DfT consultation on mandate for very high SAF use by UK aviation in coming years
The government put out its “Jet Zero” consultation on 16th July (runs to 8th September) including aspirations for the industry to use a great deal of “sustainable aviation fuels” (SAF) in the attempt to keep everyone flying, but with lower carbon emissions. Now it has produced its consultation on mandating (instructing, ordering) the use of SAF in future for the sector (runs to 19th September). While the Climate Change Committee, in their advice to government in December 2020, said the most realistic estimate for SAF would be 5-10% by 2050, or at the most optimistic 25%, and with “just over two-thirds of this coming from biofuels and the remainder from carbon-neutral synthetic jet fuel …” Now the SAF mandate consultation is considering “a number of potential SAF uptake scenarios, up to 10% SAF by 2030 and up to 75% SAF by 2050.” They are considering the fossil fuel baseline lifecycle GHG emissions intensity, by which to compare SAF for CO2 savings, as 89 gCO2e/MJ. An eligible new fuel would need to have CO2 savings of at least 60% compared to 89 gCO2e/MJ. They are considering the use of nuclear generated electricity as a way to make eligible SAF. And “feedstocks, including residues, should not be obtained from land with high biodiversity value or land with high carbon stocks in or after January 2008.”
.
Tweet
DfT consultation
Mandating the use of sustainable aviation fuels in the UK
From: Department for Transport
Published 23 July 2021
Summary
Proposes a UK sustainable aviation fuels (SAF) mandate requiring jet fuel suppliers to blend an increasing proportion of SAF into aviation fuel from 2025
This consultation closes at 11:45pm on 19 September 2021
Consultation description
Proposes the introduction of an obligation on fuel suppliers to reduce the carbon footprint of jet fuel used in the UK, to be achieved through greater use of sustainable aviation fuels.
We are seeking comments on the:
- need for a SAF mandate
- high-level ambition and design of the proposed SAF mandate
- fuel eligibility criteria
- interactions between SAF and other domestic and international policy
- compliance, reporting and verification principles that will steer the creation of the scheme
Sustainable aviation fuels (SAF) mandate consultation on reducing the greenhouse gas emissions of aviation fuels in the UK
PDF, 1.49MB, 78 pages
See Page 41 of the document for a better version of this graph and more numbers
AW Note: The consultation does not actually mention the volume, number of tonnes of jet fuel, that it considers could be produced in due course. If the total demand for air travel is much reduced by 2050, it is easier to have a high % of SAF – out of a small overall total – than if the total demand is huge.
.
A few extracts from the document:
Aim of a UK SAF blending mandate and this consultation
6. As announced in the Prime Minister’s Ten Point Plan in November 2020, the Government would like to introduce a UK SAF blending mandate. A long-term obligation can generate demand for SAF, provide an incentive to SAF producers (in the form of a tradable credit) and signal to investors the vital role the Government believes the technology will play in the UK.
7. This consultation seeks views on the high-level ambition and design of the proposed SAF mandate, the eligibility criteria SAF will need to meet, the interactions between SAF and other domestic and international policy and the compliance, reporting and verification principles that will steer the subsequent development of the proposed scheme.
8. This consultation also welcome views on how best a SAF mandate could be designed to foster SAF plants development in the UK, and whether it should be complemented by a more comprehensive policy framework.
Summary of consultation content and proposals
Key mandate design principles
9. The Government would like to mandate SAF supply in the UK by introducing a bespoke SAF mandate, separate from the RTFO. This is to ensure the scheme does not create complexity and reflects the polluter pays principle. 10. To prioritise carbon emissions savings achieved through SAF over SAF fuel volumes, we propose to implement this scheme as a greenhouse gas (GHG) emissions scheme, i.e. a scheme that awards a number of credits proportional to the kilograms of CO2e saved. Under such a scheme, SAF whose GHG emissions intensity is below the GHG emissions intensity target and meets the proposed eligibility criteria would generate credits. Jet fuel whose GHG emissions intensity is above the target, or SAF that does not meet the proposed eligibility criteria, would incur an obligation. Throughout the obligation period, credits can be sold or bought to meet the obligation.
Ambition and GHG emissions intensity trajectory
11. We would like to introduce a SAF mandate that is world leading and as ambitious as possible. To that end, this consultation sets out a number of potential SAF uptake scenarios, up to 10% SAF by 2030 and up to 75% SAF by 2050, and the associated GHG emissions intensity targets, that might be appropriate under certain market circumstances. We acknowledge high targets will be contingent on multiple technology and policy developments that could unlock a very rapid roll-out of several SAF plants in the short term, the quick commercialisation of SAF technology not yet proven at scale and the certification of new production pathways. To take into account these uncertainties, we welcome views on the right trade-off between ambition and deliverability at this stage.
12. Depending on the mandate levels chosen initially, we also are open to increasing our targets in the future if the market and the technology develop quickly and SAF costs and carbon abatement costs come down significantly. This is why we have proposed review points in 2030, for post-2035 uptake, in 2035 for post-2040 uptake and in 2040, for post-2045 uptake, including beyond 2050.
…
3.8 The Government would like to introduce a SAF mandate which delivers fuels with the highest sustainability credentials. To receive credits under the proposed mandate, SAF will therefore need to adhere to strict sustainability criteria. These will ensure significant GHG emissions savings are delivered and will prevent negative environmental consequences such as the loss of biodiversity, deforestation and the clearance of land with high carbon stock (e.g. dry peatland) that could be associated with the cultivation of raw materials used in certain SAF production.
