# LongBench v2 / 66efaf70821e116aacb234bd

task_id: 9bfc9793-0355-5df0-a0b9-34fc4e60e13b
task_key: train--66efaf70821e116aacb234bd
task_revision_id: 3

{"choice_A":"Officially launch a SAF technology R&D center led by the University of Sheffield's Energy Institute, funded by the UK government.","choice_B":"The UK's leading airline, Jet2, has made an equity investment in the planned SAF production facility in North West England.","choice_C":"In the future, the UK will regulate the blending ratio of electro-synthetic (PtL) SAF in aviation fuel.","choice_D":"The UK government stipulates that SAF produced from the hydroprocessed esters and fatty acids (HEFA) route can be used to meet all SAF demand.","context":"Contents \nForeword from the Secretary of State for Transport: We are committed to using \nsustainable aviation fuel to decarbonise aviation \n6 \nExecutive summary \n8 \nOur vision \n8 \nTargets, buy-out prices, and review points \n9 \nEligible fuels and sustainability criteria \n11 \nMeeting the obligation with tradeable certificates \n11 \nAdministering the scheme \n12 \nEnforcement \n12 \nInteractions with other domestic and international policy \n12 \nThe SAF Mandate in numbers \n13 \nIntroduction \n14 \nSAF is a key part of the UK’s aviation decarbonisation strategy \n14 \nSupporting the development, production and use of SAF in the UK \n17 \nUpdates since the consultation \n17 \nCreating secure and growing demand through the SAF Mandate \n18 \nNext steps \n19 \nResponses received \n20 \n1. Targets and price support for SAF \n21 \n2025 target and trajectory to 2030 \n21 \nSetting increasing targets into the future \n24 \nHEFA cap \n30 \nPower-to-liquid (PtL) obligation \n38 \nFinal policy parameters \n43 \n\n\n \n \n \n \n \n \n \n \nBuy-out price \n44 \nMandate review points \n49 \n2. Eligible fuels and sustainability criteria \n53 \nEligible fuel types and definitions \n53 \nDefinitions of fuels \n56 \nLow carbon energy criteria \n62 \nUse of hydrogen in SAF production \n66 \nSustainability criteria \n71 \nMinimum GHG savings threshold \n71 \nGHG emissions calculation methodology \n75 \nOther emissions \n80 \n3. Involved parties \n82 \nThe Administrator \n82 \nObligated parties and obligated fuel \n85 \nEnd point of chain of custody \n89 \nThreshold amount below which fuel is not obligated \n91 \n4. Calculating the obligations and certificate reward \n94 \nObligation period \n94 \nSuppliers’ obligations will be determined according to the amount of energy supplied \nthrough aviation fuel \n96 \nCalculation of certificates \n98 \nDischarge of obligation \n106 \n5. Submitting claims, reporting the required data, and fulfilling the SAF obligation \n112 \nRequirement for each obligated party to have an account \n112 \nSubmitting claims for SAF certificates \n113 \nCarbon and sustainability information \n115 \nValidating fuel amount information \n118 \nTransfer of certificates \n120 \nIntroducing flexibility in fulfilling obligation \n121 \n6. Interactions with other policies and airline operations \n125 \nClaiming support for SAF across multiple schemes \n125 \nTankering \n127 \n7. Enforcement \n130 \nRevocation of certificates \n130 \n\n\n \n \n \n \n \n \n \n \nCivil penalties \n132 \nGlossary \n136 \n \n \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n6 \n \n \nThis Government is committed to delivering net zero and will support the technology that \nwill tackle climate change while avoiding putting burdens on working people. \nReducing transport emissions has been important to the UK’s achievement of halving its \nemissions between 1990 and 20221, the first major economy to do so. But I recognise that \nmore needs to be done to decarbonise hard to abate sectors like aviation. In 2022, we \npublished our Jet Zero Strategy, setting out how the UK will achieve net zero emissions from \naviation by 2050. The Jet Zero Strategy identifies sustainable aviation fuel (SAF) as one of \nthe key technologies required to reach net zero: it achieves a 70% greenhouse gas emission \n(GHG) saving, on average, when replacing fossil kerosene.  \nIn July 2022, the government announced it would introduce a SAF Mandate from 2025, \nrequiring at least 10% of UK aviation fuel to be from sustainable sources by 2030. The \n \n1 https://assets.publishing.service.gov.uk/media/65c0d15863a23d0013c821e9/2022-final-greenhouse-gas-\nemissions-statistical-release.pdf  \nForeword from the Secretary of State for \nTransport: We are committed to using \nsustainable aviation fuel to decarbonise \naviation  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n7 \nMandate will drive UK demand for SAF, securing carbon savings and providing investor \nconfidence. The final SAF Mandate scheme represents one of the most ambitious \nframeworks to drive SAF demand in the world, delivering a reduction in UK aviation carbon \nemissions of 2.7 MtCO2e in 2030 and 6.3 MtCO2e in 2040. The Mandate will incentivise the \nproduction of SAF in the UK, and we are now consulting on a complementary Revenue \nCertainty Mechanism, as committed to in the 2023 Energy Act.  \nThe Mandate is adopting world-leading sustainability standards and incentivises production \nfrom wastes and advanced SAF which avoid issues including deforestation, reduction in \nbiodiversity and competition with food production. We will support SAF production that \nharnesses feedstocks including black bin bag waste, carbon captured from the air and from \nindustrial processes, and agriculture and forestry wastes. SAF produced from crops is not \ncurrently eligible for support under the scheme.  \nWe have seen major progress in the global transition to SAF. In November 2023, the UK \ntook a leading role at the International Civil Aviation Organisation’s Third Conference on \nAviation Alternative Fuels (CAAF/3), securing a global agreement to reduce emissions from \naviation fuel by 5% by 2030. This is a major step forward, but we recognise that we must go \nfurther.  \nThe aviation sector’s speed of progress continues to amaze. I was proud to be on board the \nfirst transatlantic flight on a commercial airliner powered completely by SAF in November \n2023, operated by Virgin Atlantic. The flight which resulted from a UK government \ncompetition was testament to what can be achieved when government and industry come \ntogether to push the boundaries of what is possible. It demonstrated that SAF can be used \ntoday to reduce emissions, proving that a sustainable future for aviation lies within our grasp. \n \nI am committed to supporting the industry and making sure that together we can both \ndecarbonise transport and enable passengers to keep flying when and where they want. \nThere are those that think you should deal with sustainability by reducing people’s ability to \nfly – that is not the view of this government. As we demonstrate through our Jet Zero \nStrategy, we can achieve net zero by focussing on new fuels and technologies, and SAF is \nthe most immediate solution we have for cutting emissions.  \nThank you to the Jet Zero Council and the many other voices from the public, industry, civil \nsociety, and academia who have supported the development of the Mandate by providing \nevidence and feedback. \nRt Hon Mark Harper MP  \nSecretary of State for Transport \n \n \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n8 \nOur vision \nThe 2021 Net Zero Strategy set the country on an ambitious path to net zero by 2050. In the \nsame year, the Transport Decarbonisation Plan set out how the government intends to \ndecarbonise the transport sector, the largest greenhouse gas (GHG) emitting sector. In 2022, \nthe Jet Zero Strategy, set out our plan for achieving net zero aviation by 2050. It was a \nproduct of close collaboration between government and industry focussed on rapid \ndevelopment of technologies, maintaining the benefits of air travel and seizing the \nopportunities that decarbonisation provides the UK. The strategy identified six key measures \nto achieve net zero, of which SAF is one.  \nThe government’s vision is for the UK to be a global leader in the development, production \nand use of SAF. The UK’s SAF programme is already one of the most comprehensive in the \nworld. In the 2023 consultation on the SAF Mandate, we set out the three pillars of our SAF \nprogramme;  \n1. drive demand for SAF in the UK; \n2. kickstart a UK SAF industry; and \n3. work in partnership with industry and investors to build long term supply. \nThe Mandate will help realise this vision and support our SAF programme by providing a \nlong-term incentive to supply SAF through a guaranteed level of demand. It will also provide \nan incentive and clear signal to investors to develop SAF production facilities and more \nadvanced SAF technologies in the UK and globally. \nThe primary objective of the Mandate is to deliver GHG emissions reductions contributing \nto our 2050 net zero target and in line with the 2022 Jet Zero Strategy. The policy set out in \nthis document is forecast to reduce aviation emissions by 2.7 MtCO2e2 in 2030 and 6.3 \nMtCO2e in 20403. \n \n2 Carbon dioxide equivalent (CO2e) is a measurement of the total amount of greenhouse gas emissions \nexpressed in terms of the equivalent measurement of carbon dioxide. \n3 Under international GHG inventory guidelines and GHG accounting rules consistent with whole economy \nreporting on net zero, SAF is reported as delivering 100% direct CO2e emissions savings for the aviation \n \nExecutive summary \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n9 \nThe Mandate will also bring broader benefits alongside the reduction of GHG emissions. It \ncreates an opportunity for a new UK industry that can provide green growth and jobs. It is \nalso an opportunity to highlight the UK’s ambition through the setting of targets and through \nproviding support to those novel SAF production methods with the greatest potential to \nreduce emissions.  \nThis document sets out how the mandate will deliver this vision and objectives through the \ndesign of its key parameters. In setting the parameters, we have aimed to set an ambitious \nframework that sets clear signals to drive investment but also reflects the realities of the \ncurrent state of the market. This includes balancing competing objectives such as the need \nto decarbonise the aviation sector – in a way that does not cause adverse cost or \ncompetitiveness implications for the aviation industry – as well as other sectors, such as the \nroad fuels market. \nThe SAF Mandate will deliver carbon savings by setting annual targets on fuel suppliers to \nblend in a proportion of SAF into their fuel supply. It will operate as a tradeable certificate \nscheme where the supply of SAF is rewarded in proportion to its GHG emissions reductions. \nThese certificates can be used to discharge a supplier’s obligation or be sold to other \nsuppliers. In order to be eligible for certificates, SAF must meet strict sustainability criteria, \nincluding that it must be a residual (i.e. non-recyclable) waste or residue derived biofuel, \nrecycled carbon fuel (RCF), low carbon hydrogen or power to liquid (PtL) fuel. We confirm \neach of these design elements in more detail below.  \nTargets, buy-out prices, and review points  \nWe are now building on our previous commitment to achieve at least 10% SAF in the UK \naviation fuel mix by 2030 by setting targets for 15 years, that is, from 2025 to 2040. This will \nprovide certainty to SAF producers and investors and demonstrates the UK’s world-leading \ncommitment to SAF uptake.  \nWe have set ambitious but deliverable targets. In 2025, the overall SAF trajectory will be set \nat 2% of the total fossil jet fuel supplied, which is approximately equal to 230,000 tonnes of \nSAF. This will increase annually to 10% in 2030 and 22% in 2040. These targets ensure \nalignment with the trajectory for SAF set out in the high ambition scenario in the Jet Zero \nStrategy.  \nA successful and resilient SAF industry will need a range of technologies and feedstocks to \nmeet increasing demand. We will therefore create space for more advanced fuels by setting \na cap on hydroprocessed esters and fatty acids (HEFA)4 that becomes more stringent over \ntime, starting at allowing HEFA to contribute a maximum amount (100%) of SAF demand in \n2025 and 2026, decreasing to 71% in 2030 and 35% in 2040. \nWe recognise that HEFA will play an important role in the global SAF sector and in the UK \ngiven it is the only SAF commercially available right now. We welcome the current \ninvestments that have been made here in the UK to produce HEFA SAF and have \n \nsector. The emissions associated with the production of the SAF are captured in other sectors.  Here, as in \nthe Jet Zero Strategy, we have presented the life cycle emission savings delivered by SAF in absolute \ntonnes of CO2e assuming SAF achieves 70% reduction in emissions relative to fossil kerosene on average. \n4 The cap will be placed on SAF production using segregated oils and fats as a feedstock, rather than the \nHEFA production pathway. Please see question 19 for further information.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n10 \nprovided support to this SAF under the Renewable Transport Fuel Obligation (RTFO). We \ncannot rely on this technology alone given the feedstocks they use are finite but welcome \nthe continued development of this industry in the UK alongside the more advanced \ntechnologies. There is no cap on the amount of HEFA that can be produced in the UK and \nthe HEFA cap on suppliers seeking support under the Mandate will still allow around one \nmillion tonnes of HEFA derived SAF to be supplied in the UK each year from 2035.   \nIn recognition of the need to accelerate the development of power-to liquid fuels, which have \nreduced risk of feedstock competition and other negative environmental impacts, a power-\nto-liquid (PtL) obligation will be introduced from 2028 at 0.2% of total jet fuel demand. This \nwill reach 3.5% of total jet fuel demand in 2040; should market conditions allow, we will seek \nto increase this level when the policy is reviewed.  \nA buy-out mechanism will be included for both the main obligation and the PtL obligation, \nwhich will provide a method of compliance where suppliers are unable to secure a supply of \nSAF. The buy-out prices will be set at the equivalent of £4.70 and £5.00 per litre for the main \nand PtL obligations, respectively. These buy-out prices represent a significant incentive to \nsupply SAF into the UK market. They are set at a level to encourage the supply of SAF over \nthe use of the buy-out and sets a maximum cost for the scheme, thereby delivering GHG \nemissions reductions at an acceptable cost. \nWe recognise SAF may be more expensive than traditional jet fuel, and that any costs of \ndecarbonising should be borne by those who produce the emissions. We do not, however, \nexpect this to have a large impact on costs for airline passengers. Providing sufficient SAF \nis available, increases in average air fares will fall within the range of annual variations in \naverage air fares seen historically.  \n   \nIn a scenario where there is a shortage of available SAF leading to significant unexpected \nincreases in its price, and potential buyout, there could theoretically be more significant \nincreases in consumer costs. In order to prevent this, the government would immediately \nreview the Mandate. Government could alter key parameters to ensure price rises do not \nhappen, and consumers are not adversely affected. The final position on the Mandate set \nout in this document is specifically designed to drive decarbonisation at an acceptable cost.   \n \nWe will monitor developments in SAF technologies and feedstocks and, noting \ndevelopments in the EU, keep under review whether we need to broaden the list of eligible \nfuel types and feedstocks.  As electrification scales up in the road transport sector more \nfeedstocks will be available that could be used for SAF. Building on the forthcoming LCF \nStrategy we will consider the role they might play in SAF. Given the potential benefits, we \nwill shortly consult on the use of cover crops, taking into consideration competing demand \nacross other sectors and food production, environmental and economic impacts.   \n \nTo ensure the design of the SAF Mandate reflects the latest technological and commercial \ndevelopments of SAF, there will be continuous monitoring of trends and formal reviews \nconducted and published at least every five years, with the first review carried out by 2030. \nReviews will take into account the need to continue to align with wider government policy \nand strategies including the Net Zero Strategy, Jet Zero Strategy and the Biomass Strategy. \nThey will be an opportunity to keep pace should the market to develop quicker than expected. \nAny proposed changes will be subject to consultation and will consider implications for the \nRTFO, given the desire from stakeholders to maintain consistent rules on sustainability, fuel \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n11 \neligibility and how the schemes operate. We will continue to use the Jet Zero Council forum \nfor stakeholder engagement, feedback and discussion.  \n \nEligible fuels and sustainability criteria \nThe government has always been clear that the SAF Mandate must deliver fuels with the \nhighest sustainability credentials. We are therefore imposing strict sustainability criteria that \nSAF must meet in order to be eligible under the Mandate: \n \n• SAF must be made from sustainable, non-recyclable wastes or residues (e.g. used \ncooking oil or forestry residues), recycled carbon fuels (RCFs) (e.g. unrecyclable \nplastics), PtL fuels made using low carbon (renewable or nuclear) electricity. SAF \nproduced from food, feed or energy crops is not currently eligible for support under \nthe scheme. We will monitor developments in SAF technologies and feedstocks and \nkeep under review broadening the list of eligible fuel types and feedstocks, for \nexample, to include sustainable crops and cover crops; \n• SAF must meet the relevant technical specification (e.g. Jet A1) for aviation turbine \nfuel (avtur), aviation gasoline (avgas) or hydrogen; \n• SAF must achieve a minimum GHG emissions reductions of 40% with our intention \nto increase this minimum threshold in future years of the Mandate; \n• PtL fuels will be subject to additionality criteria for energy use to ensure they deliver \ngenuine GHG emissions reductions; \n• where hydrogen is used as a fuel precursor or is the final fuel, it must be biohydrogen \nderived from residual wastes or residues, RCF hydrogen or hydrogen derived from \nlow carbon (renewable or nuclear) energy; and \n• hydrogen used in hydroprocessing will be considered a process input and will not be \nsubject to the hydrogen eligibility criteria - its use must, however, be accounted for in \nthe carbon emissions of the final fuel. \nMeeting the obligation with tradeable certificates \nCertificates will be issued to jet fuel suppliers for the supply of SAF in proportion to GHG \nemissions reductions delivered. This will therefore provide greater support for SAF with the \nbest GHG emissions reductions and act as an incentive to invest in low carbon processes \nand technologies. The SAF mandate will include a certificate trading scheme to ensure it \ncan be met cost effectively. \nAny fossil avtur or SAF that does not meet the technical and sustainability standards of the \nUK aviation market will incur two obligations – the main obligation and the PtL obligation – \ndetermined on the basis of energy supplied. At the end of each annual obligation period, \neach individual supplier will be required to discharge their obligation by redeeming \ncertificates equivalent to the amount of SAF needed to meet their obligation (or target). \nThere will be three types of certificates – PtL certificates, standard certificates and HEFA \ncertificates – to identify which fuels are eligible for the obligations or subject to the HEFA \ncap. This means that those suppliers that invest in SAF and supply beyond their obligation \nlevel can sell their excess certificates to those that have a shortfall. \nFurther details how the obligation is determined and how the supply of SAF will be rewarded \nis found in Section 4. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n12 \nAdministering the scheme \nIt is very important that the SAF Mandate is administered in a manner that is consistent and \nstraightforward to fuel suppliers. Therefore, the administration of the Mandate will align with \nthe RTFO where possible given fuel suppliers are also subject to obligations to supply low \ncarbon fuels under that scheme. This includes appointing the Secretary of State as the \nAdministrator, with responsibility delegated to a Department for Transport (DfT) \nadministration unit. Other design features that follow current practice under the RTFO \ninclude operating the same obligation period, following the same process for reporting \ninformation and submitting claims for certificates and allowing certificates to fulfil up to 25% \nof an obligation in the following year. \nEnforcement \nAchieving reductions in GHG emissions through the Mandate is dependent on the \ngovernment’s ability to robustly enforce it; however, this must be implemented in a fair and \ntransparent manner.  \nTo ensure all relevant parties are compliant with the requirements of the Mandate and that \nthe system is not undermined, the Administrator will have the right to apply proportionate \nsanctions. The department has a long history of working with obligated parties and carrying \nout compliance checks to ensure that any problems are addressed before further \nenforcement is required. However, if necessary, the Administrator will revoke certificates or \nissue civil penalties. \nInteractions with other domestic and international policy \nIt is critical that the Mandate operates effectively alongside existing and future policy. To \nensure that a level playing field is maintained for suppliers across domestic schemes, we \nwill align the SAF Mandate eligibility rules for fuels that have been in receipt of other \nincentives with those in the RTFO as much as possible. Our policy will operate alongside \nthe UK Emissions Trading Scheme (ETS), so that airlines can continue to make emissions \nreduction claims under the UK ETS for eligible SAF.  \nWe recognise that there are a number of policy changes that will affect airlines in a similar \ntimeframe to the Mandate, including from the UK ETS, when free allowances are withdrawn \nin 2026. We are mindful of the combined impact on the UK domestic aviation sector and are \nparticularly conscious of the importance of air connectivity to communities in isolated areas \nwith few other viable means of transport. We will continue to work with industry to ensure \nthere is appropriate provision for routes that are in danger of being lost, thus maintaining \nvital connectivity across the United Kingdom. \nWe recognise that SAF is a global market and have considered international policy when \nmaking the decisions contained in this document. This includes the EU mandate, the US \nSAF production incentive scheme and the decisions, guidance and policies of the \nInternational Civil Aviation Organization (ICAO), particularly its Carbon Offsetting and \nReduction Scheme for International Aviation (CORSIA). We will continue to play a leading \nrole internationally, including working closely with policymakers in other states, to ensure \nthat our policy works effectively to support global decarbonisation.