AEF Responds to Government Consultation on Developing a Sustainable Fuel Mandate

29th June, 2023

AEF recently responded to the Government’s latest consultation on proposals for developing a ‘Sustainable Aviation Fuel’ (SAF) mandate. The consultation asks for views on the appropriate future mandate levels. AEF prefers the term ‘alternative aviation fuel’, since ‘SAF’ has come to be used as a catch-all term for any non-fossil liquid aviation fuel whether or not it can be sustainably produced in a net zero future. 

Our response makes the following key points:

• It is not possible to comment on an appropriate level for a SAF mandate without the necessary evidence about the availability of sustainable feedstocks. This is an issue that the Government says it will need to revisit once it has published its plans on low-carbon fuels and on biomass and which means that the cost-benefit analysis accompanying the aviation fuel proposals varies from strongly positive to strongly negative, with no central estimate. It was a mistake, we argue, for the Government has already committed to a target of 10% ‘SAF’ by 2030 in the absence of this evidence. 
• There is a risk that creating incentives for the wrong fuels could end up increasing emissions at a system-wide level. Each of the potential waste feedstocks identified in the consultation (used cooking oil; tallow; forest residues and municipal solid waste) are likely to be difficult to source sustainably. The wider impacts in terms of the long-term sustainability of sourcing waste feedstocks in a net zero economy are not, as we understand it, reflected in the standard, ‘attributional’ lifecycle analysis that lies behind the carbon intensity values for the feedstocks proposed.
• We support the principle of a Power to Liquid (PtL or e-fuel) sub-mandate, since PtL offers advantages over waste-based fuels, particularly when produced from green hydrogen and CO2 captured from the air. However, risks of a high PtL mandate include reliance on unsustainable feedstocks and diversion of limited supplies of sustainable feedstocks from other sectors.

More broadly, we are concerned about the idea of setting up a ‘Sustainable Aviation Fuel’ policy that uses fuels from unsustainable sources, since doing so creates a market for materials and energy sources that should be rapidly phased out. We also consider there to be a real greenwash risk. 

The aviation industry would like to justify its continued expansion on the basis that it is in the process of a transformation towards ‘taking the carbon out of flying’. If this involves continuing to release CO2 from aircraft by using fuels made not from kerosene but from dead pigs and plastic straws, then environmental organisations are likely to call out these claims as misleading. 

There is an absolute and urgent need to cut atmospheric carbon. Only the very best-performing options for decarbonising aviation should be receiving investment and financial reward in that context.

Our response is available here: