Sustainable Aviation Fuels consultation
Please find our response to the Sustainable Aviation Fuels consultation which closed on 19th September 2021.
Sustainable Aviation Fuels Mandate Consultation
Response from Stop Heathrow Expansion
September 2021
Introduction and summary
Stop Heathrow Expansion is a group of residents, mainly from the London Borough of Hillingdon, directly affected by proposals for Heathrow expansion, particularly in the areas immediately around the airport. We campaign against expansion at Heathrow Airport, both in the form of additional runways and any increase in flights beyond the current cap of 480,000 ATMs.
We also work to reduce both air and noise pollution from Heathrow Airport and related road traffic, as well as to preserve community life and heritage in the villages near Heathrow, and to end the repeated threats and impacts to the area arising from Heathrow operations. Our group is supported by all local political parties.
We believe that too much faith is being placed in technologies to decarbonise aviation that are either still in their infancy or are yet to be developed.
The development and take-up of Sustainable Aviation Fuels (SAF) must be welcomed, but to reap the benefits they could bring, it is necessary to introduce a mandate. Incentives too often fail to deliver. Our answer seeks to highlight the problems with SAF in the context of the Heathrow expansion proposals.
1) Reducing the carbon intensity of jet fuel
SAF production is currently less than 1% of overall jet fuel supply. In September 2021, a domestic flight using SAF made its first commercial journey between Scotland and London. This development is important, but it is far from being used on other short haul or long haul routes in time for when a proposed third runway would open in the early 2030s.
Current global targets for approximately 50% alternative jet fuel use in 2050 would require over 1,000 bio-jet fuel refineries to be built: more than three per month for the next 30 years. Today, there are just two facilities.
In 2010, the aviation industry pledged to source 10% of fuels from sustainable sources by 2020. Yet by 2018, the industry had managed to source just 0.002% – they seem to be falling well short of their promises.
We are particularly concerned at the lack of an indication as to how much investment the industry, or Government, is willing to commit to enable alternative aviation fuel generation to be scaled up and sold at a price that is competitive with kerosene. Furthermore, it is difficult to make a strong case for public investment in initiatives such as this which benefit one sector when there are several pressing demands for public capital, in the transport area alone, that could more effectively address the decarbonisation challenge.
It is a requirement to get to net zero emissions before 2050 and reduce emissions by 78% by 2035. A carbon intensity reduction is both needed and must be an amount that can be offset in compensation, which is an apparent omission in the consultation.
Further, 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 making alternative fuels are considerable and are not being considered in computations. The “Net Zero” computation must include greenhouse gas emissions from producing the fuels as well as those from the combustion process itself.
2) Fuel Eligibility and sustainability criteria
There is no universal agreement of the term ‘sustainable’ for Sustainable Aviation Fuels (SAF) nor is it clear how emissions in production are accounted for. There is an assumption of benefit from waste being turned into fuel as opposed to being left to rot (thus generating methane), however using jet fuel from waste would still generate similar levels of carbon emissions to kerosene. To achieve net zero both methane and carbon emissions need to be avoided. Zero emissions fuels need to be mandatory.
3) Overarching trajectory
The Government’s plan to expand Heathrow should be reviewed when the results of the recent Jet Zero consultation are published in the coming months.
The SAF mandate should begin as soon as possible, and by no later than December 2022. We believe this is justified given the urgent need for the aviation sector to emit less carbon as part of the fight against the wider climate crisis.
2030 is too late for a SAF-specific review to be undertaken. An initial review should be made by 2025 at the latest, and then annually, to ensure both that the proposed policy framework is still relevant and robust and the aviation industry is delivering as required. If deliverability is not at the required rate, then this will impact other policies such as Heathrow expansion and plans to decarbonise domestic aviation by 2040.
4) Interactions with other policy
Greenhouse gas emission reductions should be claimed only once, and should not be rewarded under the Renewable Transport Fuel Obligation once the mandate is in place. It is necessary to ensure that the Department for Transport’s different SAF policies do not reward the same tonne of CO2 reduction twice. The consultation does not address how to avoid double counting across the rest of the economy. This is crucial given the likely competition for alternative fuels from across industry, manufacturing, and other transport modes.
A GHG emissions scheme, based on tradable credits, simply encourages organisations to avoid carbon reduction processes and fuels by buying their way out of the obligation. The UK must reduce our carbon and greenhouse gas emissions, but trading credits is not the optimal way to achieve this.
5) Delivering SAF
SAF are often described as the primary solution for aviation decarbonisation but this gives a false impression that airports like Heathrow can continue to expand without worrying about the climate impacts. However, SAF might only provide a tiny and expensive solution without significant government investment and intervention in the market. This investment may not be possible or politically welcomed following the recent announcement of tax increases and the significant “hit” these will have on the pockets of ordinary people.
It is important to note that even if airports can “claim” to be carbon neutral, this ignores the flights that use these airports. Consequently, Heathrow is the single largest polluter in the UK, and its emissions account for over half of all UK aviation emissions. It currently emits around 20MtCO2 of carbon annually. A 3rd runway would increase this by approximately 7MtCO2 to 27MtCO2.
Any mandate on SAF must specify industry targets. Deliverability must be measured annually to maintain progress on the implementation of the mandate.
The Government must ensure complete transparency in the use of alternative fuels, their emissions on combustion and production and be willing to enforce demand management policies until such as time that SAF production and use is genuinely sustainable, is regularly used on both short and long-haul flights, is cheaper than kerosene and has met or exceed net zero targets (2035). Until then, policies to add 260,000 extra ATMs per annum or the interim addition of 25,000 ATMs per annum, in the form of Heathrow expansion, must be withdrawn.
The full consultation document can be found here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005382/sustainable-aviation-fuels-mandate-consultation-on-reducing-the-greenhouse-gas-emissions-of-aviation-fuels-in-the-uk.pdf