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n13 \n \nFigure 1 The SAF Mandate in numbers \n \n \nThe SAF Mandate in numbers \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n14 \nSAF is a key part of the UK’s aviation decarbonisation strategy \nThe role of SAF in achieving net zero aviation \nThe air transport and aerospace sectors contribute significantly to the UK economy, directly \nemploying around 230,000 people5 and contributing around £20 billion to GDP6. Aviation \nprovides essential domestic and international connectivity for people and businesses and \nplays a key role in supporting trade and investment. The success of the aviation sector \nmeans that, while other sectors decarbonise as part of the UK’s journey towards net zero \nemissions by 2050, GHG emissions from aviation will represent an increasing share of total \nUK emissions. Without a reduction in emissions from aviation, the UK is unlikely to meet its \nupcoming carbon budgets. There is therefore an urgent need to decarbonise this sector.  \nTo address these challenges, the Jet Zero Strategy was published in July 20227. This set \nout our plan for achieving net zero aviation by 2050 through five key policy measures - \nsystem efficiencies, sustainable aviation fuels, zero emission flight, markets and removals, \nand influencing consumers – plus a sixth key policy measure addressing the non-CO2 \nimpacts of aviation. Central to the Strategy is the UK’s commitment to global leadership in \nthe development, production, and use of SAF. The High Ambition scenario in the strategy \noutlined that 50% uptake of SAF by 2050 would deliver 9 MtCO2e savings per annum by \n2050, as well as potentially additional non-CO2 emissions improvements.  \nSAF can bring both environmental and economic benefits \nSAF can be derived from a wide range of sources which achieve carbon savings relative to \nfossil fuel in different ways:  \n• where biomass is used to produce biofuels, carbon absorbed from the atmosphere \nduring the lifecycle of the biomass is equal to that emitted upon fuel combustion. The \nbiomass is then replaced with new biomass, which absorbs carbon and starts the \ncycle again. This achieves emissions savings compared to fossil fuel which \n \n5 DfT analysis of Office for National Statistics (ONS) Business Register and Employment Survey data \n6 DfT analysis of ONS low-level aggregates of UK output gross value added (GVA). \n7 https://www.gov.uk/government/publications/jet-zero-strategy-delivering-net-zero-aviation-by-2050  \nIntroduction   \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n15 \npermanently release carbon into the atmosphere that would otherwise be locked in \nthe ground. Feedstocks include used cooking oil and agricultural residues;  \n• where fossils wastes are used to produce recycled carbon fuels (RCFs), such as \nresidual municipal solid waste or industrial waste gases, carbon savings are achieved \nwhen it is more efficient to process these into fuels instead of disposing or treating \nthem via conventional means such as energy from waste. Feedstocks include \nunrecyclable plastic and industrial flue gas; and \n• where hydrogen is combined with non-biomass CO2 using low carbon (renewable or \nnuclear) power to produce power-to-liquid fuels (PtL), emissions savings are \nachieved through utilising carbon that would otherwise be emitted to, or is already in, \nthe atmosphere. \n \nSAF may also have the potential to reduce non-CO2 impacts of aviation, including contrails, \nby reducing particulate emissions. Studies indicate that non-CO2 emissions account for over \nhalf of climate impacts from aviation 8 , however, there continues to be significant \nuncertainties around the magnitude of non-CO2 impacts on climate. The government is \ntherefore providing funding to undertake further R&D in this area to better develop our \nunderstanding of aviation’s non-CO2 impacts and to identify and develop potential mitigating \noptions.  \nAlongside the emissions reducing potential of SAF, there are significant economic benefits \nassociated with the development of a domestic SAF industry. Industry research estimates \nthat such development could generate 60,000 new jobs by 2050, adding £10bn gross value \nadd per annum9. The SAF plants that are currently in development are located across \nregions that will benefit most from industrial regeneration. Moreover, the development of \ndomestic SAF production capacity will reduce the risk of dependence on other nations for \nour fuel supply, especially if it utilises a range of SAF feedstocks and production techniques. \nSAF therefore provides a means of delivering cost-effective emissions reductions for a hard \nto decarbonise sector while driving UK industry, creating green jobs, and supporting greater \nfuel resilience. As a result, the UK government recognises the importance of SAF uptake \nand this has formed a central part of the UK aviation decarbonisation strategy.  \nLow Carbon Fuels Strategy  \nDfT’s forthcoming Low Carbon Fuel Strategy, which is due to be published in Spring 2024, \naims to set a vision for the deployment of low carbon fuel (LCF) across transport modes, \nincluding aviation, in the period up to 2050 to support further investments in the sector. It \nwill help build on the UK’s success as an international leader in LCF and ensure the benefits \ntheir use offers are fully harnessed. \nLCF plays an integral part in our efforts to reduce greenhouse gas (GHG) emissions from \nthe transport sector, support green growth and enhance fuel security by providing a flexible \nalternative to fossil fuels. To date the majority of LCF supplied in the UK has been through \nthe Renewable Transport Fuel Obligation (RTFO), primarily for the use in road vehicles. In \n \n8https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/813342/n\non-CO2-effects-report.pdf  \n9 https://www.sustainableaviation.co.uk/wp-\ncontent/uploads/2023/04/SA9572_2023CO2RoadMap_Brochure_v4.pdf  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n16 \nthe medium to long term LCF will need to increasingly be prioritised across transport modes, \nespecially where there are limited alternatives to liquid and gaseous fuels such as aviation \nand maritime. \nBiomass Strategy \nThe Biomass Strategy10, published in August 2023, set out the role biomass can play in \nreaching net zero, what government is doing to enable that objective and where further \naction is needed. The strategy recognises that sustainable biomass is a limited resource \nand future availability to the UK is uncertain, and its use should be prioritised where it offers \nthe greatest environmental, economic, and social benefits.  \nThe Strategy identifies that LCF made from biomass will play an important role in transport \ndecarbonisation such as aviation where limited alternatives to the use of liquid fuels exist. \nThe Strategy provides an assessment on the amounts of sustainable biomass that could be \nused in the UK. The assumptions underpinning the Strategy have informed the analysis for \nthe SAF Mandate.  \nDelivering additional carbon savings \nThe main monetised benefits of the SAF Mandate are the GHG savings associated with \nswitching from kerosene to SAF. However, a key assumption underpinning this calculation \nrelates to the extent to which reductions in aviation sector emissions resulting from the use \nof SAF represent a net reduction in emissions across the UK. \nWe would expect the Mandate to lead other UK ETS participants to increase their demand \nfor UK ETS allowances relative to the counterfactual, as emission reduction options become \nless cost-effective under a lower carbon price. This suggests that other UK ETS participants \nwill reduce their own emission reduction activities. Based on this causal link it can be argued \nthat reductions in emissions from flights in scope of the UK ETS will not lead to a change in \ntotal UK economy emissions, unless the ETS cap is tightened in parallel, due to what is \ncalled the ‘waterbed effect’. This describes how, in the context of a cap-and-trade scheme \nfor emissions (like the UK ETS), where the cap remains fixed, any reductions in emissions \nby one participant leads to offsetting increases in emissions by other participants, with the \noverall impact that net emissions remain at the level of the cap. \nThere remains a chance that the direct impact of the Mandate on aviation emissions is \npartially offset by the indirect impact on emissions amongst some participants of the UK ETS \nscheme. This particularly applies for periods in which the UK ETS cap is already set (up to \n2030). \n \n10 https://www.gov.uk/government/publications/biomass-strategy  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n17 \nSupporting the development, production and use of SAF in the \nUK \nThe UK government has a world-leading programme of support for SAF based on three \npillars: \n• Creating secure and growing demand for SAF in the UK through the introduction \nof the SAF Mandate; \n• Kickstarting a UK SAF industry: through providing £171m of grant funding to \nsupport the development of advanced fuels since 2014, including £135m in support \nto domestic SAF projects to support our ambition to see five UK plants under \nconstruction by 2025; and \n• working in partnership with industry and investors to build the long-term \nconditions for SAF supply in the UK: through understanding barriers to investment \nand actions to overcome these, including committing to introduce a revenue certainty \nmechanism by the end of 2026. \nUpdates since the consultation \nSince the consultation was published, we have continued to progress our SAF programme.  \nTo create the longer-term conditions to support the development of a UK SAF industry, in \nSeptember 2023, the government committed to introduce a revenue certainty mechanism \nby the end of 2026. The Energy Act commits the government to consult on options to design \nand implement such a mechanism by 26 April 2024. The government is working with the \nSAF industry and aviation sector through the Jet Zero Council and its delivery groups to \nunderstand what other measures could be put in place in the interim period while the \ngovernment consults on the design of a revenue certainty mechanism.  \nTo permit support for RCFs and nuclear derived fuels into renewable transport fuel \nobligation schemes (such as the RTFO and SAF Mandate), the government tabled an \namendment through the Energy Security Bill to amend the Energy Act and allow these \nfuels to be supported. The bill achieved Royal Assent on 26 October 2023.  \nIn November 2023, the UK government announced a further eight projects to receive grant \nfunding under the Advanced Fuels Fund (AFF). This scheme is now supporting 13 plants \nwith investment of £135m. Through such investment, we are on track to deliver the Jet Zero \ncommitment to have five commercial SAF plants under construction by 2025. \nThe government has also launched the UK SAF Clearing House, to provide advice, \nguidance and funding to support the testing and approval of new SAF products, which will \nhelp accelerate their path to market.  \nMost recently, in November 2023, supported by up to £1m of grant funding from the \ngovernment, Virgin Atlantic operated the first transatlantic flight on a commercial aircraft \nusing 100% SAF. This flight generated important data and learnings to support increased \nuse of SAF in aircraft.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n18 \nCreating secure and growing demand through the SAF \nMandate \nThere is broad consensus on the need for a SAF mandate to create secure and growing \ndemand for SAF in the UK, throughout the fuels industry, the aviation industry and wider \nsociety. The SAF Mandate will obligate fuel suppliers to supply SAF in the UK and therefore \nwill create the necessary demand to incentivise the supply of SAF to the aviation industry. \nRemoving support for SAF from the RTFO will better adhere to the polluter pays principle \nso that the obligation falls on the jet fuel supply chain rather than the road fuel supply chain. \nIt will also send a clear message to investors regarding the long-term viability of the UK SAF \nmarket, thereby encouraging greater levels of investment into domestic production capacity.  \nPrevious consultation and what has been confirmed to date \nBetween July and September 2021, the government consulted on the creation of a SAF \nMandate to drive UK demand for SAF. In July 2022, we published our response to the \nconsultation confirming that the UK government will introduce a SAF Mandate that will take \neffect on 1 January 2025. After this date, SAF will no longer be eligible for support under the \nRTFO given it will be incentivised under the SAF mandate. The response also confirmed \nthe headline ambition of the SAF Mandate: by 2030, fuel suppliers will be obligated to ensure \nthat SAF comprises 10% of the UK aviation fuel mix.  \nThe principal mechanisms that make up the SAF Mandate were also confirmed in the \ngovernment response: \n• SAF will be rewarded with tradeable certificates in proportion to the GHG emissions \nreductions they achieve to promote fuels with cost-effective carbon savings; \n• a buy-out price will allow suppliers to comply with the obligation in situations where \neligible SAF cannot be supplied and protect consumers from spikes in SAF prices; \n• SAF must be made from residual wastes or residues (biomass, RCFs) or low carbon \nelectricity (renewable or nuclear). SAF produced from crops is not currently eligible \nfor support under the scheme;  \n• SAF must meet strict performance, safety, and sustainability criteria;  \n• PtL fuels will be promoted via a specific obligation to drive its production; and \n• fuel made from HEFA will be capped to incentivise the development of new \ntechnologies and diversify the feedstock mix. \nThe second consultation and government decisions \nThe second consultation on the SAF Mandate ran between 30 March and 22 June 2023, \nseeking views on the detailed design of the SAF Mandate across the following policy areas: \n• the trajectory to 2030 and beyond, the PtL obligation and the level of the HEFA cap; \n• how the scheme provides price support; \n• the level of the buy-out price – which determines the maximum potential incentive for \nsupplying SAF and helps drive price support for SAF;  \n• eligible fuels and sustainability criteria;  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n19 \n• the design of the certificate system including how certificates will be issued, traded \nand used for compliance;  \n• the Administrator of the scheme and enforcement;  \n• who the obligation applies to and how it is discharged; and \n• interactions with other domestic and international policy. \nThis document provides the government’s response. We received 104 responses from a \nrange of organisations and individuals concerning the government’s proposals. We would \nlike to thank all stakeholders for their time and contribution in responding to the consultation. \nSince the conclusion of the consultation period, we have carefully considered all responses \nand evidence provided to each question. \nThis document provides an overview of the proposals included in the second consultation, \na summary of the responses to each question and the government’s decision on each of the \npolicy proposals. It is important to emphasise that we consider a broad set of evidence when \nmaking decisions that shape the UK SAF Mandate. This includes academic literature, data \nanalysis and modelling, and consideration of domestic and international policy alongside \nstakeholder input. \nAlongside this document, we have published an updated cost-benefit analysis (CBA) that \nsets out the quantitative analysis and modelling that has underpinned the government \ndecisions. This analysis has been informed by a wide range of sources including; the \ngovernment’s Biomass Strategy, analytical tools commissioned from the Aviation Impact \nAccelerator team, led by Cambridge University’s Whittle Laboratory and the Cambridge \nInstitute for Sustainability Leadership, and evidence submitted by stakeholders during the \nconsultation.  \nNext steps \nThe Mandate will be implemented as an affirmative statutory instrument using the powers \ngranted by the Energy Act 2004 – the same primary legislation that allows the RTFO to \nprescribe an obligation on fuel suppliers. We will undergo the parliamentary process to enter \nthe Mandate into UK legislation in 2024 so that the Mandate can commence from 1 January \n2025.  \nIn parallel to drafting the legislation, the Department has been developing the IT system \nwhich will function as the principal tool for both the Administrator implementing the \nrequirements of the Mandate as well as suppliers complying with the scheme. The IT system \nis being developed as an extension to the existing RTFO Operating System (ROS) to \nsimplify compliance with the Mandate for existing users of ROS and those that will be \ninvolved with both the RTFO and SAF Mandate. Once developed, the Department will \nundergo a series of user testing sessions ahead of the Mandate commencing to receive \nfeedback and refine the IT system as needed.  \nThe Department is also developing guidance on the Mandate aimed at all interested parties \nincluding obligated jet fuel suppliers, renewable fuel suppliers, verifiers acting on the behalf \nof suppliers, relevant trade associations and other interested parties. The guidance will set \nout how obligated suppliers will comply with the upcoming legislation. This will include \npractical instruction on submitting required information to the Administrator, demonstrating \ncompliance with sustainability criteria, third party assurance and verification processes, and \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n20 \nany other information relevant to the implementation of the Mandate. The Department will \nshare the guidance ahead of the Mandate commencing to provide opportunity for \nstakeholders to familiarise themselves with it, provide feedback and ask any questions to \nthe Administrator if needed.  \nWe will continue to update stakeholders as each of these elements develop over the course \nof 2024 through the Jet Zero Council, stakeholder workshops and other engagement \nactivities. In the meantime, should any stakeholders have questions on the design and \nimplementation of the SAF Mandate, they should contact saf@dft.gov.uk.  \nResponses received \nWe received 104 responses from a range of organisations and individuals concerning the \ngovernment’s proposals. The following table provides a breakdown of those that provided a \nresponse to the consultation.  \nStakeholder group \nNumber of respondents \nAirline \n9 \nAirport \n4 \nCampaign groups / environmental NGO \n12 \nFuel producer or supplier \n24 \nFuel technology licensor or supplier \n7 \nPublic body \n2 \nIndividual \n18 \nNuclear or power industry \n5 \nOEM \n4 \nTrade association \n13 \nOther \n6 \nTotal \n104 \n \n \nFigure 2 Responses Received.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n21 \n1. Targets and price support for SAF  \n2025 target and trajectory to 2030 \nConsultation proposal \nIn the government response to the first consultation on the SAF Mandate, we confirmed our \ntarget of at least 10% SAF in the UK jet fuel mix by 2030. In the second consultation, we \npresented several possible trajectories to reach this target. Each was a linear trajectory and \nassumed that the mandated UK SAF mix will be made from a combination of domestically \nproduced and imported SAF.  \nIn the second consultation we noted that setting the 2025 target too high could lead to buy-\nout, while setting the target too low could lead to difficulties for UK industry scaling up \nproduction capacity. We sought views from respondents on which trajectory to 2030 strikes \nthe right balance between having a high ambition and providing demand certainty, whilst \navoiding being overambitious and increasing costs without GHG emissions savings through \nhigh levels of buyout. \n \n2025 \n2030 \n0 – BAU \n0.5%  \n2% \n1 - Low \n0.5% \n10% \n2 – Medium \n2% \n10% \n3 - High \n4% \n10% \nTable 1 Target trajectories from 2025 to 2030 as a percentage of UK aviation fuel demand. \nQuestion 1 \nWhich 2025 target option strikes the right balance between ambition and deliverability? \nDo you have any evidence to support your position? \nSummary of responses \nTotal \nOption 1 \nOption 2 \nOption 3 \n57 \n9 \n23 \n6 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n22 \nFigure 3 Question 1 summary of responses. \nThis question was answered by respondents in an open answer format. Fifty seven \nresponses were received, but most did not provide evidence on a specific trajectory. For the \n38 responses that did mention a trajectory, the figures are shown in Figure 3 above.  \nMost respondents who set out a preferred trajectory agreed that 2% (option 2) should be \nthe Mandate target for 2025. The main reasoning provided for this choice was to align with \nsimilar schemes in other regions to avoid any market distortions (in particular with other \nEuropean countries) and to continue to attract investment into the UK SAF industry. A few \nrespondents also suggested targets which were outside of the options provided or were \ncontent with more than one of the proposed trajectories.  \nSeveral respondents mentioned the HEFA cap when setting out their proposed option, \nstating that the level of the HEFA cap will have an impact on the deliverability of targets, \nparticularly in the early years of the Mandate. \nA few respondents stated that to meet any of the targets set out in the consultation, the \ngovernment needs to provide additional revenue support to enable the growth of a UK SAF \nindustry. Additionally, several respondents suggested that the Mandate should contain a \nmechanism to allow government to quickly alter trajectories if there is an excess supply of \nSAF compared to demand.  \nGovernment response \nWe have responded to questions one and two together - see government response below. \nQuestion 2 \nWould you find it acceptable if the trajectory from 2025 to 2030 was set at an \nambitious level and this led to high levels of buy-out and increasing costs to \nconsumers?  \nSummary of responses \nFigure 4 Question 2 summary of responses. \nMost respondents stated that they would not find it acceptable if the trajectory from 2025 to \n2030 was set at an ambitious level that led to high levels of buy-out and increasing costs. \nThe main reasoning provided for this view was that buy-out does not achieve emissions \nsavings, so a high rate of buy-out simply increases costs with no emissions reduction. Many \nrespondents also felt that a trajectory that is too high, leading to high buy-out and increasing \ncosts, would damage the competitiveness of UK aviation when compared with other similar \nregions. Several respondents additionally highlighted that the SAF market will still be in the \nearly stages of development during the period of 2025-2030 and suggested that, during this \ntime, targets should be ambitious but not unrealistic, again to avoid high levels of buy-out \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n49  \n 12 \n6 \n31 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n23 \nand increasing costs to consumers. A small number of respondents also suggested that if \nthe government decided to legislate for an ambitious target that could lead to high levels of \nbuy-out, it would need to communicate this to consumers. \nOn the other hand, several respondents highlighted that ambitious targets could send the \nright signals to investors and producers, potentially leading to increased long-term \ninvestment in the production of SAF. Others suggested that high ambition in early years \ncould be possible without high levels of buy-out if additional policy/revenue support was \navailable to industry. A small number of respondents noted that in the early years of the \nMandate, all the target options set out are quite low and suggested that even in the case of \nhigh levels of buy-out, only a small additional cost would be placed on passengers. A small \nnumber of respondents proposed that buy-out funds should be reinvested into SAF or other \naviation decarbonisation measures. \nGovernment response \nThe 2025 target and trajectory to 2030 must balance the need to deliver emission reductions \nby utilising SAF that is readily and commercially available, while also creating the \nenvironment for new technologies to develop and start contributing to a more diverse SAF \nmix that will secure the medium and long-term supply of SAF. It must also recognise the \noverall constraints on feedstock availability and the demand from other transport modes and \nother sectors of the economy. The decision on the overall trajectory has therefore been \ntaken alongside the HEFA cap, the PtL obligation and the buy-out prices.  \nGovernment decision: in 2025, the obligation will be set at 2% of jet fuel supplied, \nwhich is approximately equal to 230,000 tonnes of SAF. Targets will increase linearly \non an annual basis to reach 10% in 2030.  \nThis overarching trajectory will be comprised of the main obligation and PtL obligation. The \ncomplete set of targets between 2025 and 2030 are shown in Table 2 below. \nThis ambitious trajectory in the initial years of the Mandate sets the UK on the path to be a \nglobal leader in SAF uptake and reaffirms our commitment to at least 10% SAF in 2030; the \nmost ambitious 2030 SAF obligation in the world. This builds on the success of the RTFO, \nwhich has already seen 48 million litres11 of SAF supplied in the UK in 2022 (equivalent to \n0.4% of jet fuel supplied), which is over double the volume supplied in 2021. In 2023, this \nincreased to 81 million litres12. Based on a continuation of this trend, forecasted global \nproduction capacity and the impact of a comprehensive SAF programme in the UK, we are \nconfident that this 2025 target and trajectory to 2030 strike the right balance. \n \nYear \nOverall trajectory expressed as \npercentage of SAF of total jet fuel \nsupply \n \n11 https://www.gov.uk/government/collections/renewable-fuel-statistics  \n12 Based on provisional data. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n24 \n2025 \n2.0% \n2026 \n3.6% \n2027 \n5.2% \n2028 \n6.8% \n2029 \n8.4% \n2030 \n10.0% \nTable 2 Trajectory of % SAF in total jet fuel supply over time.  \nSetting increasing targets into the future \nThe SAF market is currently in its early stages of development. As a result, there is \nconsiderable uncertainty in the evidence and data reaching out to 2050. For this reason, the \nsecond consultation proposed to only set out increasing targets in legislation up to \n2040. This does not mean that targets end in 2040 but that they will continue at the 2040 \nlevel until they are reviewed and updated. We proposed that targets be kept under \ncontinuous assessment and are formally reviewed at least every five years (see section on \nMandate review points).  \nIn the consultation we set out three trajectories for the period 2030 to 2040, all starting at \n10% SAF uptake in 2030 and increasing at different rates, as well as a business-as-usual \ntrajectory. We also showed the potential level SAF supply could meet if trends continued to \n2050. In 2050, the medium trajectory could meet 50% of aviation fuel demand, in line with \nthe Jet Zero Strategy High Ambition scenario.  \nWe noted that if there is insufficient feedstock availability to produce the SAF needed to \nmeet the target, suppliers will need to buy out of their obligations, potentially increasing costs \nfor consumers. Conversely, if targets are set too low, the Mandate will not drive enough \ndemand for SAF or provide a strong enough incentive for suppliers and emission reductions \nmay be lower. This could also lead to the UK failing to secure domestic production facilities \nif producers decide to locate in countries with stronger incentives. We sought views from \nrespondents on which targets are both ambitious and deliverable.  \nTable 3 Increasing target trajectories from 2030 to 2040 as a percentage of UK aviation fuel demand. \n \n \n2030 \n2035 \n2040 \n0 – BAU \n2% \n3% \n4% \n 1 - Low \n10% \n13% \n17% \n2 – Medium \n10% \n15% \n22% \n3 - High \n10% \n18% \n32% \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n25 \nQuestion 3 \nDo you have any comments on the post 2040 proposal to legislate for targets \ncontinuing at the 2040 level, with the plan to update these when better data is \navailable? \nSummary of responses \nThis question was posed in an ‘open answer’ format, with 52 responses received. Of the 52 \nresponses, 42 responses stated whether they agreed or disagreed, with 62% agreeing and \n38% disagreeing with the proposal to legislate for targets continuing at the 2040 level until \nbetter data is available.  \nSome of the reasoning provided by respondents who agreed with this proposal included that \nit is sensible to not set longer-term targets (i.e. beyond 2040) without data to back up these \ndecisions, it is consistent with the RTFO, and the timeframe to 2040 provides sufficient \ncertainty to industry and investors. A small number of respondents suggested that if we \ndecide to go ahead with this proposal, a timeframe for setting the 2050 target should be \noutlined to provide greater future certainty. Similarly, a small number of respondents \nsuggested that we should make clear in any SAF Mandate guidance that targets will \ncontinue after 2040, but will not increase after that date until they are updated. This concern \nhas come from previous misconceptions regarding RTFO targets ending in 2032 when in \nfact the scheme has targets which remain at the same level post-2032.  \nConversely, those who disagreed with the proposal suggested that a 2050 target would \nprovide more certainty to investors and demonstrate the UK’s long-term ambition for SAF \nuptake, even if targets only increased slightly over this period. Several respondents \nsuggested that we should align with similar schemes in other regions, where targets have \nbeen set out to 2050. A few respondents argued that a non-increasing target will dampen \ninvestment appetite. \nSeveral respondents suggested that whatever option is chosen, producers, suppliers and \ninvestors should be given enough time to prepare for future targets.  \nGovernment response \nOne of the main objectives of the Mandate is to provide long-term certainty of SAF demand \nin the UK. We therefore recognise the importance of ensuring that targets extend far enough \ninto the future to allow all parties, including producers, suppliers, and investors, to plan \naccordingly. However, we must balance this with uncertainty around the long-term \ndevelopment of the SAF market and the need to use feedstocks in the most effective way \nacross the economy to deliver net zero.  \nGovernment decision: we confirm that we will set increasing targets to 2040 with \ntargets beyond 2040 remaining at the same level until they are reviewed, and the \nlegislation is updated.  \nOur engagement with the finance industry indicates that setting increasing targets up to \n2040 provides sufficient certainty to make investment decisions. Beyond 15 years, there is \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n26 \nincreased likelihood that targets would not be set at an appropriate level which could lead \nto unintended consequences such as high levels of buy-out. Our decision to not set \nincreasing targets beyond 2040 therefore reduces the risk of undermining the industry by \nhaving to reduce targets, should they prove to be too ambitious in the future. The Jet Zero \nStrategy already demonstrates the role SAF will play in achieving net zero aviation by 2050. \nWe will monitor the technological and commercial development of the SAF market as part \nof our review process (see response to questions 15 and 16). This will allow us to update \nthe post-2040 targets as soon as we have sufficient evidence to do so.  \nQuestion 4 \nWhat increasing trajectory to 2040 do you think strikes the right balance between \nambition and deliverability? Do you have any evidence to support your position? \nTable 4 Increasing target trajectories from 2030 to 2040 as a percentage of UK aviation fuel demand. \n \nSummary of responses \nFigure 5 Question 4 summary of responses. \nOf those who responded to this question, most believed that option three, our high trajectory \noption, strikes the right balance between ambition and deliverability. This trajectory would \nreach 32% by 2040. The main reasoning provided for this choice, as with the choice of \ntrajectory in question one, was to align with similar schemes in other regions. This would \navoid any market distortions or issues with competition (particularly with EU countries) and \nsend a strong signal to the market and drive SAF production.  \nMany respondents who chose option three also suggested that to meet the targets within \nthis trajectory, additional policy support would be required, particularly revenue support to \nmake UK SAF prices competitive with those in other countries. Similarly, several \nrespondents proposed that, to meet such ambitious Mandate targets, further polices are \nrequired that unlock access to feedstocks for SAF production and increase the production \nof low-carbon electricity.  \n \n2030 \n2035 \n2040 \n0 – BAU \n2% \n3% \n4% \n1 - Low \n10% \n13% \n17% \n2 – Medium \n10% \n15% \n22% \n3 – High \n10% \n18% \n32% \nTotal \nOption 1 \nOption 2 \nOption 3 \nNone \nDon’t know \n45 \n2 \n3 \n30 \n10 \n5 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n27 \nSeveral respondents suggested that a linear progression of targets would be preferable to \nan exponential progression, with the reasoning being that this allows producers to gradually \nscale up their production to meet demand. \nA few respondents again mentioned the impact of the HEFA cap on the availability of SAF \nwhen setting out their proposed option, stating that the level will have an impact on the \ncompetitiveness of the UK SAF market in comparison with those in other regions.  \nA small number of respondents suggested that the Mandate should aim for the highest \nambition possible to achieve the greatest emissions reductions.  \nGovernment response \nWe have considered the responses to questions four, five and six together - see government \nresponse following question six. \nQuestion 5 \nDo you have an alternative trajectory option you would prefer to see, and do you have \nevidence to support this? \nSummary of responses \nThis question was asked in an open answer format and received 34 responses. Of these, \nmost suggested that Mandate trajectories should align with, or be higher than, those in other \nregions to ensure the UK market remains competitive.  \nMany respondents suggested that a higher trajectory option should be provided, with some \nproposing that government should have the highest ambition possible and legislate a 2040 \ntarget of 100% SAF in jet fuel. It was proposed that within this ambition, only feedstocks with \nthe highest sustainability standards should be allowed. Many responses repeated that a \nlinear trajectory would be preferable to an exponential one as it allows producers appropriate \ntime to ramp up their production capacity gradually. \nSeveral respondents suggested that additional policy support is required to ensure the SAF \nmarket is suitably scaled to meet targets post-2030. Some of the options proposed included \ncapital investments, tax credits, revenue certainty mechanisms, and the reinvestment of UK \nETS revenues into the SAF sector. \nSeveral respondents raised the HEFA cap as a potential inhibitor of SAF availability to the \nUK market and suggested that government should be technology neutral if the UK wants to \nmeet its SAF targets.  \nA small number of respondents proposed that any alternative trajectories would need to be \nbased on sound science and shown to be achievable. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n28 \nGovernment response \nWe have considered the responses to questions four, five and six together - see government \nresponse following question six. \nQuestion 6 \nWould you find it acceptable if the trajectory from 2030 onwards was set at an \nambitious level and this led to high levels of buy-out and increasing costs to \nconsumers? \nSummary of responses \nFigure 6 Question 6 summary of responses. \nMost respondents stated that they would not find it acceptable if the trajectory from 2030 \nonwards was set at an ambitious level, and this led to high levels of buy-out with increasing \ncosts. Like responses to question two, the main reason provided by these respondents was \nthat high levels of buy-out would represent a policy failure, in that either targets have been \nset too high and are unachievable or the right policy support has not been provided to allow \nambitious targets to be met. Similarly, it was highlighted that buy-out does not achieve \nemissions reductions, and simply increases costs.  \nAgain, several respondents felt that an overly ambitious trajectory that leads to high buy-out \nand increasing costs would damage the competitiveness of UK aviation and the UK SAF \nindustry when compared with other regions. A few respondents highlighted that although \nthe SAF market will be more mature than during the 2025-2030 period, it will still be \ndeveloping in the period from 2040 onwards, and that targets should still be ambitious but \nnot unrealistic, to avoid high levels of buy-out and increasing costs to consumers. A small \nnumber of respondents suggested that if the government does legislate for ambitious targets \nand this leads to high levels of buy-out, they have a responsibility to communicate this to \nconsumers. Similarly, a few respondents suggested that UK airline passengers should not \nbe unfairly burdened with increased costs due to buy-out compared with passengers in other \ncountries.  \nOn the other hand, several respondents highlighted that ambitious targets could send the \nright signals to investors and producers. This could potentially lead to increased long-term \ninvestment in and production of SAF. Others suggested that a high ambition trajectory could \nbe possible without high levels of buy-out if additional policy/revenue support was available \nto industry. A few respondents also highlighted that since supply should be higher post-2030, \nthe risk of buy-out should also be lower. Due to this assumption, some respondents felt that \nbuy-out should be replaced with penalties in later years of the Mandate.  \nA few respondents suggested that buy-out funds should be reinvested into SAF or other \naviation decarbonisation measures. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n54  \n 16 \n6 \n32 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n29 \nGovernment response to questions on the overarching trajectory \nIn the Executive Summary, we set out our vision for the UK SAF sector, in which setting \nambitious long-term targets is pivotal. However, as noted in response to the question Three, \nthe uncertainties associated with the development of the SAF sector increase over time. \nThis includes technology ramp up, feedstock availability, low carbon energy and hydrogen \navailability both domestically and worldwide.  \nGovernment decision: for the targets from 2030 to 2040, to adopt the medium \ntrajectory consulted on. In 2030, SAF must comprise 10% of UK aviation fuel. This will \nincrease to 15% in 2035 and 22% in 2040.  This overarching trajectory will comprise of the \nmain obligation and PtL obligation. The full set of targets are set out in Table 5. \nThis trajectory will cement the UK as one the leading SAF markets and encourage \ninvestment. From 2030 onwards, we expect the production of SAF from second-generation \ntechnologies to rapidly increase and the production of PtL to accelerate. The targets set out \nhere, in conjunction with the HEFA cap and PtL obligation, will create the market space for \nall these technologies to develop. We will deliver the carbon savings necessary to help keep \nus on track to meet the UK’s carbon budgets and net zero, with annual GHG emissions from \naviation reducing by 6.3MtCO2e13 on average by 2040.   \nThe confirmed trajectory provides sufficient flexibility to raise targets in the future should the \nmarket and the technology develop more quickly and/or SAF costs come down significantly. \nThe Mandate review process is set out in response to questions 15 and 16.  \nWe recognise that two thirds of respondents to the consultation question preferred a more \nambitious trajectory. At the same time, most respondents would not find it acceptable if the \ntargets led to high levels of buy-out. An overly ambitious post-2030 trajectory may lead to \nhigh levels of buy-out which would represent a policy failure. This would therefore \nnecessitate the revision of targets downwards, which could undermine confidence within \nindustry.  \nYear \nOverall trajectory expressed as \npercentage of SAF of total UK jet fuel \nsupply \n2030 \n10.00% \n2031 \n10.75% \n2032 \n11.75% \n2033 \n12.75% \n2034 \n13.75% \n2035 \n15.00% \n \n13 On a lifecycle basis. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n30 \n2036 \n16.40% \n2037 \n17.80% \n2038 \n19.20% \n2039 \n20.60% \n2040 \n22.00% \nTable 5 Trajectory of % SAF in total jet fuel supply over time. \n \nFigure 7 SAF demand as % of total jet fuel demand.  \nHEFA cap \nWhat is HEFA? \nHEFA is the only pathway that is producing on a commercial scale today. It is made from \noily feedstocks – the key feedstocks which would be eligible for the SAF Mandate are the \nwaste materials used cooking oil (UCO) and tallow.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n31 \nThe need for a HEFA cap \nIn the 2022 Mandate government response, we confirmed that we would introduce a cap on \nthe amount of HEFA that would be eligible for incentives under the Mandate. The purpose \nof a HEFA cap is to create space for the development of new advanced SAF technologies \nand encourage investment in these. A diverse portfolio of SAF will also help provide a secure \nsupply to meet the Mandate targets.  \nHEFA will play an important role in decarbonising jet fuel; however, HEFA alone will not fulfil \nthe UK’s SAF demand. The HEFA feedstocks that are most relevant for use under the SAF \nMandate, in particular UCO, are a finite resource and there are competing demands across \nthe globe from other modes of transport, particularly road fuel use. Going forwards, there \nwill be increasing competition for their use in SAF as other countries’ mandates and targets \nkick-in. New technology pathways will need to be developed that can unlock new feedstocks \nto supply SAF at scale and help us meet our decarbonisation goals.  \nThe HEFA cap will reduce the risk of diverting used cooking oil and tallow from road transport \nprematurely. The UK’s RTFO relies heavily on these feedstocks – UCO comprised 42% of \nrenewable fuel in 2022 and ~75% of biodiesel14. There are limited alternative feedstocks for \nroad biodiesel, so diverting them from the RTFO, could lead to suppliers needing to buy-out \nfrom their RTFO obligations. HEFA feedstocks that are not used extensively in road \ntransport are excluded from the cap e.g. tyre pyrolysis oil from advanced conversion \ntechnologies.  \nThe cap will also help place the UK as a leader in advanced SAF technologies. All 13 of the \nprojects supported under the Advanced Fuel Fund (AFF) are non-HEFA based and deploy \na range of technologies and feedstocks. These include: Fischer-Tropsch/ gasification of \nmunicipal black bin bag waste; alcohol-to-jet using industrial waste gases or forestry/ \nagricultural residues; and power-to-liquid using low carbon hydrogen and CO2 as inputs. \nThe UK will have the advantage of being a first mover on these technologies, harnessing \nopportunities for green growth and jobs.  \nInformation on how the HEFA cap will be defined under the Mandate can be found in Chapter \n3.  \nConsultation proposal \nIn the consultation, we presented a range within which the HEFA cap could fall, without a \npreferred option, due to uncertainty around future feedstock availability and demand for \nUCO and tallow (from road transport).  \n \n14 https://www.gov.uk/government/statistics/renewable-fuel-statistics-2022-final-report  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n32 \n \nFigure 8 HEFA cap options in tonnes. \nThe lower bound capped HEFA uptake at 0% of mandated SAF uptake. This would minimise \nthe risk of UCO and tallow being diverted from use under the RTFO, although there would \nstill be competition for these finite feedstocks with schemes in other nations.  \nThe upper bound HEFA cap option was set at the maximum level of HEFA modelled in the \nAviation Impact Accelerator (AIA) model scenarios, which calculated the most economic fuel \nmix each year to meet the proposed mandate level, given the relative cost-effectiveness of \nthe emissions reductions associated with the use of SAF, and constrained by the assumed \navailability of feedstocks. We sought views from respondents on where within this range the \nHEFA cap should be set.  \nQuestion 7 \nDo you agree with where we have set our HEFA cap upper and lower bounds (upper \nbound is highest HEFA uptake modelled under the Mandate, lower bound is no HEFA \nin the Mandate)? Do you have any evidence to support this? \nSummary of responses \nFigure 9 Question 7 summary of responses. \nRespondents were evenly split on whether they agreed or disagreed with where the HEFA \ncap upper and lower bounds were set in the consultation. \n0\n50,000\n100,000\n150,000\n200,000\n250,000\n300,000\n2025\n2030\n2035\n2040\nTonnes of HEFA\nYear\nHEFA cap options in tonnes\nOption 1 - Lower bound cap\nOption 2 - Upper bound cap\nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon’t know \n36  \n 14 \n6 \n15 \n1 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n33 \nOf those that disagreed with the lower band, they largely noted that HEFA is the only \ncommercially viable and cost-effective type of SAF, and that this will be the case until around \n2030. A HEFA cap of 0% would significantly limit the ability of suppliers to meet their \nobligations – either forcing them to supply more expensive low carbon fuels, or if not \navailable, leading them to a high level of buy-out. This would increase prices for consumers \nwithout delivering emission reductions, especially if the UK pursued an ambitious target \ntrajectory.  \nSome respondents disagreed with the lower band based on its deviation from the policy of \nother regions that are trying to develop SAF industries, particularly the EU. These regions \nwill have greater access to higher volumes of cheaper SAF which may place the UK at a \ncompetitive disadvantage. This may also create a situation where UK HEFA SAF suppliers \nmust export HEFA while there is buy-out in the UK. In addition, some pointed towards the \nimpact of EU policy on the diversion of HEFA feedstock away from the RTFO’s biofuels.  \nMany of these respondents felt that the HEFA cap should be set at or near to 100% of the \nobligation in the early years. Many respondents also suggested that a HEFA cap should be \ndeferred until there is greater availability of second-generation fuels.  \nSome respondents did not agree with the inclusion of a cap. They suggested that the \ngovernment should be technology neutral, and that rather than building a cap into the \nMandate, they should instead focus on reducing net carbon emissions.  \nSome of the respondents disagreed with the level of the upper bound. They referenced the \nimpact on road fuels that the SAF Mandate would have if it did not include a HEFA cap. \nThey stated that the use of UCO and animal fats in producing biodiesel represents the most \ncost-effective and efficient emission reductions, so feedstocks should not be diverted from \nthis until road transport is electrified.  \nOther respondents that disagreed based with the higher bound level cited the need to allow \nspace for other fuels to develop. They emphasised that the HEFA cap should be used to \nsend a signal to industry that second generation SAF will be critical to delivering net zero. \nThey stated that, a HEFA cap below the higher bound level, combined with the GHG \nemissions basis of the Mandate, would incentivise the early development of these fuels, \nwhich could give the UK a competitive advantage in the long-term.  \nSome respondents suggested a HEFA cap of 0% due to the high fraud and sustainability \nrisks associated with significant increases in HEFA demand. \nGovernment response \nWe have responded to questions seven, eight and nine together – see government \nresponse following question nine. \nQuestion 8 \nDo you agree that we should try to limit the diversion of feedstocks from difficult-to-\ndecarbonise road transport modes as much as possible? \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n34 \nSummary of responses \nFigure 10 Question 8 summary of responses. \nRespondents were evenly split on whether they agreed or disagreed that we should try to \nlimit the diversion of feedstocks from road transport as much as possible. The main reasons \nprovided for this were that road transport already has clear options for decarbonisation, \nincluding electrification, and that aviation is more difficult and expensive to decarbonise. A \nfew respondents proposed that instead of limiting the amount of feedstock aviation can use \nto avoid diversion from the road sector, the government should instead focus on finding \nadditional pathways to decarbonise the road sector. \nIt was also suggested that as other countries with similar SAF schemes have not included \na HEFA cap in their policies, the HEFA cap will have no real impact on a global scale, and \nfeedstock will continue to be diverted from road by aviation sectors in other countries. \nRespondents suggested that this would therefore likely influence the UK industry’s \ncompetitiveness, as other countries will have access to higher volumes of cheaper SAF. For \nthis reason, several respondents proposed that the government should be technology \nneutral and let the market decide where feedstocks go. Several other respondents \nsuggested that if a HEFA cap is implemented, the government will need to provide additional \npolicy support to the second generation SAF sector to ensure it can compete internationally.  \nOn the other hand, those who agreed that the government should limit the diversion of these \nfeedstocks noted that less energy is required to produce biodiesel from the same feedstocks \nand that biodiesel achieves better GHG emission reductions than HEFA SAF, meaning that \nthe best use of UCO and tallow for emissions reductions is in road transport applications. \nSeveral respondents argued that a HEFA cap will also encourage the development of other \nSAF pathways, as without a cap the entire main Mandate obligation would be met by HEFA \nat the lowest cost, but with potential negative environmental and sustainability impacts.   \nGovernment response \nWe have responded to questions seven, eight and nine together – see government \nresponse following question 9. \nQuestion 9 \nAt what level do you think a HEFA cap should be set to balance Mandate deliverability \nwith road transport decarbonisation? \nSummary of responses \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon’t know \n57 \n 24 \n8 \n25 \n0 \nTotal \nLower bound \nHigher bound \nHigher than upper \nbound \nNo cap \n55 \n 5 \n5 \n5 \n4 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n35 \nFigure 11 Question 9 summary of responses. \nThis question was asked in an open-answer format and received 55 responses. Many \nrespondents did not specify what level they would like the HEFA cap to be set at, but the \nbreakdown of the 19 respondents who did is shown in Figure 11 above. From the responses \nshown in Figure 11 and from others who did not specifically state a HEFA cap level, there \nwas generally a preference for a cap close to the upper bound or no cap at all. In particular, \nseveral respondents suggested there should be a high cap at least at the beginning of the \nMandate. The reasoning provided for this was that HEFA will be the most available form of \nSAF when the Mandate begins in 2025 and will remain so until other technologies mature \nand scale. A few respondents proposed that the availability of non-HEFA SAF should inform \ndecisions on the Mandate HEFA cap level. One respondent also commented that high \nambition targets and trajectories cannot be met with a mechanism that caps HEFA at low \nlevels. \nAs with the previous questions on a HEFA cap, a few respondents highlighted that there is \nno cap on waste based HEFA in similar policies in other regions, which could potentially put \nthe UK industry at a competitive disadvantage and have a negative impact on sector growth. \nA few of these respondents also suggested that a HEFA cap in the UK and none in \nsurrounding markets would not stop the production of HEFA or the diversion of feedstocks \nbut would simply lead to the exporting of UK produced HEFA SAF to other countries. A small \nnumber of respondents suggested that the government should be technology neutral and \nshould allow the market to decide the best use of feedstocks and technologies. Additionally, \nseveral respondents again highlighted that road transport has more technology at its \ndisposal to decarbonise than aviation does currently, so feedstocks should instead be \nprioritised for SAF production. \nOn the other hand, several respondents proposed that no UCO or tallow should be allowed \ninto the SAF Mandate, and therefore HEFA derived from these feedstocks should be capped \nat 0%. These respondents argued that UCO has been produced fraudulently in the past, \ncould cause displacement emissions, and that the small amount that is produced in the UK \nis better used in road transport decarbonisation. It was suggested that the government \nshould focus on a frequent flyer levy or demand management to reduce emissions from \naviation.  \nOne respondent suggested that the UK should allow the use of crop feedstocks in the \nMandate as long as they do not create indirect land use change (ILUC) concerns. \nGovernment response to questions on the HEFA cap \nThe government remains committed to a HEFA cap within the Mandate for the reasons set \nout above. However, we recognise that HEFA is currently the only type of SAF that is \ncommercially available and that HEFA will be needed to help decarbonise jet fuel, especially \nin the early years of the SAF Mandate.  \nThe decision for the level of the HEFA cap has been taken alongside decisions on overall \nSAF targets and the level of the buy-out price.  \nGovernment decision: the HEFA cap, as proportion of the overall trajectory, will be \nset at 100% in 2025 and 2026 decreasing to 71% in 2030 and 35% in 2040.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n36 \nThe annual HEFA cap for each year in the period of 2025-2040 is included in Table 6 below. \nThis cap will apply to fuels that are made from segregated oils and fats. Further information \non this definition is found in response to question 19.  \nIt is evident that HEFA will play a critical role in the UK SAF sector, particularly during the \nearly years where there is limited production of alternative SAF. We want to avoid placing \nundue burden on the SAF production industry; we welcome the current investments that \nhave been made here in the UK to produce HEFA SAF and have provided support to this \nunder the RTFO. We cannot rely on this technology alone, given the finite nature of \nfeedstocks such as UCO, but welcome the development of this industry in the UK alongside \nthe more advanced technologies. There is no cap on the amount of HEFA that can be \nproduced in the UK, while the HEFA cap on suppliers seeking support under the Mandate \nwill still allow around 1 million tonnes of HEFA derived SAF to be supplied in the UK from \n2035 onwards. This will reduce the risk of buy-out and ensure that the UK aviation sector \ncan continue to operate competitively while still securing emission reductions.  \nHowever, for the reasons set out above, it is not feasible to continue a reliance on HEFA if \nwe are to meet the 2030 target and continue to increase ambition thereafter as set out earlier \nin this section. Technology pathways will need to be developed that can unlock new \nfeedstocks, such as residual municipal solid waste and agricultural residues, to supply SAF \nat scale. From 2027, the cap will provide a dedicated space in the market for technologies \nother than HEFA to sell into. This reaffirms the UK’s commitment to develop these advanced \ntechnologies and will encourage further investment into non-HEFA SAF production. The \ninclusion of the cap, in combination with supporting 13 projects through to Final Investment \nDecision with £135m awarded under the Advanced Fuels Fund and the introduction of a \nRevenue Certainty Mechanism by the end of 2026, will give the UK first mover advantage \non these technologies, harnessing opportunities for green growth and jobs and cementing \nour position as a world-leader of second-generation SAF.  \nThe cap will also help ensure that the biodiesel sector is able to access UCO and tallow. \nThere are limited alternative feedstocks for biodiesel so diversion of these feedstocks from \nthe RTFO could lead to buy-out and increase GHG emissions from road transport should \nthere be insufficient feedstock15. It should be noted that there will be competition for UCO \nand tallow from international schemes including the EU SAF Mandate.  \nWe recognise that there are concerns that increased demand for UCO could lead to \nincreased sustainability and traceability risks. The UK is a world- leader in setting and \nenforcing strict sustainability requirements and we will continue to do so in the SAF Mandate. \nWe will monitor the situation closely as the SAF Mandate is introduced, with the ability to \namend the Mandate at the review points confirmed in response to question 15. Furthermore, \nwe are working closely with voluntary schemes to identify ways that supply chain certification \ncan be improved.  \nYear \nHEFA cap as % of jet \nfuel demand \nHEFA cap as % of \noverarching SAF trajectory \n2025 \n2.00% \n100% \n \n15 In 2022, UCO comprised 42% of renewable fuel and 75% of biodiesel supplied in the RTFO. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n37 \n2026 \n3.60% \n100% \n2027 \n4.80% \n92% \n2028 \n5.80% \n85% \n2029 \n6.60% \n79% \n2030 \n7.10% \n71% \n2031 \n7.50% \n70% \n2032 \n7.60% \n65% \n2033 \n7.70% \n60% \n2034 \n7.70% \n56% \n2035 \n7.80% \n52% \n2036 \n7.80% \n48% \n2037 \n7.80% \n44% \n2038 \n7.80% \n41% \n2039 \n7.80% \n38% \n2040 \n7.80% \n35% \nTable 6 HEFA cap as percentage of jet fuel demand and of overarching trajectory over time.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n38 \n \nFigure 12 HEFA cap as a percentage of total SAF demand and percentage of UK jet fuel demand over time. \nPower-to-liquid (PtL) obligation \nIn 2022, we confirmed that the Mandate would include an obligation to supply power-to-\nliquid (PtL) fuels to specifically incentivise the supply of these fuels given their high GHG \nemissions reduction potential and low risk of environmental impacts including land use \nchange. The PtL obligation will have a separate, higher, buy-out price to account for the \nhigher costs of producing the fuel compared to SAF.  \nPtL is defined as low carbon avtur for which the energy content of the fuel is derived from \nrenewable (excluding bioenergy) or nuclear energy sources. Further information on this \ndefinition can be found in response to question 20. \nWe consulted on potential trajectory options for a PtL obligation out to 2040. In these options, \nwe noted the balance between the need to provide a high enough incentive for PtL whilst \nalso recognising the likely costs of high ambition. \nAs PtL production relies on the use of low carbon electricity, low carbon hydrogen and a \nsource of CO2, we also asked respondents to consider the low carbon energy, hydrogen \nand CO2 requirements PtL production could have, and how the availability of, and access \nto these could impact on production capacity. \n \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n39 \n \n2025 \n2030 \n2035 \n2040 \n1- Low \n0% \n0.05% \n0.25% \n1.5% \n2- Medium \n0% \n0.10% \n0.50% \n3 % \n3- High \n0% \n0.20% \n1% \n6% \n4- Very High \n0.05% \n1% \n3% \n8% \nTable 7 PtL obligation range as a percentage of total jet fuel demand. \nQuestion 10 \nAt what level do you think a PtL mandate should be set to strike the right balance \nbetween ambition and deliverability? Do you have any evidence to support your \nchoice, in particular considering low carbon electricity and hydrogen production, as \nwell as carbon capture requirements? \nSummary of responses \nFigure 13 Question 10 summary of responses.  \nThis question was asked in an open-answer format and received 59 responses. Many \nrespondents did not specify which level they would like the PtL obligation to be set at, but \nthe breakdown of the 25 respondents who did is shown in Figure 13 above. \nRespondents who felt the PtL target should be set at a high, or very high, level, or higher \nthan the options provided, suggested that an ambitious target will send a strong signal to \ninvestors that there will be future demand for PtL SAF. They also highlighted the emission \nreduction potential of PtL alongside the benefit of not requiring biomass feedstocks in their \nproduction. Additionally, several of these respondents suggested that we should align with \nsimilar schemes in other regions, to ensure our PtL targets are not substantially lower than \nothers. \nMany respondents, regardless of their view on the level of the PtL obligation, highlighted \nthat growth is required in the renewable electricity, hydrogen and carbon capture usage and \nstorage (CCUS) sectors before PtL will be available in large quantities. In particular, it was \nnoted that renewable electricity prices in the UK are much higher than in neighbouring \nregions, which would increase PtL production prices and impact on the competitiveness of \nany future UK PtL market if not addressed. Several respondents proposed that the \ngovernment needs to do more work to ensure that there will be suitable capacity to allow \naviation to decarbonise alongside the many other sectors who will be competing for \nrenewable energy as the UK aims to reach net zero by 2050. Stemming from these views, \nTotal \nMedium \nHigh \nVery high \nHigher than \noptions provided \n59 \n 2 \n12 \n7 \n4 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n40 \nseveral respondents argued that system level impacts of the proposed PtL targets should \nbe included in our analysis.  \nA few respondents highlighted that Direct Air Capture (DAC) is not the only carbon source \navailable for the production of PtL, and that other forms such as industrial point source \ncarbon are also available and should be eligible under the Mandate. Additionally, a small \nnumber of respondents highlighted the potential role of small modular nuclear reactors within \nPtL production.  \nSeveral respondents suggested that additional policy support is required if PtL supply is to \nreach the levels needed for UK aviation. Some of the support mentioned included research \nand development funding for the technology, funding for plants and a ‘Contracts for \nDifference mechanism’ for revenue certainty. \nRespondents who advocated for slightly lower targets, a slower ramp up of the PtL obligation, \nor did not know which option to pick, highlighted that PtL technology does not yet exist at \nscale. Several respondents suggested that setting out a PtL obligation too early, or too high \nwould lead to high levels of buy-out at an even higher cost than for the main target, leading \nto increased costs and no emissions savings. For this reason, some respondents found it \ndifficult to choose a trajectory option, particularly in the early years of the Mandate, with \nseveral suggesting that we keep targets low or have no targets for the first few years.  \nRespondents who did not agree with a PtL obligation suggested that government should be \ntechnology neutral and not try to pick winning technologies. A few of these respondents \nsuggested that PtL will already be incentivised and positively rewarded as the Mandate is a \nGHG emissions scheme. \nGovernment response \nWe have responded to questions 10 and 11 together – see government response following \nquestion 11. \nQuestion 11 \nIn which year do you think it would be most appropriate for a PtL obligation to start \nand how quickly do you think ambition should ramp up? \nSummary of responses \nTotal \n2025 \n2026 \n2027 \n2028 \n2030 \n2032 \n2035 \n47 \n4 \n4 \n3 \n2 \n20 \n1 \n4 \nFigure 14 Question 11 summary of responses.  \nThis question was asked in an open-answer format and received 47 responses. Some \nrespondents did not specify which year they thought the PtL obligation should start in, but \nthe breakdown of the 38 respondents who did is shown in Figure 14 above. Out of the \nrespondents who did pick a year, most chose 2030, with the main reasoning being that the \ntechnology is still in development and is yet to be demonstrated at scale, therefore volumes \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n41 \nmay not be available before this point. Several respondents also outlined that a 2030 start \ndate would be in alignment with similar schemes in other regions and urged for the same \nstart date to create harmonisation between policies. Additionally, several respondents \nsuggested that a scale-up of renewable electricity is required before PtL will be available in \nhigh quantities, and this will take time to achieve.  \nA few respondents suggested that the PtL target and its implementation date should be \ndeveloped in alignment with other government schemes focussed on the availability of \nCCUS, low carbon hydrogen and low carbon electricity to ensure economy-wide \ndecarbonisation policies are consistent. A small number of other respondents proposed that \nwhen targets begin and how quickly they ramp up should be based on an assessment of \nthe readiness of industry and should be reviewed frequently. \nSeveral respondents suggested that if the PtL obligation began in 2030, ambition should \nramp up very quickly after this point, with targets increasing rapidly due to expected industry \ngrowth in the 2030s. A few respondents also highlighted that this quick ramp-up in targets \nwould be necessary due to the high level of competition for waste feedstocks and current \nlimited alternatives to waste-based SAF. \nAs with most of the previous questions, several respondents suggested that additional policy \nsupport is required to ensure PtL SAF production is feasible in the UK. Some of the options \nproposed include stacking of incentives such as the hydrogen and industrial carbon capture \nbusiness models; provision of grant funding; and the use of UK ETS revenues. Additionally, \nas with previous questions on PtL, a few respondents have suggested that the government \nshould be technology neutral, and therefore a separate PtL target should not be included in \nthe Mandate. \nOne respondent suggested that rather than having a separate PtL obligation, we should \ninstead include a PtL multiplier which rewards PtL SAF with double credits. It was argued \nthat this would mean the start date of PtL reward would not be an issue because of the lack \nof a separate obligation and therefore a lack of a need to buy out of this obligation. Another \nrespondent who proposed that the PtL obligation should begin in 2030 suggested that in \norder to incentivise early adoption of PtL before 2030, we should allow suppliers to generate \nPtL certificates from 2028 and bank these for use once the PtL obligation starts in 2030. \nGovernment response to questions on the PtL obligation  \nThe government has already set out its commitment to the development of PtL fuels by \nconfirming in the 2022 response to the first consultation that there would be a specific PtL \nobligation in the Mandate. These fuels can achieve close to 100% GHG emissions \nreductions on a lifecycle basis and have a low risk of environmental impacts including land \nuse change. Furthermore, the obligation will further diversify the SAF available to meet net \nzero aviation, deliver the Mandate targets and contribute to a secure supply of SAF. \nHowever, there is significant uncertainty around the technological and commercial \ndevelopment of PtL and the demands of low carbon energy across the economy.  \nGovernment decision: The PtL obligation will be introduced in 2028 where it will be \nset at 0.2% of total jet fuel demand. This will increase to 0.5% in 2030 and 3.5% in 2040.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n42 \nThis trajectory will enable a market for these fuels to be established whilst balancing the \nuncertainty associated with their development.  \nThe overarching trajectory comprises the main obligation and the PtL obligation. \nThe PtL obligation for each year is presented in Table 8. The fuels that will qualify for PtL \ncertificates is confirmed in response to question 20.  \nStarting the PtL obligation before 2030 demonstrates the UK’s commitment to advanced \nfuels and reflects its role as a global leader in this area. There is significant investment being \ndirected into this technology globally, including projects in the UK being supported by the \ngovernment’s Advanced Fuels Fund. In Europe, PtL plants are expected to start producing \nSAF prior to 203016. The UK will be an early mover in mandating PtL fuels compared to \nother regions and the PtL obligation will set a clear signal for investors. However, \nrecognising the uncertainty around this new technology, we have combined the early start \ndate with a relatively low obligation level to mitigate the risk of buy-out if there is limited PtL \nSAF available.  \nBetween 2030 and 2040, our confirmed trajectory broadly aligns with the medium option we \nconsulted on. During this timeframe there is less certainty regarding international production \ncapacity as well as the availability of CCUS, low carbon energy and low carbon hydrogen \nthat these plants rely on. However, by showing ambition and establishing a market, we will \nencourage investment to accelerate the development of PtL and capitalise on the \nenvironmental benefits it offers.  \nWe recognise that imported PtL will likely play an important role in meeting our ambitious \nPtL obligation. Indeed, SAF imported from parts of the world with very low renewable energy \ncosts may offer cost-effective emission reductions and diverse supply sources can help \nprovide a secure supply of SAF.  \nYear \nPtL obligation as % of jet fuel demand  \n2028 \n0.20% \n2029 \n0.20% \n2030 \n0.50% \n2031 \n0.50% \n2032 \n0.75% \n2033 \n1.00% \n2034 \n1.25% \n \n16 https://www.transportenvironment.org/discover/e-fuels-for-planes-with-45-projects-is-the-eu-on-track-to-\nmeet-its-targets/  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n43 \n2035 \n1.50% \n2036 \n1.90% \n2037 \n2.30% \n2038 \n2.70% \n2039 \n3.10% \n2040 \n3.50% \nTable 8  PtL obligation as a percentage of jet fuel demand over time.  \n \nFigure 15 PtL obligation as a percentage of jet fuel demand over time.  \nFinal policy parameters  \nThe chart below illustrates how the main and PtL obligation combine to meet the total SAF \ndemand. We have included select years in the table below to illustrate how each of the main \nobligation, PtL obligation and HEFA cap interact.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n44 \n \n \nFigure 16 The main obligation, PtL obligation and HEFA cap expressed a percentage of total jet fuel demand.  \nBuy-out price \nIn the government response to our first Mandate consultation, we confirmed that a buy-out \nmechanism will be included in the UK SAF Mandate. The purpose of a buy-out mechanism \nis to provide a way for suppliers to discharge their Mandate obligation in cases where they \nare unable to secure a supply of SAF, preventing excessive costs being passed on to \nconsumers. It is not intended to be a long-term form of compliance given that it does not \nlead to emission reductions. The buy-out price also effectively sets the maximum price for \nMandate certificates, as it is assumed that a supplier will choose to pay the buy-out price \nrather than supply eligible fuel or purchase certificates at a higher cost. \nIn the consultation, we set out a range of options for the main buy-out price and PtL buy-out \nprice to seek views from respondents which price would be appropriate. We considered that \na low buy-out price would increase the likelihood that suppliers will buy out of their \nobligations, and therefore the possibility that emission reductions from the scheme would be \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n45 \nreduced, while a high buy-out price would not protect consumers against disproportionately \nhigh costs. \nOur evidence suggested that the medium buy-out price option of £2 per litre, or £2,567 per \ntonne, should cover the pessimistic production costs of all SAF types included in the main \nMandate and was therefore proposed to be used as the main Mandate buy-out price. \nSimilarly, we proposed that the PtL buy-out price should be set at £2.75 per litre, or £3,525 \nper tonne. We proposed that these buy-out prices remain in place for the duration of the \nMandate, but are kept under continuous review, and will also be formally reviewed every \nfive years. \nTable 9 Main buy-out price options considered. \nTable 10 PtL buy-out price options considered. \nQuestion 12 \nDo you agree or disagree with the proposed use of the medium buy-out price of £2 \nper litre or £2,567 per tonne for the main mandate, and do you have any evidence to \nsupport your response? \nSummary of responses \nFigure 12.1: Question 12 summary of responses. \n \n17 The buy-out price for development fuels under the RTFO is £0.80 per litre, but as qualifying fuels are \nrewarded with double certificates, this equates to £1.60 per litre, or £2,051 per tonne in the case of \nqualifying SAF. \nOption \nExplanation \n£/tonne \n£/litre \nLow \nRTFO development fuel buy-out price \n£2,051 \n£1.6017 \nMedium \nPessimistic production costs \n£2,567 \n£2.00 \nHigh \nPessimistic production costs plus margin  \n£3,846 \n£3.00 \nOption \nExplanation \n£/tonne \n£/litre \nLow \nMedium option proposed for main obligation \n£2,567 \n£2.00 \nMedium \nPessimistic production costs \n£3,525 \n£2.75 \nHigh \nPessimistic production costs plus margin  \n£5,320 \n£4.15 \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n47 \n 6 \n20 \n21 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n46 \nResponses to this question were split with many respondents either disagreeing or not \nexpressing a preference with the use of the medium buy-out price for the main mandate. \nThe main reasoning provided for this was that the price was too low, with many respondents \nsuggesting the high option should be used, and a few proposing we use a price higher than \nthe options provided. Several respondents suggested that a higher price would better \nsupport investment in and production of SAF, as the buy-out effectively sets the maximum \nprice for Mandate certificates. Other respondents proposed that the buy-out price should \nalign with the price in similar schemes in other regions, in order to avoid negative impacts \non the competitiveness of the UK SAF and aviation industries.  \nMany respondents suggested that additional revenue support is required for the UK SAF \nindustry and highlighted that it is difficult to make a decision on a buy-out price when there \nis no clarity on whether this additional support will be provided. Several respondents set out \nthat if there is no additional revenue support, then the buy-out price will need to increase \neven further to take this into account. A few respondents suggested that a margin is needed, \nbecause the pessimistic cost of production is not actually covered by the medium buy-out \nprice.  \nIn terms of what the buy-out price should be based on, or how it should be benchmarked, a \nfew respondents suggested that the buy-out price should not be significantly higher than the \ncost of production. On the other hand, a similar number of respondents suggested that the \nbuy-out price should be based on evidence from producers and ensure the price is high \nenough to allow their projects to secure the investment they need (producers/suppliers). \nOne supplier suggested that the RTFO buy-out price should be set at the same level as the \nMandate buy-out, to ensure that feedstocks are not taken from the road transport fuel market \nto produce SAF. \nSeveral respondents suggested that a fixed buy-out price is not ideal in a moving market \nand that instead the buy-out price should be linked to a credible market index. A few other \nrespondents suggested that the buy-out will need to be kept under review and updated if it \nis found to be too low or too high. \nSeveral respondents proposed that the Mandate should include legislation to ensure that \nsuppliers cannot pass any additional costs that come from buying out onto airlines, with one \nof these respondents suggesting that the additional cost could be addressed via free UK \nETS allowances. A few respondents suggested that buy-out revenue collected should be \nreinvested back into SAF through grants or through a revenue support mechanism. \nFinally, a small number of respondents proposed that suppliers who buy-out should have to \npay the buy-out price as well as making up their obligated shortfall in following years. \nGovernment response \nThe buy-out price should encourage the supply, and trading, of certificates over the use of \nbuy-out to secure emissions reductions, future-proof against price fluctuations in the fuels \nmarket and set a maximum cost of the scheme.  \nGovernment decision: the main obligation buy-out price will be set at the equivalent \nof £5,875 per tonne, or £4.70 per litre. Given that the obligation is determined in energy \n(see question 40), the buy-out price will be expressed as £0.137 per MJ in legislation. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n47 \n \nThis buy-out price represents a significant incentive to supply SAF into the UK market. It is \nhigh enough to capture a wide range of SAF technologies that are expected to come online \nin the coming years. It will also allow some margin to accommodate price fluctuations that \ncould arise due to plant performance in the early years of operation. This will help support \ninvestor confidence in SAF.  \nA range of sources of evidence informed this decision. Following the second consultation, \nDfT commissioned AIA to update the assumptions on the costs, GHG emissions savings, \nand feedstock demands of SAF types eligible for the SAF Mandate. This work expanded the \nscope of fuels and technologies for which we had cost data and revealed that some had \ngreater costs than the first commission had identified. DfT has also considered the evidence \nprovided through the consultation responses and data received through the administration \nof the Advanced Fuels Fund. As a result of this research, the preferred buy-out price set out \nin the consultation (£2.00 per litre) is no longer considered sufficient to cover the maximum \ncosts of SAF production. It is therefore no longer considered a strong enough incentive to \nsuppliers to produce SAF.  \nA higher buy-out price works alongside the mid-trajectory and HEFA cap to deliver cost-\neffective emission reductions. Together, these minimise the risk of widespread buy-out due \nto over-ambitious targets while a high buy-out price maximises the incentive to suppliers to \nmeet the targets. This strikes the right balance of ambition and deliverability, maximising \nemissions savings with setting a maximum cost for the scheme, ensuring emission \nreductions at an acceptable cost.  \nQuestion 13 \nDo you agree or disagree with the proposed use of the medium buy-out price of £2.75 \nper litre or £3,525 per tonne for the PtL obligation, and do you have any evidence to \nsupport your response? \nSummary of responses \nFigure 17 Question 13 summary of responses. \nTwenty nine of 50 respondents to this question disagreed with the use of the medium buy-\nout price for the PtL obligation. The main reasoning provided for this was that the price was \ntoo low to cover the additional cost of producing PtL SAF and that the high option, or an \noption higher than those provided should be used instead. As with the main obligation buy-\nout price, several respondents suggested that a higher price would better support \ninvestment in and production of SAF.  \nA small number of respondents again suggested that the government should be technology \nneutral and a separate PtL target should not be included in the Mandate. Additionally, two \nrespondents argued that PtL is the least productive use of renewable energy. On the other \nhand, several respondents recognise the renewable electricity needs of PtL and suggest \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n50 \n 6 \n15 \n29 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n48 \nthat the government needs to focus on the scaling of this renewable electricity capacity to \nallow for the development of a PtL SAF industry. \nThe remaining points raised in response to this question align with the responses to the \nprevious question on the main target buy-out price.  \nGovernment response \nThe same principles for setting the buy-out price for the main obligation apply to setting the \nbuy-out price for the PtL obligation. However, PtL is projected to be more costly and there \nis greater uncertainty around setting the price owing to the lower maturity of this pathway.  \nGovernment decision: the PtL obligation buy-out price will be set at the equivalent of \n£6,250 per tonne, or £5.00 per litre. Given that the obligation is determined in energy \n(see question 40), the buy-out price will be expressed as £0.145 per MJ in legislation. \nAs with the main obligation buy-out price, the updated information from AIA and information \nsubmitted by stakeholders in response to the second consultation has shown that the costs \nof producing PtL are greater than first anticipated. The preferred consultation buy-out price \nof £2.75 per litre would not cover the costs of production and, therefore, would not \nadequately incentivise suppliers and producers to produce PtL. The higher buy-out price \nalso reflects the need to provide greater incentive to accelerate the development of this \ntechnology and bring it to commercial scale in line with the targets. \nQuestion 14 \nDo you agree or disagree with the proposal that a buy-out mechanism should be a \npermanent feature of the mandate? \nSummary of responses \nFigure 18 Question 14 summary of responses.  \nTwenty nine of 49 respondents agreed with the proposal for a buy-out mechanism to remain \na permanent feature of the Mandate. The main reasoning provided for this choice was that \nthe buy-out provides a safety net for suppliers in the event that there is no or low access to \nSAF, for example in the case of supply chain issues. A few respondents also highlighted \nthat the option of buy-out has continued to remain available to suppliers within the RTFO \nand this has been an effective policy since the RTFO started in 2008. A small number of \nrespondents stated that they had no issue with the buy-out mechanism remaining \nthroughout the course of the mandate as long as the price was high enough to encourage \nsupply of SAF.  \nOn the other hand, several respondents suggested that while buy-out will be needed in the \nearly years as supply will be low and the SAF sector will not yet be fully established, there \nwill be no need for a buy-out mechanism in a functioning market as there should be no \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n49 \n 29 \n10 \n10 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n49 \nreason for suppliers to not supply SAF. A small number of respondents suggested that rather \nthan having a buy-out mechanism, the Mandate should instead issue fines if a supplier does \nnot meet their obligation. A few respondents suggested that not only the price of the buy-\nout, but also its existence should be subject to periodic review. \nFinally, a small number of respondents again suggested that buy-out funds should be \nredirected back into the SAF industry in the form of grants or contracts for difference \nschemes.  \nGovernment response \nThe buy-out mechanism ensures that suppliers are able to discharge their obligation in \ncases where they are unable to secure a supply of SAF. Even as the market develops and \nmore SAF becomes available, there is still the chance that unexpected spikes in the SAF \nmarket price will occur, or that unforeseen supply chain issues or feedstock shortages may \narise in later years. We therefore view the buy-out as an effective safeguard by setting a \nmaximum cost of the Mandate should such an exceptional circumstance occur.  \nGovernment decision: the buy-out mechanism will be a permanent feature of the SAF \nMandate.  \nFor the mechanism to remain effective, the buy-out price must be set at an appropriate level \n(see the responses to Questions 12 and 13), to prevent suppliers using buy-out as a frequent \ncompliance mechanism. This approach is consistent with the RTFO and has been positively \nreceived by those involved in the scheme.  \nWe do not think it is proportionate to issue fines for suppliers that do not meet their obligation \ndue to unforeseen circumstances, particularly as it may be out of the obligated party’s control. \nHowever, we have proposed to issue civil penalties for intentional non-compliance (see \nresponses to questions 60 and 61).  \nRegarding the suggestion to repurpose buy-out funds to support the SAF industry, the \nMandate will take the same approach as the RTFO; whereby payments go into The \nConsolidated Fund, but this will be kept under review. The government is directly supporting \nthe UK SAF industry in many ways, including through the Advanced Fuels Fund, which has \nawarded £135 million to 13 UK SAF projects, and we have committed to designing and \nimplementing a Revenue Certainty Mechanism for UK SAF projects by the end of 2026.  \nMandate review points \nIn the government response to our first consultation, we indicated that we would include a \nregular review process within the Mandate. Building on this, the second consultation \nincluded information that could be in scope of the reviews, including level of supply against \ntargets; the levels of targets, HEFA cap, PtL obligation and buy-out prices; fraud/non-\ncompliance; feedstock and energy availability; sustainability criteria and GHG emissions \nthreshold; costs and benefits; industry updates; and progress of other decarbonisation \nmodes for aviation. Any formal review would include a consultation process to gather \nstakeholder views. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n50 \nGovernment decision: we will keep the information above under continuous review, \nand official reviews will be conducted and published at least every five years. This \nmeans that a formal review may be carried out before the five-year point, but not after. \nQuestion 15 \nDo you agree or disagree with the information we could include in our reviews? Is \nthere anything you feel we haven’t considered but should? \nSummary of responses \nFigure 19 Question 15 summary of responses. \nThirty three of 41 respondents agreed with the information that could be included in SAF \nMandate reviews. Most respondents did not provide a reason for why they agreed with the \nproposal, but many did provide additional information they believe should be included in \nreviews. Some of the additional aspects respondents thought should be reviewed included: \n• Data on the proportion of SAF supplied under the Mandate produced in the UK; \n• Data on the use of Mandate rewarded SAF to meet UK ETS and CORSIA obligations; \n• Impact of the HEFA cap on the decarbonisation of other sectors; \n• Available feedstocks and feedstocks used to produce SAF under the Mandate, \nincluding impacts of the Mandate on other sectors using waste feedstocks; \n• Impact of the Mandate on connectivity and competitiveness, including passenger \ndemand; \n• The timeframe for compliance and whether this works in practice, or causes any \nadverse administrative issues; \n• International developments; \n• Potential negative impacts such as displaced emissions; \n• Amount of tankering as a result of the Mandate; and \n• LCA emissions of feedstocks, as the calculations of these figures depend on \nchangeable assumptions and variables. \nGovernment response \nGiven the nascent status of the SAF industry, the design of many of the Mandate’s \nparameters have been reliant upon modelling and analytical evidence. We have already \nunderlined the importance of having a review mechanism within the Mandate to amend its \ndesign, should the SAF sector develop in a different way to projected.  \nGovernment decision: to ensure that we can maintain a flexible approach to reviews, \nwe will not set out what information will be included in reviews in legislation.  \nWe need to ensure that we keep a broad set of factors under review such that the Mandate \ncan be revised to effectively meet its objectives.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n41 \n 33 \n8 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n51 \nAs the Mandate is implemented and the market develops, we will ensure that all relevant \nfactors that impact policy design will be reviewed.  \nFlexibility in the review process has been central to arriving at the policy positions set out in \nthis government response; however, to ensure industry and investor confidence in the UK \nSAF market, a high bar must be met for concerns to require a review to one or more \nparameters.  \nThe following considerations will influence whether we decide to make any changes \nfollowing a review:  \n• Level of supply against targets \n• Level of buy-out and the reasons for this  \n• Costs and benefits including carbon savings delivered and costs to industry and \nconsumers \n• Scale and pace of development of the UK and global SAF industry \n• Feedstock and energy availability and future forecasts, including the impacts of or on \nother decarbonisation policies  \n• Fraud and non-compliance plus effectiveness of penalties  \n• Progress of other decarbonisation options for aviation  \n• Wider government policies and strategies  \nQuestion 16 \nDo you agree or disagree with our proposed flexible approach to review timelines? \nSummary of responses \nFigure 20 Question 16 summary of responses. \nTwenty nine of 41 respondents agreed with our proposed approach to keep information \nunder continuous review but conduct and publish official reviews at least every five years. \nSome of the reasoning provided for agreement with this approach was that it is similar to \nthe current approach under the RTFO and that it would allow the government to be reactive \nto market changes and align with the emergence of new information in the industry. \nMany respondents did however suggest that there should be more frequent reviews in the \nearly years of the Mandate with a few proposing reviews every one, two or three years.  \nSeveral respondents suggested that the government should provide a place for stakeholder \nfeedback and take this into account as part of the review process, with a small number of \nrespondents suggesting the Jet Zero Council SAF Delivery Group: Mandate Subgroup as a \npotential forum for useful discussion.  \nSeveral respondents also mentioned the need for certainty to provide investors with \nconfidence that there will be a market for SAF. While these respondents felt that there should \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n41 \n 29 \n3 \n9 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n52 \nbe regular reviews, they also outlined that regular major changes to the policy are likely to \nlower investor confidence and risk plant investments. Conversely to this, a few respondents \nsuggested that the government needs to be prepared to quickly make changes to the policy \nbased on findings from reviews, particularly if it is found that an aspect of the Mandate is not \nfunctioning as planned. \nGovernment response \nOur approach to reviews seeks to balance the need to be structured, to avoid unnecessary \npolicy uncertainty for industry, particularly investors, with flexibility to allow for the \namendment of policy parameters, guidance and/or the legislation once it is evident there is \na need for change. Whenever changes are made to either guidance or legislation, we will \nconsult stakeholders.  \nGovernment decision: we will have a formal review at least every five years, with the \nfirst review to be carried out by 2030.  \nThe first official review must be carried out before 1 January 2030. Meanwhile, we will \ncontinue to monitor all information relevant to the Mandate. The government has also \ncommitted to review the Jet Zero Strategy every five years, with the first in 2027. This \nprocess will also consider the operation and progress of the SAF Mandate, alongside the \nformal five yearly process. \nWe acknowledge that some respondents prefer more frequent reviews during the early \nyears of the mandate and that, given the industry is growing quickly, unforeseen trends may \nemerge that are unprecedented. Given that we will continuously monitor the implementation \nof the Mandate and the development of the SAF market, the government will be able to \nreview as necessary.  \nReviews will take into account the need to continue to align with wider government policy \nand strategies including the Net Zero Strategy, Carbon Budget Delivery Plan and the Jet \nZero Strategy. Any proposed changes will be subject to consultation and will consider \nimplications for the RTFO given the desire from stakeholders to maintain consistent rules \non sustainability, fuel eligibility and how the schemes operate. Alongside the formal review \nprocess, we will continuously monitor all relevant information. \nThe Jet Zero Council has played an important role in supporting the design of the mandate \nand the government views it as a key forum for engaging with stakeholders. This includes \ntesting new ideas, refining policy proposals and seeking feedback. We will continue to use \nthis forum once the Mandate is implemented, giving stakeholders regular opportunities to \nprovide feedback. The continuous collaboration will provide a forum for all those involved in \nthe SAF Mandate to provide feedback on its implementation, regardless of whether a formal \nreview is being conducted or not.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n53 \n2. Eligible fuels and sustainability criteria \nEligible fuel types and definitions \nTo ensure that all aviation fuels are covered by one policy instrument and given that we will \nbe providing support to SAF under the Mandate, we confirmed in the government response \nto the first consultation that no SAF will be eligible for support under the RTFO once the SAF \nMandate is in place. It is therefore necessary that the Mandate legislation accurately defines \nthe scope of aviation fuels. This section sets out which aviation fuels are subject to an \nobligation or eligible for certificates when supplied to the UK as well as the definitions for \ntypes of SAF that will receive different certificates or adhere to specific sustainability criteria.  \nFollowing the first consultation on the Mandate, it was confirmed that fossil aviation turbine \nfuel (avtur) will be subject to an obligation to ensure that the carbon intensity of this fuel \ndecreases over time across the UK. Furthermore, we confirmed SAF that does not meet the \nsustainability criteria will be subject to the obligation. This will deter the use of any SAF that \nfalls below minimum GHG emissions savings threshold or does not meet any of the other \nrequired sustainability criteria which would otherwise lead to a relative increase in emissions. \nThe second consultation proposed that other types of fuel, such as low carbon aviation \ngasoline, would be eligible for certificates providing it meets the sustainability criteria. The \nBiomass Strategy reviewed the potential future availability of sustainable biomass to the UK \nand considered how this resource could be prioritised strategically across the economy to \nhelp achieve the government’s net zero target, and wider environmental and energy security \ncommitments. We recognised that aviation is a hard to decarbonise sector and requires \naction now to start on the path to Jet Zero. \nFor some available feedstocks, there may be uses other than SAF which could offer greater \nGHG savings at potentially lower cost. The SAF Mandate has a statutory requirement for a \nreview at least every 5 years. The reviews will consider the best use of biomass to support \nthe UK’s net zero target and will take into account developments in the evidence base. The \nmandate also has protections in place to ensure that the eligible feedstocks and fuel \npathways deliver genuine carbon savings and adhere to strict sustainability criteria. \nConsultation proposals \nIn the second consultation it was proposed that the supply of fossil aviation fuels other than \navtur will not be subject to an obligation, for example avgas. Sustainable fuel alternatives \nfor aircraft using these fuels are not as technically mature as those for avtur so applying an \nobligation at this stage would be overly burdensome on industry.  \nTo accelerate the development of other low carbon aviation fuels and create additional \nrevenue streams for suppliers, it was also proposed that standard certificates are to be \nrewarded for the supply of:  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n54 \n• low carbon hydrogen; \n• low carbon unleaded avgas; and \n• low carbon ammonia. \nWe previously confirmed that, when replacing avtur, only certified SAF that meets the \nMinistry of Defence (MOD) Defence Standard (DEF STAN) 91-091 and American Society \nfor Testing and Materials (ASTM) D7566 specification will be eligible for incentives under \nthe Mandate. In a similar manner, we proposed that low carbon avgas must meet the DEF \nSTAN 91-090 specification in order to be eligible for support. For hydrogen and ammonia, \nwe stated our intention to amend the Mandate legislation fuel definitions to include relevant \nstandards once they have been developed.  \nQuestion 17 \nDo you agree or disagree that low carbon avgas, low carbon ammonia and low carbon \nhydrogen aviation fuel, should be eligible for incentives without being subject to \nobligation providing they meet the sustainability criteria? \nSummary of responses \nFigure 21 Question 17 summary of responses. \nMost respondents agreed with the proposal to reward the supply of low-carbon hydrogen, \navgas and ammonia with certificates. Respondents broadly agreed that allowing these fuels \nas eligible to receive certificates would incentivise their uptake and could accelerate their \ntechnical development. Others reflected on the need to encourage a range of fuel types to \nachieve aviation decarbonisation, in particular hydrogen, which could play a prominent role \nin the future. They added that it also provides a route for all aviation sectors, such as general \naviation using avgas, to decarbonise. However, some respondents felt that the Mandate is \nnot the most appropriate mechanism to incentivise these fuels.  \nThe key reasons for disagreeing were that including these fuels could hinder the \ndevelopment of other SAF (avtur) pathways and dampen the certificate price, as well as the \nneed for further development of appropriate technical standards before these fuels can be \nused safely. Other comments included: that ammonia was not relevant for aviation; that \nfurther evaluation of the emissions arising from ammonia use should be carried out first; and \nthe need for clearer definitions of ammonia and hydrogen. \nSeveral respondents suggested that fossil versions of these aviation fuels should be \nobligated, for example fossil hydrogen or fossil avgas. They considered that owners and \noperators of general aviation (GA) aircraft should be subject to the costs resulting from the \nMandate and have a requirement to decarbonise. If not, the SAF Mandate may not be \nconsidered equitable or adhere to the polluter pays principle.  \nConversely, a few respondents were in agreement that fossil avgas, hydrogen and ammonia \nshould not be obligated. Some of these respondents went further to suggest that where low \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n44  \n 34 \n4 \n6 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n55 \ncarbon versions did not meet the sustainability criteria the obligation should not apply here \neither. The reasoning was based on experience from the RTFO, where suppliers have to \nrisk high costs in the event the fuel did not meet the sustainability criteria thereby creating \nlittle incentive to supply these fuels.  \nThree respondents asked for the inclusion of electricity in the Mandate given that it could \nplay a role in short haul aviation.  \nGovernment response \nGovernment decision: Low carbon avgas and low carbon hydrogen for aviation will \nbe eligible for standard certificates under the mandate. Low carbon ammonia, \nhowever, will not be eligible for certificates under the mandate. These fuels will be \neligible for certificates if they meet the relevant technical and sustainability criteria, \ndescribed in the remainder of this chapter. If they do not meet the technical or \nsustainability criteria, they will become subject to an obligation. \nThe supply of fossil avgas and fossil hydrogen will not be subject to an obligation. \nThe government recognises that a variety of technologies will be required to meet net zero \naviation by 2050, as outlined in the Jet Zero Strategy. Allowing low carbon avgas and low \ncarbon hydrogen to receive certificates, which can then be used by obligated suppliers to \nmeet their obligations, is intended to close the price gap between fossil fuel and the cost of \nproducing and supplying low carbon aviation fuel, while also potentially accelerating their \ndevelopment. \nWith respect to low carbon avgas and hydrogen that does not meet the sustainability criteria, \nwe will place an obligation on this consignment in line with our approach confirmed for low \ncarbon avtur in the government response to the first consultation. This is to deter the use of \nany low carbon aviation fuel that falls below this threshold or does not meet any of the other \nrequired sustainability criteria as this will lead to a relative increase in emissions. The \nAdministrator (see section 3) will work closely with suppliers to ensure that they are aware \nof the requirements to meet the sustainability criteria and be eligible for certificates.  \nWe do not believe that it is currently appropriate to obligate fossil avgas and hydrogen in the \nsame way that fossil avtur is obligated. The development of low carbon versions of these \nfuels is in its relative infancy compared to avtur, therefore obligating these would place a \ndisproportionate burden on suppliers and users of these fuels. We will review this position \nas the low carbon fuel sector develops. \nThe primary objective of the SAF Mandate is to reduce carbon emissions by using \nsustainable feedstocks, rather than reducing other pollutants in fuel. Therefore, unleaded \navgas, such as UL91, will be treated the same as leaded avgas. That is, if the fuel is made \nfrom sustainable feedstocks that meet the sustainability criteria in the future, it will be eligible \nfor standard certificates. However, if it is made from fossil sources that do not meet the \nsustainability criteria, it will not be subject to an obligation.  \nThe Mandate targets we have set show ambition and allow sufficient space in the market \nfor a range of SAF from different technologies and feedstocks. We therefore do not view the \ndampening of the certificate price as an issue. Further, there is no low carbon avgas or low \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n56 \ncarbon hydrogen currently being supplied to UK aviation. Should low carbon avgas become \ncommercially available, given that avgas accounts for less than 0.1% of total aviation fuel \nsupplied to the UK18, any certificates gained through its supply will have minimal impact on \nthe market pricing. Hydrogen aircraft are still under development with none to date certified \nfor use in commercial passenger services. The roll-out of hydrogen and/or battery electric \naircraft will take time with avtur (included blended with SAF) continuing to make up the \nmajority of aviation fuel until at least 2050.  \nFrom our engagement with the aerospace manufacturing sector we are not aware of any \nmajor programmes currently focussed upon ammonia fuelled aircraft. We have also taken \nregard to the findings of the FlyZero project which recommended focusing on hydrogen \nrather than ammonia in developing commercial zero emission aircraft19. Consequently, we \nare not including low carbon ammonia as an eligible fuel under the Mandate at this time but \nwill keep this position under review should evidence on it change.  \nWe will consider the inclusion of electricity if future evidence indicates this to be appropriate.  \nDefinitions of fuels \nConsultation proposals \nIn the consultation we proposed that low carbon avgas and hydrogen must meet relevant \ntechnical standards to be eligible in the Mandate. We also we set out definitions for HEFA \nand PtL so that suppliers are clear which fuels are subject to the HEFA cap and those that \nare eligible to receive PtL certificates.  \nWe proposed that the HEFA cap applies to any fuel using a segregated oil or fat as a \nfeedstock, where a segregated oil or fat is defined as “a material that is capable of being \nused as a transport fuel directly, after extraction, or after conversion by transesterification, \ninto a usable fuel, irrespective of any blend wall limits on use”. This includes used cooking \noil and tallow but would exclude tyre pyrolysis oil. \nWe proposed that fuel eligible for PtL certificates is low carbon avtur for which the energy \ncontent of the fuel is derived from renewable (excluding bioenergy) or nuclear energy \nsources. Fuels produced using fossil energy would not be eligible.  \nWe also proposed that input CO2 has not been deliberately produced for the sole purpose \nof creating a fuel, where CO2 can be derived from atmospheric DAC or naturally-\noccurring/geothermal sources, biological sources or from fossil sources (for example, waste \nflue gases from coal and natural gas power generation).  \nWhere carbon sources other than CO2 are used in the production process, energy would \nbe imparted on the final fuel and therefore the resultant fuel would not be considered a PtL. \nFor example, carbon monoxide (typically generated where incomplete combustion has \noccurred) contains energy – so if carbon monoxide from combustion of biomass was used \n \n18 https://www.gov.uk/government/statistics/petroleum-chapter-3-digest-of-united-kingdom-energy-statistics-\ndukes  \n19 FlyZero - Aerospace Technology Institute (ati.org.uk)  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n57 \nthe resultant fuel would be a biofuel, while using carbon monoxide from a waste fossil gas \nwould be classed as an RCF. \nQuestion 18 \nDo you agree or disagree that the definition of aviation fuels should include relevant \ntechnical specifications? \nSummary of responses \nFigure 22 Question 18 summary of responses. \nMost respondents agreed that the definition of aviation fuels in legislation should include the \nrelevant technical specifications. Those that agreed underlined the importance of \nmaintaining safety and performance standards and that any low carbon fuel used in aviation \nmust meet established industry standards. Furthermore, these respondents felt that clearly \nstating the technical standard in the definition of fuel will provide clarity to industry on which \nfuels are eligible from the onset. Many respondents referenced ASTM D7566 as the \nappropriate standard for the Mandate to include in its definitions for avtur. Though, one \nrespondent suggested that reference to specific annexes would be too rigid. It was \nsuggested that in cases where a synthetic standard does not exist, for example avgas, it \nmay be necessary for the Mandate to reference a future standard and update legislation as \nappropriate.   \nAmong those that disagreed, there was concern that including a specification in the legal \ndefinition of aviation fuels would bind industry to specific standards without the appropriate \npolitical or legal oversight, which further runs the risk of error in the way standards are \nreferred to. Furthermore, referencing specific standards such as ASTM or DEF STAN, would \nunnecessarily exclude certain types of fuel that would otherwise be accepted by the aircraft \nand engine original equipment manufacturers (OEMs), for example those covered by \nCanadian, Russian or Chinese aviation fuel specifications.  \nOne respondent emphasised the difference between requiring SAF to meet UK DEF STAN \n91-091 and ASTM D7566 to be eligible for certificates and including the relevant technical \nspecifications in the legal definition of aviation fuels. In a similar manner, one respondent \nstated that it is unnecessary to include that technical standard in the definition given that all \nSAF produced is already required to comply with relevant technical standards. \nGovernment response \nWe had previously confirmed that avtur, low carbon or otherwise, must be certified in line \nwith DEF STAN 91-091 and ASTM D7566. This will ensure that safety and performance \nstandards are not compromised through the introduction of new decarbonisation \ntechnologies. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n35  \n 27 \n1 \n7 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n58 \nGovernment decision: in the Mandate statutory instrument, aviation fuels will include \nthe relevant technical specifications in their definition.  \nTo maintain consistency with the RTFO Order and other domestic and international \nregulations, we will use established industry standards when defining different types of \naviation fuel. For example, avgas will be defined as meeting one of the following standards:  \n• ASTM International standard D910 (as revised or re-issued from time to time); \n• Ministry of Defence standard 91–90 (as revised or re-issued from time to time); or \n• a standard that is equivalent to either of the standards mentioned in the first two \nbullets. \nThis is the same approach currently adopted under the RTFO Order and we intend on using \nthe same definitions. Adopting this approach will address key responses in the consultation, \nspecifically that the fuel should meet established industry standards, the definition refers to \nfuture revisions of standards to ensure keep pace with latest developments and that \nequivalent standards accepted by OEMs in other parts of the world would be accepted.  \nIncluding standards within the legal definition of fuels is standard practice when legislating \nfor regulations that concern transport fuels. This has worked well under the RTFO and we \ntherefore do not intend to deviate from this common approach for aviation fuels within the \nMandate legislation.  \nHydrogen differs on its technical standards due to it comprising of just one molecule, \nwhereas avtur or avgas which are made up of a variety of hydrocarbons of different lengths \nand isomers. As a result, no such technical standards exist and the quality of fuel is instead \nsimply enforced by the need for companies to be accurate in what they supply. Should a \ntechnical standard be introduced at a later stage we will consider if it is appropriate to require \nthat low carbon hydrogen rewarded under the SAF Mandate meets this standard. \nQuestion 19 \nDo you agree or disagree with the proposed definition of HEFA? If not, please provide \nan alternative definition? \nSummary of responses \nFigure 23 Question 19 summary of responses. \nMany respondents agreed with the proposal to link the definition of HEFA to feedstocks \nrather than the production pathway. Generally, these respondents recognised that the \nnegative impacts of an over reliance on this fuel is driven by the demand on feedstock rather \nthan the conversion process itself. Some of those in agreement did however underline the \nimportance of monitoring the definition to minimise the risk that “loopholes” can be found to \navoid the HEFA cap. This approach is current practice under the RTFO.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n41  \n 26 \n4 \n11 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n59 \nHowever, several respondents disagreed with the proposal on the basis that using a \ndefinition of HEFA that deviates from the industry standard leads to confusion and potentially \nunintended consequences related to aviation fuel quality standards. These respondents \npreferred that the definition referenced ASTM D7566 specification, or alternatively make an \nexplicit point that this definition concerns HEFA feedstock that will be capped.  \nA few respondents instead preferred a more flexible approach whereby DfT would assess \neach individual feedstock to determine whether it is subject to the HEFA cap rather than \nsetting a definition in legislation.  \nGovernment response \nAs explained in the section on the HEFA cap, HEFA feedstocks that are most relevant for \nuse under the Mandate, in particular UCO, are a finite resource and there are competing \ndemands across the globe from other modes of transport, particularly road fuel use. In the \nfuture, there will be increasing competition for their use in SAF as other countries’ mandates \nand targets kick-in. Technology pathways will need to be developed that can unlock new \nfeedstocks to supply SAF at scale and help us meet our decarbonisation goals. The HEFA \ncap is therefore to create space for the development of new advanced technologies and \nencourage investment. \nThere is broad agreement between the government and respondents that we should link the \ncap to certain feedstocks that use this production pathway. This is in line with our objectives \nof encouraging new feedstocks. \nGovernment decision: any fuel that uses a segregated oil or fat as a feedstock will be \nsubject to the HEFA cap. This will limit the amount of the certificates that can be used \nto discharge the main obligation in line with percentage cap set out in response to \nquestions seven, eight and nine.  \nWe will use the following definition of segregated oil or fat, as originally proposed in the \nconsultation; “a material that is capable of being used as a transport fuel directly, after \nextraction, or after conversion by transesterification, into a usable fuel, irrespective of any \nblend wall limits on use”.  \nThis definition will ensure that the cap only includes feedstocks that are currently widely \nused in the HEFA process or for existing transport fuels. It will allow other more novel \nfeedstocks using the HEFA production pathway, such as tyre pyrolysis oil, to avoid having \nits use curtailed.  \nWe understand that there are concerns that using this definition deviates from the ASTM \ndefinition of HEFA. However, the legislation will specifically refer to segregated oils and fats \nto avoid inconsistency with other specifications. We will ensure that guidance clearly outlines \nthat the HEFA cap only applies to these specific feedstocks.  \nWe will continue to review the impacts of key feedstocks as the SAF market develops and \namend the definition of the HEFA feedstock cap if new evidence justifies any changes.