DfT consultation on sustainable aviation fuels mandate

 

A big thank you to those who responded to us with comments, thoughts and encouragement. We have sent our responses to the DfT and they are as follows:

RESPONSES OF THE TEDDINGTON ACTION GROUP

The view of the Teddington Action Group is that alternative or “sustainable” fuels must be properly sustainable, which means that there are genuine net zero emissions from the fuel burn. It is no good tearing down trees to grow crops for fuel creation, since there will be no net emissions savings. The trees which captured carbon will have been destroyed giving no net saving in CO2 emissions. You might as well keep the trees and extract the fossil fuels for combustion. Conversely, extraction of CO2 from the atmosphere to create fuel may assist net zero if the CO2 emissions created in the manufacturing process plus the CO2 and other greenhouse gas emissions of the ultimate combustion process do not exceed the CO2 extracted from the atmosphere (normally by combining the CO2 with hydrogen) in order to make the fuel.

Similarly, extracting fuel from genuine waste, that would otherwise disintegrate and emit CO2 or other greenhouse gases while disintegrating, will be carbon neutral if the CO2 saved through not leaving the waste to disintegrate exceeds the CO2 emitted in the conversion of the waste to fuel together with the CO2 emitted in the subsequent fuel burn. If the CO2 saved does not equal or exceed the CO2 and other greenhouse gases emitted in the fuel burn, then the use quite simply is not carbon neutral.

Hydrogen is a genuine carbon neutral fuel (for combustion at least, although its manufacture may be a different matter) as its residue is oxygen and water. However, there are very significant problems with its usage and manufacture[1].

Electric propelled aircraft may be a possibility but there are very significant environmental problems in the production of lithium batteries, which must be tackled[2].

Our viewpoint contrasts with the government’s “Jet Zero” Council consultation document which states that “Through our strategy, we will commit the UK aviation sector to reaching net zero by 2050 – or Jet Zero”. Closer examination shows though that the Jet Zero Council proposals will be nowhere near net zero emissions. The Analysis shows that even with “High Ambition” as defined by the Jet Zero Council, the uptake of SAFs by 2050 will be just 30% of the total with just a 2.0% per year fuel improvement in aircraft efficiency. This will still give 35,735,870 Mt CO2 per year in 2050 according to the Jet Zero Council dataset. That is almost exactly the same as today’s figure! It is also way above any other carbon capture mechanism that could be dedicated to capturing carbon from aviation and thus bring the emissions to “net zero”.

It is therefore vitally important that Governments are honest about this. Net Zero and its concept will lose all credibility unless we tackle the subject properly and honestly. The human race depends on this. Organisations like the Jet Zero Council should be abolished as only representing vested interests and being frivolous. Even with “High ambition with a breakthrough on zero emission aircraft” as defined by the Jet Zero Council, the annual CO2 emissions would still be 17.4 Mt CO2 and that depends on complete speculation with little or no supporting evidence

 

Q1: Do you agree or disagree that a SAF mandate should be introduced in the UK?

Yes, we agree. We are pleased to see that the definition of SAF will be “only waste-derived biofuels, renewable fuels of non-biological origin (RFNBOs), SAF from nuclear energy and recycled carbon fuels (RCFs)”. It is extremely important that SAFs are not derived from first generation crops including oils such as palm oil. In addition, “waste derived” fuels should be waste from a genuine process and not derived from false or secondary purposes leading to an effective first generation use with the risk of deforestation. Unless concrete is torn up, land growing foodstuffs is likely to absorb the same carbon as land growing crops for fuel, with the consequent zero saving in carbon emissions. We note with concern the Government’s apparent enthusiasm for companies such as Neste Oil, who openly promote on their website HEFA fuels made “from a wide range of oils. The crude palm oil used by the company to produce renewable diesel today is 100% certified and traced back to the plantation where it originally comes from”[3]. That simply will not do and should be banned outright. It is not net zero.

Aviation is one of the major polluters. A figure of 3% of global CO2 is frequently given but this is from a tiny fraction of the global population (less than 11%)[4]. In addition, the secondary greenhouse gas emissions probably triple this. Just 1% of the global population account for half of all CO2 emissions from aircraft[5]. The proportion of global greenhouse gases from aviation is predicted to increase to 25% by 2050 if unchecked and this will be caused by some 10% of the population. The industry simply must restrain itself.

 

Q2: Do you agree or disagree that an obligation to supply SAF in the UK should sit outside the RTFO?

