Benefits from sustainable aviation fuels must not be over-claimed, AEF highlights in response to SAF consultation

21st September, 2021

AEF has responded to the Government’s consultation on Mandating the use of sustainable aviation fuels in the UK which closed on 19th September.

Our key points are set out below. To read our full consultation response, click here.

• We agree that a sustainable aviation fuel (SAF) mandate should be introduced in the UK as long as it delivers genuine emissions mitigation, avoids wider environmental harm, and does not distract from the need for other measures to also be delivered.
• The life cycle analysis (LCA) for any alternative fuels should be based on an assumption that all sectors are on a net-zero-compliant trajectory. Current LCA appears to be based on comparisons with what happens today or what could happen under Business as Usual. In particular, to deliver a future-proof SAF policy, ‘avoided emissions’ (e.g. methane avoidance from the waste sector in the production of waste-based aviation fuels) should not be included in LCA. 
• Fuels generated using captured CO2 and green hydrogen offer a better option in aligning the sector with net zero, but these are not yet available for purchase and will likely be very expensive in comparison to waste-based fuels.
• SAFs emit at least as much CO2 as kerosene, with any greenhouse gas savings made in their production stage. SAFs should therefore be considered as a category of aviation offsets and included in the ‘net’ rather than ‘actual’ trajectory for aviation decarbonisation. 
• A non-CO2 criterion for SAF should also be considered. Latest evidence indicates that aviation’s non-CO2 impacts have caused twice as much warming to date as CO2, although some SAF could potentially reduce the incidence of contrail formation.
• Measures to incentivise SAF uptake, alongside a mandate, include: a meaningful aviation policy framework that includes interim aviation emissions targets prior to IAS inclusion in carbon budgets; policy to tackle non-CO2 emissions; and effective carbon pricing and/or the introduction of a kerosene tax.