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n60 \nQuestion 20 \nDo you agree or disagree with the proposed definition of fuels that will be eligible for \nPtL certificates to be redeemed against the PtL obligation? \nSummary of responses \nFigure 24 Question 20 summary of responses. \nMost respondents either agreed with the proposed definition of PtL outright or broadly \nagreed and suggested amendments on specific aspects. One of the main points of \ndiscussion was regarding CO2 eligibility where respondents generally agreed with the \ngovernment proposal to allow a wide range of sources initially to kickstart the PtL market. \nHowever, some respondents suggested that the definition should be revised in the future to \nlimit eligibility to biogenic and DAC sources once the market is technically and commercially \nadvanced. Respondents pointed to the EU approach where waste fossil CO2 is eligible until \n2041. However, a few respondents were concerned with the proposal to include waste fossil \nCO2 as this could create a financial incentive for ongoing fossil CO2 emissions.  \nRegarding the proposed requirement that CO2 has not been deliberately produced for the \nsole purpose of creating a fuel, a few respondents recommended the wording should be \nchanged as it currently excludes CO2 that has been produced during the SAF production \nprocess. As a result, this would lead to inefficient SAF production plant design whereby CO2 \nproduced during SAF that has been captured must be stored rather than recycled back into \nthe production process to produce PtL, meanwhile CO2 produced in other industrial \nprocesses would be eligible.  \nA further amendment suggested by a couple of respondents from the nuclear industry was \nto include reference to direct heat for PtL production. These respondents regard the use of \nheat as a proven and efficient energy source which they believe should be referenced \nexplicitly in the PtL definition.  \nOf those that disagreed with the definition, respondents urged the government to include a \nbroader range of eligible energy sources. Specifically, that biogenic energy sources should \nbe eligible for PtL certificates, or more broadly hydrogen that meets the Low Carbon \nHydrogen Standard (LCHS) regardless of energy source. \nAlthough not a direct response to the PtL definition, several respondents showed a \npreference that any guidance on energy allocation where there is a mixed source of input \nenergy and/or feedstock is the same as that of the RTFO. Similarly, one respondent was \nconcerned with the lack of explicit reference to co-processing of PtL in the proposed \ndefinition, which would exclude existing fossil fuel production facilities that could be partially \nrepurposed to co-process renewable inputs to produce PtL alongside conventional fossil \nfuel.  \nOther comments in the responses included: \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n47  \n 33 \n2 \n12 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n61 \n• Revising the wording “input raw materials must contain no usable energy” to “input \nraw material must contain no usable combustion energy”;  \n• Recognition that the definition excludes the use of carbon monoxide as a feedstock; \nand  \n• Stating that there is no need for a PtL definition at this stage. \nGovernment response \nGovernment decision: Fuel eligible for PtL certificates will be defined as low carbon \navtur for which the energy content of the fuel is derived from renewable (excluding \nbioenergy) or nuclear energy sources. Carbon can be derived from atmospheric or \nnaturally-occurring/geothermal sources, biological sources or from waste fossil \nsources. \nThis definition therefore remains as proposed in the consultation. It will ensure that we \nincentivise this strategically important type of SAF while ensuring the eligibility is wide \nenough for PtL to scale at a rate needed to meet net zero targets. It also maintains \nconsistency with the RTFO. \nFurther implications of this definition are:  \n• energy can be either from electricity or direct heat; \n• fuels produced using fossil energy would not be eligible;  \n• as the available energy source comes from electricity or heat, input raw materials \nmust contain no usable energy. This means the only eligible carbon source is CO2. \n• hydrogen as a fuel used for combustion or in a fuel cell would not be eligible for PtL \ncertificates. \nWe are pleased that respondents generally agreed with having a wide range of carbon \nsources eligible for PtL production that align with the current criteria for Renewable Fuels of \nNon-Biological Origin (RFNBOs) under the RTFO. Allowing waste fossil carbon to be used \nwill facilitate the scale up of PtL production plants and create synergies with industrial \nfacilities that do not have access to CO2 storage. This will be particularly important during \nthe initial years of the Mandate, while the CO2 transport and storage (T&S) network is being \ndeveloped.  \nCarbon sources are assumed to be zero GHG emissions at the point of collection. With \nrelation to waste fossil CO2, this is only the case where emitters must not claim an emission \nreduction. Given that industrial sectors will have their own requirements to decarbonise, \nthrough the UK ETS or otherwise, we do not consider that eligibility of waste fossil CO2 will \ncreate an ongoing incentive. However, it offers an opportunity for aviation to decarbonise \nwhile these sectors are transitioning to net zero. While we recognise that using atmospheric \ncarbon from DAC will be important in the longer term it is currently more expensive than \ncapturing carbon from point sources. Limiting eligibility to just this CO2 source at the outset \nwould therefore hinder the development of the PtL sector, ultimately leading to less SAF on \nthe market and lower emission reductions. We will keep this under review and will consider \nany new emerging evidence on whether it would be appropriate to phase out point source \ncarbon and focus support on DAC. \nAs noted above, eligible energy sources are renewable (excluding bioenergy) or nuclear, \nwhere energy is defined as either electricity or heat. We will not extend the definition to \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n62 \ninclude bioenergy. This is because it is an inefficient process of generating energy when \ncompared to other low carbon energy sources. Therefore, we do not want to incentivise \nenergy production pathway by classing the final fuel as a PtL. If bioenergy is used, the \nenergy content will be derived from biomass and would therefore be classed as a biofuel.  \nWe will allow the recycling of CO2 produced during the SAF production to produce additional \nSAF, as this will maximise the emissions savings from feedstocks. We will provide full details \nof carbon accounting in this situation in guidance, which will be published separately. The \nguidance will also cover other points raised by respondents in this section, including energy \nallocation (which is explained in the following section), the eligibility of co-processing and \nexplicit exclusion of carbon monoxide.  \nLow carbon energy criteria  \nConsultation proposals \nIn the consultation we proposed that the SAF Mandate should adopt criteria for PtL fuel \nconsistent with those currently used for RFNBOs under the RTFO. That is, the default \nposition is assumed to be that where electricity used to produce the fuel is derived from the \nnational grid. The proportion of the final fuel eligible for certificates will be determined by the \nproportion of low carbon electricity in the grid mix. For the purpose of the Mandate, low \ncarbon electricity includes renewable (but not bioenergy-derived) or nuclear derived \nelectricity. For example, the average UK grid in the third quarter of 2023 was 41.5% eligible \nlow carbon electricity – so 41.5% of a PtL fuel made using electricity derived from the grid \nwould be eligible for support under the Mandate20.  \nThe exceptions to this are if a production site is connected to an electricity grid that meets \nthe criteria for regionality21, when regional grid averages can be used, or if the renewable or \nnuclear electricity is considered additional22.  \nNuclear energy is not supported under the RTFO. However, we proposed the guiding \nprinciples will align with those for renewable energy, while the details on compliance will be \nset out later in guidance.  \nQuestion 21 \nDo you agree or disagree that the SAF Mandate should adopt the criteria concerning \nadditionality for RFNBOs that aligns with the RTFO? \n \n20 The actual grid average to be used in the calculation would be taken as an annual grid average, not quarterly.  \n21 If the electricity grid a production site is connected to can be reasonably considered to be a distinct electricity \ngrid from the relevant national grid, suppliers may use data from that electricity grid rather than the national \ngrid in determining the portion of their fuel which is defined as a PtL. \n22 Additionality, as defined in the RTFO, is renewable (or nuclear) energy that would not have been available \nto the grid in the absence of power demand from the RFNBO plant in question. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n63 \nSummary of responses \nFigure 25 Question 21 summary of responses. \nMost respondents agreed with the proposal to adopt additionality criteria for PtL fuels that is \nthe same as the RTFO criteria for RFNBOs. Of those that agreed, four stated that they \nmostly agree. Those that agreed generally held a view that the Mandate should maintain \nconsistency with the RTFO Order where possible to maintain a level playing field between \nthe two schemes. Furthermore, these respondents highlighted that many PtL producers will \nalso produce fuel eligible under the RTFO, so the same rules should apply. Several \nrespondents noted that introducing these additionality rules for PtL will ensure genuine \ndecarbonisation and avoid shifting emissions from between sectors.  \nHowever, a few respondents noted that, while the mandate and RTFO rules should be \naligned, the RTFO rules must be updated. These respondents felt that the current \nrequirements of additionality under the RTFO Order are too restrictive, which is evidenced \nby the limited amount of RFNBOs supplied under the RTFO to date. In particular, \nrespondents urged the government to extend the temporal correlation requirement from 30 \nmins to 1 month to align with the EU. Several respondents suggested that the mandate \ninstead aligns with the requirements of the Low Carbon Hydrogen Standard (LCHS) to \nmaintain one standard for low carbon hydrogen across the UK.  \nThose that disagreed outright did so for similar reasoning, stating that additionality \nrequirements would limit commercial-scale production due to investment being directed to \nthe EU where rules are less stringent. Furthermore, the additionality rules will further \nincrease the cost of PtL in the UK and add complexity for suppliers complying with the \nmandate.  \nFinally, a couple of respondents suggested that the mandate should adopt the RTFO \nadditionality rules with the further requirement of only allowing imported hydrogen or \nRFNBOs from countries where the grid is sufficiently decarbonised, to ensure demand does \nnot increase emissions by displacing renewable electricity use in other countries.  \nGovernment response \nIt is vital that the Mandate accurately accounts for carbon emissions and delivers genuine \nemission reductions. The rules concerning the use of energy under the RTFO Order ensure \nthat the supply of RFNBOs accurately account for the carbon emissions and reflect the \namount of renewable energy used to produce the fuel. These rules are in place to ensure \nthat the production of RFNBOs does not divert energy from existing applications, which \nwould likely be replaced with fossil energy sources leading to increased GHG emissions.  \nWe will uphold the same values under the Mandate to ensure that the scheme does not \nhave indirect impacts on other sectors.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n42  \n 29 \n3 \n9 \n1 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n64 \nGovernment decision: In line with the consultation proposals the SAF Mandate will \nadopt the same rules around energy allocation as the RTFO applies to RFNBO \nproduction.  \nThis means that if energy is taken from the grid, the carbon intensity of the energy and \nproportion of resultant fuel that is eligible for certificates is linked to the characteristics of the \ngrid. In special cases, such as where an electricity grid meets criteria for regionality, or where \nenergy is additional, different rules apply (see Figure 26).  \nIn the UK, it is expected that using grid electricity to produce a PtL fuel would not meet the \nminimum GHG emissions savings threshold (see question 11) as the grid is not yet \nsufficiently decarbonised. Until the UK grid is sufficiently decarbonised, domestic PtL \nproducers will either need to be connected to a regional grid or use additional energy23. We \nwill adopt the same guidance that is already in place for the RTFO24 which explains how \nRFNBOs are defined and treated under the scheme and how additionality can be \ndemonstrated in the context of renewable electricity used as an energy input25.  \nAlthough the guidance includes examples of specific use cases, prospective PtL producers \nand/or suppliers are strongly encouraged to contact the department as early as possible \nduring the development process to ensure that the design meets our requirements for \nadditionality. These rules apply whether the fuel or input energy is domestic or international.  \n \nFigure 26 How different parameters are accounted for when determining supplying PtL under different electricity supply \nscenarios.  \n \n23 Renewable (or nuclear) energy that would not have been available to the grid in the absence of power \ndemand from the RFNBO plant in question. \n24https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1164946\n/rtfo-guidance-for-renewable-fuels-of-non-biological-origin.pdf \n25 Note that the RTFO does not support nuclear energy which will need separate guidance developed for the \nSAF Mandate and is explained in response to question 22. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n65 \nWe recognise that some respondents raised concerns about how the energy rules are \nimposed, or how the requirement for additionality in many countries would apply, and its \nimpact on the ability for PtL to scale up.  \nIt is imperative that the Mandate delivers genuine emission reductions, rather than simply \ndiverting existing renewable energy production from one sector to another. Under the RTFO, \nthese rules have been refined over time to ensure that suppliers have maximum flexibility to \nmeet the requirements and cost effectiveness for suppliers when producing RFNBOs, while \nstill meeting the legal requirements of the Energy Act 2004. \nThe additionality principles in the LCHS are compatible with the RTFO and Mandate \ninterpretation. Although the LCHS does not require additional energy to be used, there is a \ncommitment to incentivise and reward projects that meet the additionality principles.  \nQuestion 22 \nDo you agree or disagree that additionality rules should be introduced for nuclear \npower that follow the same principles as those currently applied to RFNBOs in the \nRTFO? \nSummary of responses \nFigure 27 Question 22 summary of responses. \nMost respondents agreed what where PtL fuels are produced using nuclear energy, \nadditionality criteria should apply. The predominant reason for agreeing with this proposal \nwas that it supports technology neutrality by placing nuclear energy on a level playing field \nwith renewable energy. A couple of respondents also noted that additionality rules will \npromote new nuclear deployment and ensure genuine emission reductions. Other \ncomments from those that agreed included, making sure that new nuclear is easy to deploy \nand introducing bespoke additionality rules that meet the needs of the nuclear industry.  \nA few respondents, however, preferred an approach that aligns with the LCHS or the EU for \nreasons based on maintaining consistency in the UK standards and ensuring the UK \nremains competitive in relation to investment in hydrogen production.  \nAs with renewable energy, the main concern from those that disagreed was that additionality \nrules would prevent the scale up of hydrogen production due to strict criteria. In particular, if \nthe rules applied mean that only new nuclear is eligible, this would remove a viable route of \nrepurposing existing nuclear to producing hydrogen or SAF. This could be mean less eligible \nnuclear energy is available given the time and money it takes for new nuclear plants to be \nfinanced and permitted.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n30  \n 21 \n2 \n5 \n2 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n66 \nGovernment response \nThe specific rules on the use of energy are to ensure that the final fuel is accurate, both in \nterms of carbon intensity and the proportion of which is eligible for certificates.  \nGovernment decision: we will introduce specific rules around the use of energy for \nPtL fuels using nuclear as its energy source. These rules will follow the same \nprinciples as those already in place for renewable energy, used to produce RFNBOs \nunder the RTFO, including additionality.  \nWe endeavour to keep nuclear and renewable energy on a level playing field when \ndetermining the amount of certificates to be rewarded for the supply of PtL. This means that \nwhere nuclear energy is additional, the grid intensity will not be used and the proportion of \neligible fuel will be allocated on the proportion of additional nuclear energy used to produce \nthe fuel.  \nWe understand there are concerns that such requirements may hinder the scale up of \nnuclear derived SAF as some respondents understood this to mean that new nuclear \nfacilities would need to be built to meet the additionality requirement. However, we are keen \nto maximise the opportunity for existing nuclear plants to be used where it fits with our \ndefinition. One possible scenario could be avoiding curtailment or wastage.  \nWe are developing specific guidance around what is considered to be additional and how \nsuppliers can demonstrate this. Government will continue to work with the nuclear industry \nand other interested parties to ensure that the resulting compliance rules are practical, well-\nunderstood and meet the requirements set by the Energy Act 2004.  \nUse of hydrogen in SAF production \nGovernment proposals \nHydrogen is typically used in SAF production either as a process input, where it does not \ncontribute to the final energy content of the fuel, or as a precursor26, where it does contribute \nto the final energy content of the fuel.  \nWe proposed that where hydrogen is used as a precursor, it must be low carbon which was \ndefined as hydrogen derived from renewable or nuclear energy, biohydrogen from wastes \nor residues and RCF hydrogen27. This is the same requirement as the RTFO but with the \naddition of nuclear electrolytic hydrogen as an eligible source. Where hydrogen is used as \na process input, no further eligibility criteria will apply beyond the final fuel meeting the \nminimum GHG savings threshold. We also welcomed evidence from respondents on the \nrole of CCUS-enabled hydrogen in SAF production – the eligibility of which in the mandate \nwould require changes to primary legislation.  \n \n26 In the consultation, we referred to hydrogen as a feedstock. Where hydrogen is derived directly from \nbiomass or waste fossil sources, these materials are the feedstock not hydrogen. In this document we will \ntherefore refer to it as a precursor where it contributes energy and atoms to the final fuel. \n27 In order to be eligible, RCF hydrogen pathways require substantial CCS of the otherwise emitted carbon.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n67 \nThe distinction between a process input and precursor is not always definitive. In some \ncases, during the fuel upgrading (or hydroprocessing) process, some hydrogen used as a \nprocess input to remove impurities may end up contributing atoms to the final fuel, thereby \nbecoming a precursor, as per current definition in the RTFO. In the consultation we proposed \nthat suppliers must determine the amount of hydrogen in the hydroprocessing step that \ncontributes both atoms and energy of the fuel, unless eligible low carbon hydrogen is used. \nQuestion 23 \nDo you agree or disagree that, where hydrogen is used as a feedstock, eligibility \nshould be limited to biohydrogen derived from wastes or residues, RCF hydrogen \nand hydrogen derived from renewable and nuclear energy (when legal powers allow)?  \nSummary of responses \nFigure 27 Question 23 summary of responses. \nMost respondents did not agree with the proposed feedstock eligibility criteria for precursor \nhydrogen. Instead, they preferred an approach whereby any hydrogen production pathway \nwith a lifecycle analysis that meets the minimum GHG savings threshold should be eligible, \nregardless of the feedstock. Respondents felt that specifying eligible feedstocks and \nproduction pathways would not represent a technology neutral approach and introduces \nunnecessary complexity. Instead, by simply assessing eligibility on the carbon intensity of \nthe hydrogen production, SAF producers would have greater flexibility without impacting the \nsustainability objectives of the Mandate.  \nRespondents stated that this approach would be more in line with the LCHS, which many \nbelieved should be the reference for hydrogen eligibility in the Mandate. These respondents \nwere keen to see consistency in standards across government departments and certainty \nthat hydrogen supported under DESNZ schemes, for example the Hydrogen Production \nBusiness Model, would be eligible in SAF production. Some noted that DESNZ are currently \ndeveloping a certification scheme that is aimed at facilitating international trade of hydrogen \nthat meets the LCHS.  \nMany respondents went further to explain that one key benefit of aligning with the LCHS or \ntaking a technology approach is that it would potentially unlock eligibility of steam methane \nreforming of natural gas with CCUS (referred to as CCUS-enabled hydrogen). These \nrespondents recognised that CCUS-enabled hydrogen is expected to have among the \nlowest levelised costs of all low carbon hydrogen production routes so excluding CCUS-\nenabled hydrogen will limit availability of hydrogen and increase costs of SAF in the UK. \nTherefore, it was claimed that exclusion of CCUS-enabled hydrogen would go against a key \nobjective of the GHG incentive of the Mandate to deliver emission reductions at the lowest \ncost. Additionally, CCUS-enabled hydrogen was viewed as a key technology that will enable \nthe SAF industry to scale initially while the cost of other hydrogen production routes is still \nhigh. Respondents therefore urged the government to amend the Energy Act (which provide \nthe primary powers for the Mandate) to permit CCUS-enabled hydrogen as an eligible \nsource.