list to browse. Entries match on organisation name or email domain, as a substring, so a single word blocks every variant of a company's name, and a block placed against an organisation that has not registered simply waits for them. A block suppresses alerts, contact requests and CAAFI-routed introductions alike, and the blocked party is never told.

Deliberately, there is no register for developers to pick from. Publishing who has signed up would expose partners who have good reasons for discretion, airlines above all. Blocking by name asks the developer to name a concern they already have rather than to go looking for one.

The blocklist is a better answer than vetting. CAAFI is not deciding which organisations are legitimate. Each developer decides who may see their own projects, which is a question they are far better placed to answer and one CAAFI has no business adjudicating.

The by-product is a market measurement

Aggregate what partners are willing to engage on and the result is something nobody currently publishes: the readiness level at which each part of the value chain actually shows up. If no lender in the network will look at a project before F$RL 8, the number measures where capital begins rather than exposing a gap in the roster. Repeated across six categories, it maps the valley of death by showing precisely where the supply side stops appearing.

The failure mode is volume. Twenty partners at one threshold and forty projects crossing it is eight hundred emails. Developers stop submitting, the dataset decays, and the measurement above becomes worthless. The cap on alerts per crossing matters more than the matching logic does.
08  /  ADOPTION

The hard part is not the CERL tool

No developer has ever entered their own data into the CERL workbook. Every record in it was typed in on their behalf, which is a large part of why the effort stalled last year. The problem to solve is a cold-start problem, and cold starts are solved by reach rather than by engineering.

Contact details for most of the industry already exist. That list is the asset. The CERL tool can be linked to in an email, opened in a browser, and completed in one sitting with no account approval standing in the way — which converts the list into submissions in a way that emailing the CERL workbook as an attachment never will.

Automated monthly prompts

The single highest-value piece of automation is a scheduled reminder. Once a month, everyone on the list who has not submitted gets a short note with a direct link. Everyone who has submitted gets a different note — their current six asks, their score, and a one-click confirmation that nothing has changed. Confirmation is as valuable as an update: it is what keeps a record from going stale, and it takes the recipient ten seconds.

That loop runs without anyone at CAAFI touching it, and it is what converts a static list of email addresses into a dataset that refreshes itself.

09  /  SURVIVABILITY

It should not depend on CAAFI existing

A registry that dies with its custodian was never really a registry. The design question is how much of the CERL tool can run with nobody at the wheel — and the answer is nearly all of it.

Already automatic

Account creation by email domain, project creation, scoring, snapshots, threshold alerts, partner matching, the public dashboard, the monthly reminder loop, and full data export. None of these need a person. They are arithmetic and scheduling.

Currently needs judgement, and how each one is removed

Needs a human todayHow it stops needing one
Merging genuine duplicatesAsk the developer at the point of creation. They know whether project 46 is theirs; nobody else does.
Approving value chain partnersPublish the criteria, verify the email domain, auto-admit, and remove on complaint rather than screening in advance.
Ripeness thresholdsA one-time exercise. Once written down they are just rules, and they run themselves.
Releasing identity on requestRoute the request straight to the developer with approve and decline links. CAAFI is a bystander to its own permission flow.
Reviewing submissionsOptional. Everything publishes as self-reported; a review badge is an enhancement, not a gate.
Take those five away and there is no critical path through any person. What remains is a website, a database, a scheduled email, and an exportable file. That runs for a trivial monthly cost and can be handed to another organisation intact, or left standing as a read-only archive, without anything being lost.

Worth stating the cost of this honestly: automating the introductions removes exactly the discretion that makes them valuable. A rules-based referral is not the same as a well-timed phone call from someone the recipient already trusts. The sensible position is that the automated layer is the floor — it keeps working regardless of who is around — and human judgement is applied on top of it while there are people to apply it.

10  /  OUTPUTS

What comes out the other end

Four views the CERL workbook cannot produce, all generated by the CERL tool from the same sixty answers.

Portfolio at a glance
The CERL workbook's radar, rebuilt. Solid fill is the ladder; the dashed outline is the sum. Where the two separate, a project is working out of sequence — visible instantly across an entire portfolio rather than one project at a time.
Announced against backed
Cumulative announced capacity, and the same capacity weighted by demonstrated readiness, measured against the Grand Challenge target.
Where the value chain shows up
Aggregated engagement ranges from registered partners. The pale region is readiness no one has volunteered to serve.
Movement
Because every submission is kept rather than overwritten, progression becomes measurable: which projects advanced, by how much, and how long each gate took to clear. Movement is the view the CERL workbook structurally cannot produce, and the one that answers what a year of CAAFI's work actually achieved.
The second chart is the one to look at twice. No registered lender will engage before F$RL 8, and no offtaker before OARL 4. That pale band on the left is the valley of death, measured rather than asserted — and it is a number only CAAFI would be in a position to publish.

