Sustainable aviation fuels mandate - Summary of consultation responses

The report, published by the Department for Transport (DfT), summarises a total of 79 responses received from a range of organisations concerning the government’s proposal for a UK Sustainable Aviation Fuels (SAF) mandate.

Understanding an appropriate level of ambition for the UK SAF mandate has been a key focus of the Jet Zero Council SAF Delivery Group, Mandate Sub-group (click here to read recent minutes from meetings). Over the course of a year, the group provided input on the proposal which will require jet fuel suppliers to blend an increasing proportion of SAF into aviation fuel from 2025.

The DfT ran the consultation from July to September 2021, to gather insight from a wider range of stakeholders on how best a SAF mandate could be designed and whether it should be complemented by a more comprehensive policy framework (such as a Contracts for Difference (CfD) mechanism).

An overview of responses published in the summary report is outlined below:

1. A greenhouse gas emissions scheme to reduce the carbon intensity of jet fuel

Most respondents agreed that a SAF mandate should be introduced in the UK, with the predominant arguments for the introduction being that it would:

• Generate demand for SAF
• Stimulate the domestic economy
• Deliver emissions savings
• Help increase investor confidence

There were wide variations around the point at which the fuel should be assessed; blending and certification, jet supply terminals and airport were all suggested as viable options, with pros and cons for each.

2. Fuel eligibility and sustainability criteria

The most varied response in this section was around defining eligible feedstocks. It was felt that being too prescriptive may stifle innovation around or restrict the development of new feedstocks.

3. Overarching trajectory

In the consultation, 5 high-level scenarios for SAF uptake in the short- and long-term were presented; 37 out of the 65 participants that answered this question didn’t know which scenario gave the best trade-off between ambition and deliverability. This was believed to be down to too many uncertain factors in the SAF market.

Respondents were fairly evenly divided in their views on the introduction of a HEFA (hydroprocessed esters and fatty acids) cap, though there was broad agreement among all respondents that an excessive reliance on HEFA is detrimental to the environment and feedstock competition for other uses.

4. Interactions with other domestic and international policy

The Government would like to require that any SAF supplied to meet the proposed standalone SAF mandate cannot be claimed under the RTFO (Renewable Transport Fuels Obligation), and vice versa.

The majority of respondents agreed that SAF GHG emissions reductions should be claimed only once under the most relevant scheme. This will prevent double counting of reductions, particularly as this undermines the credibility of climate change policies.

5. Delivering SAF to the market

The consultation welcomed views on what, if any, additional interventions may be needed to provide more certainty for developers and investors considering building plants in the UK. Most respondents agreed that a more comprehensive policy framework beyond a SAF mandate is required to build a successful UK SAF sector, as a SAF mandate is generally not considered sufficient on its own to stimulate domestic production of SAF.

Respondents identified a wide range of commercial and other interventions to be considered when designing a policy framework for SAF including Contracts for Difference, loans and guarantees, grants, tax credits and a UK SAF Clearing House.

6. Scheme practicalities, reporting and verification

It was proposed a reporting requirement on all aviation fuel (SAF and conventional) would need to be introduced so that the obligation on aviation fuel suppliers can be calculated accurately. 82% of respondents suggested that reporting should be carried out annually and there were suggestions about the information that obligated suppliers should report which included lifecycle carbon intensity, SAF origin and feedstocks used.

Read the full Summary of Responses

Responses outlined above are only a small fraction of those received; please click here to read the full summary of responses.

Many of the issues identified and suggestions made during the consultation will be subject to ongoing discussion in the Jet Zero Council SAF Delivery Group with an updated mandate consultation period expected to conclude by the end of 2022.

Innovate UK KTN provides the secretariat for the Jet Zero Council SAF Delivery Group, and you can read the meeting minutes from the Mandate sub-group here.