The UK’s SAF mandate is here – what does it mean for aviation’s decarbonisation?
Last week, the long-awaited UK sustainable aviation fuels (SAF) mandate was published – a document that will help drive the decarbonisation of the sector through the uptake of alternative fuels for the next 15 years. It’s a crucial regulation supporting the UK government's headline Jet Zero Strategy, but is the SAF mandate ambitious enough to drive aviation decarbonisation at the pace required? We think not, and here's why.
What is the SAF mandate?
Put simply, the SAF mandate lays out the minimum amount of sustainable aviation fuels that producers will have to use in any given year from 2025 to 2040 – and the price they will pay for not complying.
With SAFs being more expensive than traditional jet fuel, and for the most sustainable forms at an early stage of development, fuel producers need to be incentivised to produce them. With a mandate guaranteeing demand, we're also more likely to see investor confidence in the industry leading to an uptake in production facilities being developed and an increase in supply.
But as we know, not all 'sustainable' fuels are equal, and the various fuel production pathways that fall under the SAF umbrella vary in production cost, stage of development and – crucially – emission-reduction potential.
That is why the mandate not only includes a headline figure for the amount of SAF in the aviation fuel mix from 2025 onwards, but also the maximum amount which can come from hydroprocessed esters and fatty acids (HEFA) and the minimum amount that must come from so-called 'power-to-liquid' (PtL) fuels. This is because the feedstock used to produce HEFA fuels is currently widely used in other industries for their own decarbonisation (for example, road transport), while PtL fuels – produced using green hydrogen and a source of carbon dioxide – offer far greater potential to lower emissions.
At the moment HEFAs are also far more widely available than PtL fuels and come at a much lower cost. This is why we need to incentivise the use of PtLs over HEFA if we're going to see the production and use of green hydrogen-derived fuels increase in the near future.
How ambitious is the SAF mandate?
Unfortunately, the SAF mandate falls significantly behind the level of ambition needed to drive the use of truly sustainable fuels for the aviation sector. With a headline figure of only 22% 'sustainable' fuels required by 2040, the mandate has fallen short of where it needs to be. It is also lagging behind the EU's ReFuel EU Aviation regulation which mandates 34% of jet fuel by the same year.
While we do see greater ambition in the short term – the SAF mandate will require 10% of jet fuel to be sustainable by 2030 – this overarching figure is not backed up by suitable targets for limiting the use of HEFA fuels nor driving the uptake of PtLs.
Setting a low target for the uptake of PtL fuels (at only 0.5% of the fuel mix in 2030 and rising to just 3.5% in 2040) and high cap for HEFA of 71% in 2030 and 35% in 2040, also represents a huge missed opportunity for innovation and investment in truly sustainable fuels in the UK.
By leaving HEFA on the table for fuel producers, the industry lacks an additional incentive to drive the development the more sustainable PtL fuels. If we're going to be serious about the UK being a hub for the production of green hydrogen-derived fuels, any future SAF mandate revision is going to need to up the level of ambition hugely.
What next for sustainable fuels?
Alongside the SAF mandate, the UK government also published the consultation documents for their incoming revenue certainty mechanism for the production of SAFs. This could be a useful mechanism, but only if done well. We’ll be feeding into the consultation, and calling for the mechanism to be industry funded and targeted at the fuels with the greatest emission reduction potential and at the earliest stage of development – namely power-to-liquid fuels.
It's also important to note that, while the SAF mandate lacks ambition, it is still an improvement to what regulations are in place to decarbonise shipping in the UK. We’re still waiting for the updated Clean Maritime Plan (PDF), and hope to see in it a commitment to introduce an e-fuel mandate for the shipping sector to drive their uptake of sustainable fuels.
Want to hear more about how policy can drive decarbonisation of shipping and aviation in the UK alongside supporting green growth? Join our webinar ‘How decarbonising shipping and aviation will boost UK green growth’ on Tuesday 7th May.
You can also read more about the SASHA Coalition’s vision for decarbonising shipping and aviation through the use of green hydrogen-derived fuels in our regulation roadmaps.