Yes, we agree. The Renewable Transport Fuel Obligation (RTFO) is currently not ambitious enough and in any case includes blending fossil fuels with bioethanol, biomethanol or biodiesel – derived from sources such as palm oil, oilseed rape, cereals, sugar cane, sugar beet, and reprocessed vegetable oil. Again, these are (or at least may well be) first generation, which the consultation says the Government will not use. Secondly some of the fuels will not be suitable for aviation. Bioethanol has a combustion temperature that is low enough to be unsafe to be used in a commercial airliner. Conversely, biodiesel has a freezing temperature that is too high so will turn to jelly at high altitude and will also be unsuitable for aircraft. Much research still needs to be done on the work required to make such biofuels safe and efficient[6].

Specific types of fuel will be needed for aircraft to be both safe and retain liquidity at the low temperatures existing at high altitude. In addition, the volumes of fuel needed will necessitate special monitoring of these fuels[7].

 

Q3: Do you agree or disagree that a GHG emissions scheme based on tradable credits should be preferable to a fuel volume scheme when designing a SAF mandate?

No. Transferrable credits simply encourage organisations to avoid carbon reduction processes and fuels by buying their way out of the obligation. We have simply got to reduce our carbon and greenhouse gas emissions – not trade our way into oblivion

 

Q4: Do you agree or disagree that the proposed SAF mandate obligation should be placed on fuel suppliers that supply aviation fuel (avtur) to the UK?

Agree.

 

Q5: Should the obligation apply to all avtur supplied into the UK, regardless of whether this is subject to fuel duty or not?

Yes.

 

Q6: If the obligation applies to all avtur supplied into the UK, should there be a threshold below which fuel is not obligated, in a certain obligated period? Should this threshold distinguish between dutiable and non-dutiable fuel?

No. If we do this, we will not sufficiently tackle the problem. The likelihood is that the traditional jet engine may well have had its day and the industry will have to find alternative non-CO2 producing propulsion for the future. Providing exemption or thresholds will not help this

 

Q7: Where do you think the assessment point should be placed for jet fuel not subject to fuel duty, and how is this going to affect the definition of the proposed obligated party (aviation fuel suppliers to the UK)?

Nil – all jet fuel should be subject without exception.

 

Q8: Do you agree or disagree that only certified SAF that meets the DEF STAN 91-091 specification should be eligible under the proposed SAF mandate?

Disagree. The crucial point is whether the sustainable fuel is sustainable. If it is then it should be admitted. It will be for the industry to find ways of making it satisfactory or not using it. For example, at present hydrogen is completely unsuitable as an aviation fuel even though it is a good sustainable fuel. However, hydrogen might be made acceptable if cooling and pressurisation can be made safe and/or acceptable to ordinary operations. The making or separation of hydrogen must also be considered, and only “green” hydrogen is likely to be acceptable. “Blue” hydrogen is unlikely to be acceptable because of the risks of carbon storage and the high amount of CO2 emissions in the making of it.

 

Q9: Do you agree or disagree with the sustainability criteria set out here? If you do not agree, what alternative or additional criteria would you recommend?

Disagree. We are pleased that you “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”. However, you have not specified any safeguards for fictitious or spurious first uses.

Thus, you say that “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.” That exclusion, with respect, will not prevent a substance like palm oil being used for some insignificant or unnecessary purpose with the intention of becoming “waste”. There may be insignificant primary usage giving a technical change which the oil companies and aviation industry will argue is not an “intentional modification”. The commercial pressure to do this will be enormous since there is unlikely to be sufficient non-fossil fuels either from biofuels as you have defined them, or fully synthetic fuels made from extracting CO2 from the atmosphere

 

Q10: Do you agree or disagree with the feedstocks set out here and listed in Annex B? If you do not agree, what alternative or additional feedstock(s) would you recommend?

Agree to some but others profoundly disagree. Any waste that could be first generation and used for other uses should be forbidden. Therefore, all primary food uses should be excluded from eligibility. Also, scrubland should be excluded since waste land will act as a carbon capture and growing stuff for fuel use will not save CO2. Items that you have listed as eligible but should be forbidden are:

Bracken – open to abuse and “cutting to reduce fire risk” could be open to abuse. Bracken is a carbon capture mechanism

Cashew nut liquid – open to abuse and use of the food stuff

Empty palm fruit bunches – open to abuse and would assist deforestation

Rapeseed residue – open to abuse and may intrude into the food chain

Sugar beet residue and tops, tails, chips – open to abuse and may intrude into the food chain.

Used cooking oil unless there is a very strict, transparent process open to independent random inspection  to verify that the first “use” is genuine, and the fuel making process is not intruding into the food  or other chains. The food chain and other uses like lubrication oil or other fuels will not save on CO2 emissions since these wastes would have been used in any case.

Ditto with waste pressings from vegetable oils

Waste wood – this is open to abuse and the waste is likely to be used for other purposes such as heating or horticulture

Bagasse – open to abuse and excessive use of sugar cane pulp may intrude into the food chain. Safeguards are needed to ensure that the pulp is derived from genuine waste.