3.9 While it is advantageous to maximise coherence of sustainability criteria with other schemes and to build on existing criteria (such as those prescribed by the development fuel category of the RTFO), a standalone SAF mandate would require its own set of sustainability criteria to reflect the specificities of the SAF market and to ensure clarity for fuel suppliers
3.10 In this respect, the proposed mandatory sustainability criteria for the SAF mandate are:
- -Fuels must achieve a minimum GHG emissions saving on a lifecycle basis;
- – Fuels must be made from sustainable wastes or residues, RCFs, RFNBOs or nuclear energy (SAF produced from food or feed crops will not be allowed);
- – Waste use must comply with the waste hierarchy29;
- – Feedstocks, including residues, should not be obtained from land with high biodiversity value or land with high carbon stocks in or after January 2008;
- – SAF production must not direct renewable electricity away from existing applications;
- – Where hydrogen is used as a process input, the hydrogen must be low carbon.
3.11 We expect these criteria would allow us to restrict SAF production to feedstock and process inputs that deliver genuine GHG emissions savings, when taking into account their supply chains and direct and indirect sustainability and land use impacts. These criteria would also allow us to convert waste that could have not been recycled or used anywhere else in the economy (e.g. unrecyclable plastics) into a sustainable fuel. We would like to seek views on the proposed sustainability criteria, which are discussed in more detail below.
Feedstock requirements
3.12. It is proposed that only waste-derived biofuels, RFNBOs, SAF from nuclear origin and RCFs can contribute towards the SAF mandate obligation, as these fuels can deliver high carbon savings and do not typically present significant direct or indirect land use or wider environmental impacts. Each of these renewable aviation fuels will play a strategic role in the short- and long-term SAF market and their inclusion is therefore critical for achieving the domestic production potential.
3.13 We are not proposing to extend eligibility to crop-derived biofuels, which could lead to modest GHG emissions savings or, in some instances, to an increase in carbon emissions when taking into account their indirect land use change impact.
…
Biofuels derived from wastes and residues
3.15 A biofuel is a renewable transport fuel that is wholly derived from biomass. The definition of a waste is any substance or object which the holder discards or intends or is required to discard, excluding substances that have been intentionally modified or contaminated for the purpose of transforming them into a waste. The waste and residue feedstocks that are expected to be eligible under the SAF mandate include:
- – ‘ligno-cellulosic material’ – material composed of lignin, cellulose and hemicellulose such as biomass sourced from forests and forest-based industries’ residues and wastes;
- – ‘non-food cellulosic material’ – feedstocks mainly composed of cellulose and hemicellulose, and having a lower lignin content than ligno-cellulosic material; it includes food and feed crop residues (such as straw, stover, husks and shells), industrial residues (including from food and feed crops after vegetal oils, sugars, starches and protein have been extracted), and material from biowaste;
- – ‘residues from agriculture, aquaculture, fisheries or forestry’ – residues that are directly generated by agriculture, aquaculture, fisheries or forestry; they do not include residues from related industries or processing;
- – ‘processing residue’ – in relation to a production process, a substance that is not the end product sought directly from the process, the production of which is not a primary aim of the process, and in respect of which the process has not been deliberately modified in order to produce it;
- – ‘segregated oils and fats’ – a material that is capable of being used as a transport fuel directly, after extraction, or after conversion by transesterification, into a usable fuel; these include waste vegetable oils, fish oils, used cooking oils and animal fats (tallow and greases)30.
How to respond:
Respond online https://www.smartsurvey.co.uk/s/6FZWAX/
or
Complete a response form https://assets.publishing.service.gov.uk/government/uploads/system/uploads/consultation_response_form_data/file/886/saf-download.rtf
and either
Email to:
LowCarbonFuel.Consultation@dft.gov.uk
Write to:
Low Carbon Fuels Team
Department for Transport
Zone 3/32 Great Minster House
33 Horseferry Road
London
SW1P 4DR
.
See earlier:
Jet Zero consultation – what it says on “sustainable aviation fuels” (spoiler…crazy over-optimism)
The DfT’s consultation on reducing aviation carbon emissions, “Jet Zero” places a lot of faith in finding novel, low carbon fuels, so people can continue to fly as much as they want. These are called “Sustainable Aviation Fuels” (SAF). The consultation says SAF “could play a key role in decarbonising aviation, whilst also representing an industrial leadership opportunity for the UK.” The economic opportunity aspect, and producing jobs, is key for the DfT. They say “Many experts view SAF as the only alternative for long-haul flights up to 2050, which are the flights with the biggest climate impact.” The DfT is hoping SAF could “result in over 70% CO2 emissions saving on a lifecycle basis and could deliver net zero emissions with the addition of greenhouse gas removal technologies.” SAF would either be biogenic, non-biogenic (from wastes) or made using zero-carbon electricity. There are huge problems, glossed over by the consultation. A key problem is that “there is currently no comprehensive global regulatory standard for SAF sustainability. The UK is therefore active at ICAO in negotiating for a full set of sustainability criteria for SAF.” The DfT “will shortly consult on a UK SAF mandate setting out our level of ambition for future SAF uptake.”