The CERL tool itself

Four role views, live below. Switch roles with the control at the top right: Public sees numbers only, Developer is signed in as DG Fuels with three projects, Value chain is a partner setting their range, CAAFI staff sees everything including the routing queue and the vetting inbox.

The CERL tool runs entirely in the browser at this stage. Refreshing resets it.

11  /  DECISIONS NEEDED

Eight decisions, each with a recommendation

Each was a placeholder in the CERL tool. Each now carries a recommended default, in teal beneath the question. None is a technical question, and all remain CAAFI's to set.

  1. Alert cap and rankingHow many partners hear about one crossing, and in what order. Without rotation the first partner to register takes every lead in their category and the rest disengage.RecommendedCap at three partners per crossing, ordered least-recently-alerted so leads rotate, with a monthly ceiling per partner. The numbers tune once real volume shows.
  2. Whether score regressions notifyA project can move backward. Telling a prospective lender would make developers reluctant to opt in at all.RecommendedUpward crossings alert; downward ones do not. A regression stays visible to CAAFI and the developer, and is never sent outbound.
  3. The ripeness thresholdsSix categories, sixty items, and a first-draft judgement on each about when an introduction becomes useful.RecommendedShip the current five holds as editable defaults, red-lined once by a CAAFI hand before any real introduction fires. Don't hold launch to perfect them.
  4. Basis for readiness weightingNameplate multiplied by the ladder score out of sixty, or keyed to specific gates — FID reached, binding offtake signed.RecommendedKeep both — ladder ÷ 60 for the working views, and a separate gate-keyed "backed volume" (past FID, binding offtake) for any figure published externally. Neither stands in for the other.
  5. Reminder cadence and toneMonthly is a starting point. Too frequent and it is ignored, too rare and records go stale between prompts.RecommendedQuarterly for submitters but responsive to events; a decaying sequence for non-submitters; sent in a named person's voice, not a system's.
  6. Review before publicationWhether a submission appears as self-reported immediately or waits for CAAFI to review it.RecommendedPublish immediately, labelled self-reported and unverified, with an optional CAAFI-reviewed badge as an earned signal — never a gate.
  7. Staleness thresholdHow long a project's score stands before it is marked out of date. Twelve months is a guess.RecommendedKeep twelve months, but stamp every figure with its date and label a lapsed record rather than hide it, so a reader can weight it.
  8. CustodianshipWho holds the registry and its data if CAAFI does not. Worth answering before developers are asked to put anything into it.RecommendedName a custodian and a fallback, commit to data portability, and state both to developers before they enter anything. Settle this one first.
12  /  WHAT THIS IS NOT

Honest limits

The CERL tool is a prototype, and it is unannounced. Everything runs in the browser with no database and no accounts, and refreshing resets the data. The CERL tool exists to make the decisions in section 11 concrete enough to argue about. Nobody at CAAFI has seen it, and no commitment has been made to build it out.

The seed data is illustrative. Company names and sites are real, drawn from the CERL workbook's entity table. The answers, scores and volumes are plausible fabrications. Screenshots should not circulate as findings.

It does not live on the main site, and does not need to. CAAFI's site is built on Wix, which has no database and no server-side code. The route around that is settled: a development page on its own Cloudflare URL, with the main site linking across. A separate address keeps the CERL tool independent of the main site's constraints, and puts this document, the CERL tool and anything built next at one URL that can be shared as a link.

The readiness-weighted number will be lower than the announced number. A lower figure is the whole point, but publishing one undercuts the more optimistic ones already in circulation, including CAAFI's own. Framed as "what is actually backed," the lower number is a credibility gain. Framed carelessly, it reads as CAAFI turning pessimistic on the industry. The framing is a decision to take deliberately rather than to discover later.

CERL — Commercial Engagement Readiness Level
A walkthrough of the CERL tool, for internal review. The CERL tool is embedded in section 10 and also runs on its own. Seed data is illustrative — company names are real, answers and volumes are not.