On 7 March 2022, the Department for Transport published a summary of the responses to its recent consultation on the introduction of a sustainable aviation fuel (SAF) mandate. The summary details replies from 79 respondents, who included airlines, airports, trade associations and fuel producers and suppliers.
Jet Zero consultation
The consultation arose out of a commitment in the Prime Minister's Ten Point Plan for a Green Industrial Revolution announced in 2020. As part of this plan, the Jet Zero Council was established to bring government and industry stakeholders together with a view to delivering UK capabilities for achieving net-zero carbon emissions in the aviation sector.
The Jet Zero consultation proposed a mandate for the supply of SAF in the UK that would sit separately from the existing Renewable Transport Fuel Obligation (RTFO). The suggested scheme would award credits proportional to the amount of carbon emissions saved against a target. Those credits could then be sold to those who have incurred an obligation by using fuel which releases greenhouse gas emissions above the target.
The aim of the consultation was to scope the design of the proposed scheme as well as its ambition and deliverability. Additionally, the consultation requested views from stakeholders on how the mandate would interact with the wider policy and reporting landscapes both in the UK and internationally.
Responses
Most respondents agreed that a SAF mandate should be introduced in the UK, that it should sit outside the RTFO and that the scheme should be based on tradeable credits. The predominant arguments for this were that the mandate would generate demand, align with the UK's decarbonisation goals and incentivise SAF production in a technology-agnostic way. It would also maintain a simple reporting process and avoid passing on SAF-related costs to road users (unlike if the mandate were to be wrapped into the RTFO).
In general, there was agreement with the sustainability criteria proposed and the baseline greenhouse gas emissions intensity below which credits would be issued. However, when asked which of four aviation decarbonisation scenarios, ranging from a continuation of current trends to a "high ambition" forecast, was the best trade-off between ambition and deliverability, most replied "Don't know / other". Of those who provided substantive responses, most selected the most ambitious target arguing that it was the only scenario which would lead to net-zero aviation by 2050 and that a stretch goal builds investor confidence in the UK SAF sector. The second most popular substantive answer was one which the Jet Zero Council SAF Delivery Group had discussed as the most realistic pathway based on production potential.
Next steps
At the outset, the Department for Transport envisaged that the first consultation on a SAF mandate was likely to be followed by a further consultation aimed at addressing, in greater detail, the administering of such a mandate.
On 21 March 2022, the Department issued a further technical consultation which is open for responses until 25 April 2022. The aim of this is to provide an opportunity for stakeholders to consider an updated analysis regarding the four aviation decarbonisation scenarios. As such, responses to both stages of the consultation will be considered in tandem.
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