A federal clean fuel standard (CFS) for the USA

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Clean fuel standards (CFSs) are regulations which reward or penalise transport fuels based on their lifecycle greenhouse gas emissions — in particular, their emissions with respect to a ‘compliance standard’ which tightens each year. A number of CFSs are already in operation around the world.

Our paper published in the journal Energy Policy examines a hypothetical CFS covering the USA’s road and aviation segments. We model two transport decarbonisation scenarios: one with an emphasis on road electrification, and the other with an emphasis on next-generation liquid fuels and CCS. Both are designed to be consistent with a net-zero-2050 target for the USA’s economy as a whole, with road transport achieving a 87-94% carbon intensity cut and aviation ∼84% (excluding contrails). The electrification-heavy scenario offers faster and deeper emissions cuts, as well as being a significantly cheaper decarbonisation option.

The development and results of these scenarios provide context for considering CFS design issues: the ambition of targets, how to drive investment, and the need for restrictions on certain biofuel feedstocks.

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Staying Aloft: Support Mechanisms for ‘Sustainable Aviation Fuels’ in the United Kingdom and European Union

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The EU’s ReFuelEU Aviation and the UK’s SAF Mandate place requirements on fuel suppliers to bring alternative aviation fuels to market. In parallel, financial support for alternative fuels comes from the EU’s reimbursement scheme, which subsidises some fraction of the cost difference paid by airlines, and the UK’s guaranteed strike price (GSP), which shields SAF producers from variability in market prices.

This report examines the policy frameworks in the two regions and reviews their strengths and weaknesses. It finds that the structure and targeting of their complementary support mechanisms will deliver diverging outcomes. The EU’s reimbursement scheme will benefit airlines and reduce the costs to flyers, but will do little to motivate next-generation fuel producers. In contrast, the UK’s GSP delivers clear reassurance to fuel producers and is more likely to stimulate investment in the industry by facilitating finance availability and reducing the cost of capital.

The report presents illustrative model scenarios and concludes by distilling major challenges and recommendations for the two policy frameworks.

  • The EU’s mandate trajectory and its slightly obscure system of non-compliance penalties could be reviewed, and a joined-up approach adopted for targeting resources towards supporting investment in more sustainable alternative fuels.
  • For the UK, there are some important details to iron out about how price-setting works in the GSP; and a potentially vacillating balance of alternative fuel supply and demand from the EU may pose challenges for compliance and costs.
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Fuelling nature

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How e-fuels can mitigate biodiversity risk in EU aviation and maritime policy

This report, commissioned by Opportunity Green on behalf of the Skies and Seas Hydrogen-fuels Accelerator Coalition (SASHA), explores the biodiversity risks associated with the EU’s efforts to decarbonise aviation and maritime transport. The ReFuelEU Aviation and FuelEU Maritime regulations aim to engender a rapid transition away from fossil fuels and towards alternative fuels; but this raises concerns for nature protection, potentially undermining the EU’s biodiversity commitments under the Biodiversity Strategy for 2030 and the Nature Restoration Regulation. Cerulogy’s report assesses how different fuel pathways – biofuels from crops, residues and waste oils, and synthetic e-fuels – compare in terms of pressure on land, habitats, species, and ecosystems.

Cerulogy modelled alternative fuel demand in the aviation and maritime segments to 2050. We considered four scenarios representing different dominant fuel production technologies: cellulosic residues, cellulosic crops, lipids, and electrofuels. For each scenario, we estimated feedstock and land requirements, and developed a biodiversity risk framework to evaluate land-use change, habitat degradation, species loss, pollution, and agrochemical use. To assess policy coherence, we examined trade-offs and synergies between the EU’s transport decarbonisation goals and its nature and biodiversity policy framework.

Our findings show that, while all fuel pathways carry some environmental risk, electrofuels may represent the lowest overall risk to biodiversity, largely due to their minimal land footprint and reduced pressure on ecosystems, species, and habitats. Even biofuels derived from residues and wastes may have implications for nature when scaled to meet growing fuel demand. The EU’s current approach risks locking in high-impact fuel systems unless it also addresses total energy use in aviation and shipping. Until policymakers are ready to confront demand growth in these hard-to-decarbonise sectors, support for options like electrofuels may be the clearest path for the EU to aligning its climate and biodiversity goals.

Download the report from the SASHA website

Vertical Take-off? Cost Implications and Industrial Development Scenarios for the UK SAF Mandate

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In this paper for the International Council on Clean Transportation we consider the industrial development implications of the targets for alternative aviation fuel supply that are being introduced throught he UK’s SAF Mandate.

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Scrutinising the future role of alternative fuels in delivering aviation decarbonisation

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Alternative fuels have been identified as an important tool to reduce the climate change impact of the aviation industry, but there are many challenges associated with increasing the production and use of these fuels in a sustainable way. In this series of reports for the Aviation Environment Federation we discuss issues relating to the lifecycle analysis of alternative fuels, to the use of wastes and by-products as feedstock for alternative fuels, and to the commercialisation and expansion of an alternative aviation fuel industry.

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A front cover image showing a plane refuelling in front of some Spanish landmarksCerulogy 2022

Aviation biofuels in Spain

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This report for the Spanish NGO Ecologistas en Acción considers the potential for the development of an aviation biofuel industry in Spain. It notes that it may be challenging to reorient existing renewable diesel capacity to aviation fuel production because of the need to find non-food feedstocks if the fuel is to be counted under the EU’s ReFuelEU policy, and that advanced alternative aviation fuel technologies will be needed to deliver long term growth in the sector.

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SAFty in numbers

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As part of the Green Deal, the European Commission has launched the “ReFuelEU Aviation Initiative” to increase the role of “sustainable aviation fuels” in EU aviation. This report for Transport and Environment discusses the potential supply of different SAF categories in 2030, and what might be required to deliver a rapid supply expansion. This includes presenting results from a simple bottom-up SAF production model, and discussing what an ambitious but potentially achievable level might be for a GHG intensity reduction target for 2030 aviation fuel.

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Biofuel to the fire

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In partnership with the Rainforest Foundation Norway, this report reviews the threat to tropical forests from continued expansion of mandates for palm- and soy-oil based biofuels.

RFN webpage
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Destination deforestation

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The aviation industry identifies ‘sustainable aviation fuels’ as a key tool to manage the growing climate impact of aviation. There are, however, fundamental differences between the sustainability risks associated with the scaling up of the different available alternative aviation fuel technologies. At present, the only alternative aviation fuel technology that is operational at commercial scale is ‘HEFA’ (hydroprocessed esters and
fatty acids), which can be produced at renewable diesel facilities. The feedstocks for HEFA production are primarily vegetable oils, and a rapid expansion of demand for HEFA fuels would put considerable pressure on the global vegetable oil market. That can be expected to lead directly or indirectly to increased production of palm and soy oils. Both the oil palm and soybean crop are associated with ongoing tropical deforestation.

In this report for the Rainforest Foundation Norway, we review the potential for growth in palm oil and soy oil demand due to the introduction of ‘sustainable’ aviation fuel support policies. The report shows that delivering stated ambition without actively managing the technologies and feedstocks used could increase vegetable oil demand by tens of millions of tonnes, and details the potential deforestation, peat loss and climate implications of meeting those targets with a significant contribution from palm and soy oils.

While the worst case scenario is that stated aviation targets would be met without managing the feedstock mix, the report also notes that it currently seems likely that most of the targets discussed will be missed entirely. If so, aviation needs to find viable options to manage its climate impact – that may well need to involve management and limitation of demand growth.

Visit the Rainforest Foundation Norway website
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