Straw – while an agricultural waste, it has plenty of other uses like animal bedding. There is little surplus straw and the last thing society needs is competition in the animal feedstuff and bedding sector from wealthy aviation fuel suppliers

Water – use of water is in direct competition with survival of life. Water is in short enough supply already and water from storms drains away and evaporates with extreme heat.

 

It is notable that no details or calculations have been given on what anticipated yields each of the Appendix B listed eligible feedstocks would give towards the annual quantity of fuels suitable for aviation. We suspect that the proportion will be small and therefore the pressure to increase yields by unauthorised means or intrude into unauthorised feedstocks will be huge. The risk of abuse is substantial and should not be underestimated

 

 

Q11: Do you agree or disagree that the baseline lifecycle GHG emissions intensity for aviation fuels for reporting purposes under a UK SAF mandate should be 89 gCO2e/MJ? If you do not agree, what should the baseline emission be and/or how should it be calculated?

Not qualified to answer

 

Q12: What should the minimum carbon intensity reduction SAF will need to meet be (subject to the final GHG methodology used)?

This whole discussion is a distraction. The clear requirement is to get to net zero before 2050. We therefore need a carbon intensity reduction to be an amount that can be offset in compensation – and the consultation paper is notably silent on that. In short, the carbon intensity reduction has to be 100% unless appropriate offsetting provisions are made. It is back to the drawing board for this. The idea of “drop-in” fuels being used is likely to be a major distraction. In many cases the CO2 or greenhouse gas emissions in the making process of some alternative fuels are considerable and are not being considered in computations. The “Net Zero” computation must include the greenhouse gas emissions incurred in making the fuels as well as the combustion process itself. It may well be that the jet engine is now obsolete in the same way the piston engine was post World War II

 

Q13: Are there any land use (direct or indirect) or other implications associated with the feedstocks set out earlier that we should reflect in the eligibility criteria and minimum GHG emissions threshold?

Yes, there are. Almost all the proposals for use of waste materials for making alternative fuels could have very serious impacts upon both feedstuffs and animal habitats for the reasons already stated – essentially that the supply of alternative fuels will be insufficient to meet demand and the cost will be much higher than traditional fuels. Both will lead to pressure to direct first generation crop production away from food with deforestation into the alternative fuel sector. That way we are likely to be in a worse situation than we are now.

 

Q14: As more CCUS becomes available and the GHG emissions intensity of fuels can decrease further, should the envisaged minimum GHG emissions intensity threshold be raised up over time?

In short “No”. However, this may depend on how successful carbon capture, utilisation and storage is. We do not know this yet, so it is impossible to make decisions on it. We do know that climate change with the resulting wild forest fires and flooding have a devastating rate of destruction of carbon capture and storage facilities. Much (if not all) CCUS could be rendered useless necessitating a genuine zero emissions transport structure

 

Q15: What GHG methodology should be used to calculate the carbon intensity of fuel?

Not qualified to answer this

 

 

Q16: How should the GHG methodology vary to take into consideration the different fuels, feedstocks, power sources and production pathways?

It shouldn’t, since the requirement is to get to zero emissions

 

Q17: Do you agree or disagree that SAF that does not meet the proposed eligibility and sustainability criteria should incur an obligation?

Yes, but not sure that the criteria or the supervision of compliance with the criteria are correct. If fuels do not meet eligibility criteria then the starting point should be that they should not be used and mandated sustainable fuels only should be used.

 

Q18: Do you agree or disagree that a SAF mandate should start in 2025?

Yes

 

Q19: Do you agree or disagree that the targets should assume a linear growth up to 2035 and an exponential growth after 2035?

Yes, but obviously it will depend on the rate of growth

 

Q20: What scenario do you think represents the best trade-off between ambition and deliverability? What evidence can you provide to support your position?

Not qualified to answer

 

Q21: Do you agree or disagree that we should include review points in 2030, 2035 and 2040, depending on initial mandate levels?

Yes

 

Q22: Should the amount of HEFA that can be claimed under the SAF mandate be capped over time? If this is the case, how could the cap work in practice, given the scheme will be based on GHG emissions savings? How should the cap be calculated?

Yes. HEFA will not be an acceptable alternative fuel for very long. Firstly the fuels may contain palm or other oil obtained from first generation cultivation thus risking deforestation and will take the place of other CO2 absorbing crops, so offer little or no CO2 reduction. Also, the fuels emit CO2 on combustion, and there is CO2 produced in the manufacturing process. We will need a true zero emissions fuel or genuine and reliable capture and storage. HEFA is also vulnerable to intrusion into the feedstock process (see above)

 

Q23: How can the innovation and roll-out of power-to-liquid fuels be accelerated? Should a sub-target and/or a multiplier be introduced?

Not qualified to answer

 

Q24: How can SAF produced through pathways other than HEFA and power-to-liquid be accelerated?

Not qualified to answer

 

Q25: Do you agree or disagree that SAF GHG emissions reductions should be claimed only once under different schemes?

Yes – otherwise the calculations are not correct!

 

Q26: How could the UK ETS, CORSIA and proposed SAF mandate be used together to continue to incentivise uptake, while preventing double counting of emissions reductions?

Compulsion. Nothing less will do since the industry has shown itself to be wholly incapable of tackling the problem

 

Q27: Do you agree or disagree that SAF that has been produced on the back of industrial plants or clusters which have received competition funding from government can be claimed under the proposed UK SAF mandate?

Not qualified to answer

 

Q28: Do you agree or disagree that SAF should no longer be rewarded under the RTFO when and if a SAF mandate is in place?

Yes. Zero emissions fuels need to be mandatory

 

Q29: What provisions should the UK SAF mandate include to reduce the risk of tankering even further?

Not qualified to answer but it is up to the Government to develop a scheme where there are genuine carbon emissions reductions. You have been told through the IPCC and Committee on Climate Change what is required.

 

Q30: Do you consider a more comprehensive policy framework beyond a SAF mandate is required to build a successful UK SAF sector?

Not qualified to answer this

 

Q31: If you believe this is the case, how can this policy framework be designed?

Please provide any evidence you may have available to support your answers.

Not qualified to answer this

 

Q32: Should buy-out be allowed? If so, how should the buy-out price set to encourage actual supply of SAF and delivery of GHG emissions savings? How should the buy-out evolve over time?

No; buy-outs should not be allowed. The industry must organise itself to cater for this crisis. There should be no way for emitters to “buy out” of the obligation otherwise the targets will not be met. The industry must understand that it either complies with the targets or it cannot operate. It is that serious and the professional advice on this is clear

 

Q33: What penalties should be introduced in addition/alternatively to a buy-out to ensure sustainable SAF, that meets the proposed criteria, is supplied?

Not qualified to answer this but it seems to us that burning fossil fuels or alternative fuels that are not genuinely net zero should be prohibited and a breach should be a criminal offence with serious financial penalties

 

Q34: Do you agree or disagree that a mass balance approach should be the only chain of custody system permitted under the proposed SAF mandate?

Not qualified to answer

 

Q35: Where do you think the chain of custody will need to end? Please refer to any evidence to support your position.

Not qualified to answer

 

Q36: Do you agree or disagree that obligated suppliers will need to report annually information on the aviation fuel supplied to the Department for Transport, regardless of whether they claim SAF credits?

Not qualified to answer

 

Q37: Do you have views on what information obligated fuel suppliers should report?

Not qualified to answer

 

Q38: Do you have views on the reporting calendar?

Not qualified to answer

 

Q39: Do you have views on what the timescale for submitting claims and the information/evidence required by this process should be?

Not qualified to answer

 

Q40: Should certification provided by voluntary schemes count as evidence of compliance with the sustainability criteria of the SAF mandate? If so, do you think this step should or should not be mandatory?

Not qualified to answer

 

Q41: What information should the obligated party provide, either through verifiers or other means, to demonstrate compliance with the sustainability criteria?

Not qualified to answer

 

Q42: Do you agree or disagree that claims for credits under the SAF mandate should be verified? If so, should these be verified to a ‘limited’ or ‘reasonable’ assurance?

Not qualified to answer other than the giving of “credits” and allowing “buy-outs” allows people to circumnavigate the requirements which is the very thing that the IPCC and Committee on Climate Change say should not happen

 

Q43: What data related to the SAF mandate should DfT make publicly available? How often should this information be published?

There should be regular updates and complete transparency in the use of alternative fuels, their emissions on combustion and production

 

 

[1] See for example an article “The hydrogen revolution in the skies” in BBC Future at https://www.bbc.com/future/article/20210401-the-worlds-first-commercial-hydrogen-plane

[2] See for example the Institute of Energy Research “The Environmental Impact of Lithium Batteries” 12th November, 2020 at https://www.instituteforenergyresearch.org/renewable/the-environmental-impact-of-lithium-batteries/

[3] https://www.neste.com/certifying-new-feedstocks-will-now-be-faster

[4] Stefan Gössling professor of Tourism Research at Linnaeus University and Human Ecology at Lund University   http://lnu.diva-portal.org/smash/record.jsf?pid=diva2%3A1520254&dswid=-9226

[5] https://www.theguardian.com/business/2020/nov/17/people-cause-global-aviation-emissions-study-covid-19

[6] See e.g. presentation of Imperial College at https://www.imperial.ac.uk/media/imperial-college/grantham-institute/public/publications/briefing-papers/BP-23-Aviation-Biofuels.pdf

[7] See reference above in footnote 6

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