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n50  \n 12 \n3 \n35 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n68 \nA few respondents explicitly noted opposition to the inclusion of CCUS-enabled hydrogen \nas a feedstock. Reasons included that it would continue to incentivise natural gas extraction, \nthere is high risk of methane leakage, and that sufficient hydrogen feedstock and production \npathways exist to meet SAF demand without the need for CCUS-enabled hydrogen.  \nFinally, a couple of respondents were against the inclusion of RCF hydrogen as it was not \nconsidered a sustainable feedstock. A small number of other respondents felt that only \nrenewable electrolytic hydrogen should be eligible.  \nGovernment response \nWe recognise that many respondents disagreed with the proposal to define low carbon \nhydrogen by the production pathway and instead prefer an approach whereby hydrogen \nmust simply meet a carbon intensity threshold. However, as we want to ensure that we are \nconsistent with our approach across all feedstocks and to maintain a level playing field, we \nwill implement the same criteria as our wider feedstock eligibility criteria, which specifies \ncertain production routes and is line with what our primary powers allow us to do.  \nGovernment decision: where hydrogen28 contributes to the energy content of the final \nfuel it must be hydrogen derived from renewable or nuclear energy, biohydrogen \nderived from wastes or residues, or RCF hydrogen. Where hydrogen does not \ncontribute to the energy content of the fuel (i.e. is considered a process input), there \nwill be no eligibility criteria beyond the final fuel meeting the minimum GHG savings \nthreshold. \nMany respondents requested that the Mandate criteria aligns with that of the LCHS, which \nhas been designed to underpin the growth of a low carbon hydrogen economy. The standard \nis technology agnostic, and sets out certain sustainability criteria which low carbon hydrogen \nproduction must meet, including a maximum carbon intensity of 20 gCO2e/MJ. Whereas the \nprimary powers of the RTFO and the Mandate only permits certain routes of hydrogen \nproduction to be eligible under those schemes. As with the Mandate, the LCHS is subject to \nregular review to ensure that it remains fit for purpose and keeps pace with our growing \nunderstanding of how new technologies work in practice. We will continue to use these \nreviews to see how the schemes can align while still maintain the specific objectives of the \nindividual policies.  \nIn the consultation we asked for further evidence on the use of CCUS-enabled hydrogen in \nSAF production (noting this would require an amendment to primary legislation). Our \nanalysis projects low carbon hydrogen demand for SAF will range between 1.3 TWh and \n2.6 TWh by 203529, though the actual demand could be significantly lower depending on the \nlevel of imports. DESNZ, which is responsible for planning hydrogen production capacity to \nmeet the needs of the hydrogen economy, has indicated that the UK’s first 10 GW of capacity \ncould produce around 60 TWh/yr of low carbon hydrogen, assuming the deployment of 4 \nGW of CCUS-enabled fossil hydrogen and 6 GW of electrolytic hydrogen30. Therefore, there \n \n28 This hydrogen is referred to as a precursor, where the material that made the hydrogen is considered the \nfeedstock (for example biomass or low carbon energy).  \n29 Actual demand could be lower or higher depending on the level of imports of SAF. \n30 https://www.gov.uk/government/publications/hydrogen-production-delivery-roadmap  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n69 \nwill be a range of hydrogen pathways producing at a commercial scale within the UK to \nsupply to the SAF sector for use as both a precursor or a process input.  \nAnother key point raised about the exclusion of CCUS-enabled hydrogen is that it would \nraise the cost of SAF. To get the scale and cost reductions we need to meet our carbon \nbudget and net zero commitments, the UK is supporting multiple production routes, including \nboth electrolytic and CCUS-enabled hydrogen. Electrolytic – or ‘green’ – hydrogen is likely \nto be a core long-term hydrogen production technology as it is expected to be able to operate \nflexibly, responding to the availability of electricity inputs, and when paired with renewable \nelectricity can deliver zero carbon hydrogen.   \nWe will reflect on the information submitted as part of the consultation and wider evidence, \nas well as taking into account interactions with wider Government policy including the Low \nCarbon Hydrogen Standard and RTFO, to inform any future decision on the inclusion of \nCCUS-enabled hydrogen. Future inclusion would be subject to consultation and require a \nchange to primary powers used for the SAF mandate.   \nQuestion 24 \nDo you agree or disagree that the contribution of energy content from \nhydroprocessing should be calculated? \nSummary of responses \nFigure 28 Question 24 summary of responses. \nMost respondents agreed with the proposal to calculate the energy content arising from \nhydroprocessing. The main reason being that this approach would treat types of SAF equally \nand that it would ensure that any use of fossil hydrogen would not be considered renewable. \nA couple of respondents suggested that as a consequence of this accounting, the use of \nlow carbon hydrogen in refining and upgrading of SAF would be encouraged. Though, \nseveral respondents underlined that this proposal is only relevant where the fuel is not wholly \nrenewable, given the lifecycle analysis will have already accounted for the carbon intensity \nof the hydrogen input. A couple of respondents suggested that the RTFO should also be \nupdated in line with this proposal for the same reasons stated here, as well as to maintain \nconsistency between the schemes.  \nHowever, a few respondents noted that the calculation of energy content from \nhydroprocessing can be burdensome and challenging, particularly in complex and dynamic \nindustrial processes. Furthermore, the energy content from hydroprocessing is minimal and \nthe lifecycle analysis already accounts for the carbon intensity. Therefore, accounting for \nthe energy content would not be a proportionate response and would be at odds to other \nregulatory schemes.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n37 \n 33 \n0 \n4 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n70 \nGovernment response \nHydrogen used in hydroprocessing is supplied in large volumes with the intention of \nrecycling it through the process again, rather than being carefully scaled as would be \nexpected in chemical synthesis. However, some of the hydrogen is likely incorporated into \nthe fuel and could meet the definition of a fuel precursor. \nThe hydrotreated vegetable oil (HVO) and HEFA pathways account for most of the \nhydroprocessing seen under the RTFO. These are considered to be 100% renewable in the \nRTFO Order, regardless of whether fossil or renewable hydrogen is used in its production. \nIn practice, the hydrogen used in hydroprocessing is considered a process input rather than \na feedstock, meaning that it is not subject to hydrogen eligibility criteria. Only in unique cases, \nsuch as certain development fuels, is the hydrogen tracked through the hydroprocessng \nstage in the same way that we proposed in the second Mandate consultation. The \ngovernment is instead confirming that the HVO and HEFA approach should be adopted for \nall SAF supplied under the Mandate.  \nGovernment decision: hydrogen used in hydroprocessing will be considered a \nprocess input and therefore not subject to hydrogen eligibility criteria. However, its \nuse must be accounted for in the lifecycle emissions of the final fuel.  \nThis applies where hydrogen is used to remove undesirable atoms such as but not limited \nto sulphur, oxygen and nitrogen from an existing hydrocarbon molecule, or to shorten an \nexisting hydrocarbon molecule (hydrocracking processes). \nIn contrast, where hydrogen is used directly in the production of hydrocarbon fuels prepared \nfrom smaller carbon molecules (e.g. CO, CO2, methanol, ethanol) hydrogen should be \ntreated as a precursor.  \nThe confirmed position diverges from what was originally proposed in the consultation. This \nis to ensure that we do not impose unnecessary administrative burden on suppliers, \nintroduce inconsistencies with other schemes or create unintended consequences. Critically, \nthis approach still accounts for the full emissions of the hydrogen used in the production \nprocess and the final fuel must still meet the minimum GHG emissions savings threshold. \nGiven we are rewarding SAF in proportion to the GHG emissions reductions it achieves, \nthere is an incentive to use low carbon hydrogen even if does not impact the renewability of \nthe fuel. Furthermore, the confirmed approach continues to ensure that all CO2 released by \nSAF is low carbon.  \nBy considering hydrogen used in hydroprocessing to be a process input, we will align with \nthe current treatment of HEFA under the RTFO Order and internationally. This will maintain \nregulatory simplicity and avoid potential issues with voluntary schemes that have so far used \nthis approach. It will simplify the process for suppliers operating in different regions, who \nunder the original proposal would be required to manage their mass balances separately in \nthe UK and internationally.  \nThis approach will also prevent suppliers from claiming certificates where fossil jet fuel is \nhydroprocessed with renewable hydrogen. This is important to ensure the Mandate \nencourages the development of advanced fuel production technologies which are needed \nto achieve stretching Mandate targets in later years.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n71 \nOur confirmed approach under the Mandate will not change how the RTFO treats \nhydroprocessing. This will continue to be considered as part of wider RTFO considerations. \nSustainability criteria  \nMinimum GHG savings threshold \nConsultation proposals \nA fuel’s carbon intensity is a measure of the GHG emissions generated per unit of energy \ncontained in the fuel, expressed in gCO2e/MJ. We previously confirmed that SAF would \nneed to achieve a minimum GHG saving, compared to fossil derived kerosene, in order to \nbe eligible for certificates under the mandate. We welcomed views and supporting evidence \non the following potential minimum GHG savings threshold to be implemented in the \nMandate: \n• 40% saving compared to fossil kerosene (equal to a maximum carbon intensity of \n53.4 gCO2e/MJ) \n• 50% saving compared to fossil kerosene (equal to a maximum carbon intensity of \n44.5 gCO2e/MJ)  \n• 60% saving compared to fossil kerosene (equal to a maximum carbon intensity of \n35.6 gCO2e/MJ). \nIt was also proposed that the threshold is increased over time to provide a mechanism for \nsuppliers to reduce the carbon intensity and we welcomed views on how the threshold \nshould change over time.  \nIn the original consultation, questions 25 and 26 were written in terms of carbon intensity. In \norder to make this section clearer, we have re-phased them, stakeholder responses and \nviews and the government response in terms of the relative GHG saving. \nQuestion 25 \nWhat level should the minimum GHG savings threshold be set at to maintain high \nsustainability credentials while ensuring enough flexibility to allow a wide range of \nSAF to be developed? Please provide evidence to support your answer. \nSummary of responses \nRespondents suggested a variety of figures for the minimum GHG emissions savings \nthreshold. The preferred threshold among respondents were 50%, 65% and 40% (in that \norder), collectively accounting for over half of responses. The remainder of respondents \nproposed figures ranging between 10%-70%, as well as stating the case for no threshold at \nall.  \nThose respondents that supported a minimum GHG emissions savings threshold of 50% \ndid so on the basis that this initial threshold would accommodate a wide range of production \npathways and feedstocks. Respondents stressed the importance of this during the early \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n72 \nyears of plant operation to successfully manage risks around plant performance. \nFurthermore, a higher threshold than this may discourage investors. A few respondents also \nnoted that the 50% threshold aligns with that of the US Inflation Reduction Act (IRA) and \nwould therefore facilitate imports of US SAF. Some respondents explained that the minimum \nGHG emissions savings threshold is less important than other sustainability criteria given \nthat the GHG scheme will incentivise reductions above and beyond the minimum threshold. \nHowever, they recognised that a 50% threshold would provide an appropriate minimum level \nto avoid greenwashing accusations or incentivising fuel that does not provide substantial \nbenefit. A fewer number of respondents provided all these reasons in their justification for a \nminimum threshold of 40%.  \nThose in favour of a 65% threshold underlined the importance of aligning the threshold with \nthat of the UK ETS and, to a lesser degree, the RTFO. Respondents highlighted that if the \nMandate does not require as stringent sustainability criteria as the UK ETS, there is a risk \nSAF suppliers will supply SAF to the UK that cannot be zero rated or claimed under the UK \nETS by airlines. Similarly, a few respondents proposed aligning with the EU ETS and \nRefuelEU thresholds (meaning 65% for biofuels and 70% for PtL) to support UK SAF \nproducers exporting to the EU.  \nSome respondents proposed a threshold of 10% to align with CORSIA, which applies \nglobally to airlines. These respondents felt that a less stringent threshold may mitigate the \nrisk of SAF plant development being slowed down due to the competition for finite design \nand construction resources such as CCUS, low-carbon hydrogen and enhanced grid \nconnections for renewable energy. They added that, given that the Mandate will award \ncertificates based on carbon intensity, the risk of the Mandate being fulfilled by high carbon \nintensity SAF is minimal. A couple of respondents went further to argue that there is no need \nfor a threshold at all.  \nA small number of other respondents preferred a threshold of 60% - the highest in the \nconsultation – which they felt would still allow a wide variety of projects to develop but would \nalso send a strong signal that there is demand for SAF with high GHG emissions savings \nand accelerate the decarbonisation of the aviation sector.  \nSeveral respondents did not propose a figure but instead underlined that the threshold must \nallow for the use of hydrogen that meets the maximum carbon intensity permitted by the \nLCHS.  \nGovernment response \nIt is our intention to support a mix of SAF types with high sustainability credentials, avoiding \ndirecting investment into SAF technologies that achieve minimal GHG emissions reductions \ncompared to fossil kerosene. The Mandate will reward certificates in proportion to the GHG \nemission savings of a given SAF consignment. This will incentivise cost-effective GHG \nemissions reductions and minimising the risk that the SAF mixture will be primarily made up \nof SAF that achieves minimal GHG emissions reductions. Nevertheless, we feel it is \nnecessary to have a minimum threshold as a further safeguard to guarantee a minimum \nGHG emissions reduction.  \nWe want to ensure that setting a minimum GHG emissions savings threshold does not \nunnecessarily exclude certain types of fuels or feedstocks that could still achieve significant \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n73 \nGHG emissions savings compared to fossil kerosene. This could particularly be the case, \nwhere SAF may not meet the minimum threshold during the initial years of production. It is \nimperative that the UK fosters an environment that allows a diverse pool of SAF to be \nsupplied, such that we can reach ambitious long-term targets and maximise decarbonisation \nthrough the use of SAF.  \nWe expect that the carbon intensity of SAF will decrease over time through the \ndecarbonisation of the electricity grid and supply chains, as well as the optimisation of \nproduction processes and the adoption of CCUS in reducing emissions of some of the SAF \npathways. If we set the minimum GHG savings threshold too high, it could risk stifling \ninnovation and reducing investment into SAF. This could minimise the diversity of SAF and \nlimit the volume brought to the UK market, leading to a reduced likelihood of achieving the \nMandate targets. \nWe have reviewed a multitude of evidence, including known projects, such as successful \nbidders to the AFF, and academic papers assessing the projected lifecycle carbon intensity \nof different technology pathways in reaching our decision.  \nGovernment decision: SAF will have to achieve a minimum GHG emissions savings \nthreshold of 40% against a fossil fuel comparator of 89 gCO2e/MJ in order to be \neligible for certificates from the Mandate start date. \nThis will ensure that investment in SAF production is not hindered while also ensuring a \nsufficient level of GHG emissions reductions.  \nWe have noted that some respondents stressed the importance of being able to make \nemissions reductions claims under the UK ETS for the use of SAF supplied for the Mandate. \nUnder the UK ETS,31 it is possible for an airline to make a claim for a reduction in aviation \nemissions (an Emissions Reduction Claim (ERC)) from the use of eligible SAF. Eligibility is \nbased on the sustainability criteria of the RTFO.32 All eligible SAF is currently rewarded an \nemissions factor of zero. A successful ERC thus reduces an airline’s emissions figure and \nthe number of UK ETS allowances they are required to surrender. \nThe UK ETS Authority will continue to develop proposals on how the UK ETS should treat \nthe use of SAF by aircraft operators and will consult on these in due course.33 The Authority \nwill consider full alignment with the SAF Mandate sustainability criteria. In addition, while \nSAF will continue to be zero rated under the UK ETS in the short-term, the Authority will \ncontinue to explore alternative options to SAF being zero rated in the future.  \nQuestion 26 \nDo you agree or disagree that the minimum GHG savings threshold should be \nincreased over time? If so, how should it evolve? \n \n31 Greenhouse Gas Emissions Trading Scheme Order 2020 (UK ETS Order) \n32 Schedule 1 of the Renewable Transport Fuels Obligation Order 2007 \n33 Consultation on Developing the UK Emissions Trading Scheme (UK ETS): \nhttps://www.gov.uk/government/consultations/developing-the-uk-emissions-trading-scheme-uk-ets \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n74 \nSummary of responses \nFigure 29 Question 26 summary of responses. \nSlightly more than half of respondents agreed that the minimum GHG emissions savings \nthreshold should increase over time. One of the key arguments was that it would maximise \nthe GHG emissions reductions by encouraging investment in the most low-carbon \ntechnologies and seeking efficiencies throughout the production process. These \nrespondents felt it would send a strong signal to drive improvement along the supply chains \nof existing pathways. Furthermore, as the grid decarbonises and low carbon hydrogen \nbecomes more widely available, it will be easier for producers to meet the minimum \nthreshold, and this should be reflected. \nThe main reason for disagreeing with this proposal was that it is unnecessary to increase \nthe threshold in a scheme that already incentivises greater GHG emissions reductions \nthrough the reward system. Such a scheme already allows for incremental improvement, \nwhile avoiding the risk of setting out threshold increases in legislation at the wrong rate. \nOther respondents disagreed on the basis that the threshold should be set at a high level \nfrom 2025 and therefore there is no need to increase it over time. These respondents were \nkeen to avoid a situation whereby fuels with lower environmental standards are eligible or \nindustry invests in infrastructure that cannot be adapted to meet the highest GHG emissions \nreductions.  \nIn terms of the rate at which the threshold should be increased, respondents urged the \ngovernment to consider many factors that impact the lifecycle GHG emissions reductions of \nSAF production. This included grid decarbonisation, low carbon hydrogen availability, CCUS \ndevelopment, commercial readiness of PtL facilities and developments in international \nsustainability criteria. However, no respondents suggested a specific trajectory. \nMany respondents urged the government to communicate any changes to the threshold as \nsoon as possible and to legislate these changes from the start. Critically, many respondents \nsought clarity on how the Department would consider grandfathering 34. Respondents \nexplained that clarity on the evolution of the threshold would provide certainty for investors, \nwhile grandfathering would ensure existing plants are not penalised. \nSome respondents, however felt that there are insufficient data available to set out how the \nthreshold should change at this given time. Rather, the minimum threshold and all relevant \nfactors should be monitored as SAF supply increases. It was suggested that changes to the \nminimum GHG emissions reductions threshold should be included in the regular review \nprocess discussed in questions 15 and 16.  \n \n34 Grandfathering is a provision in which an old rule continues to apply to some existing situations while a \nnew rule will apply to all future cases. Here, it would mean that production plants producing SAF prior to \nan increase in the minimum GHG emissions savings threshold would not be required to meet this new \nminimum GHG emissions savings threshold.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n48 \n27 \n5 \n16 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n75 \nGovernment response \nWe believe that the GHG emissions reductions threshold of 40% compared to a fossil fuel \ncomparator of 89 gCO2e/MJ is appropriate during the early years of the Mandate to \nencourage investment into SAF and ensure a diverse set of technologies can develop. \nHowever, we feel that it will likely be necessary to increase the threshold as other sectors \ndecarbonise, such as the grid, and CCUS becomes widely available. This is important to \nensure we incentivise the continual improvement of SAF production pathways.  \nTypically, it is RCFs which deliver the lowest GHG emissions reductions of the eligible types \nof SAF. The GHG methodology uses an energy from waste counterfactual to determine \nGHG emissions reductions, which is not used for the methodology in biofuels and PtL. This \ndifference in approach reflects the fundamentally different nature of RCFs, which embody \nfossil carbon. The environmental benefits of RCFs are realised when the conversion of \nfeedstock to RCFs delivers greater carbon savings compared to the counterfactual use. The \ncounterfactual emissions associated with UK derived RCFs could decrease significantly \nover the coming years as the electricity grid decarbonises35. As the electricity grids in the \nUK and overseas decarbonise, RCF production plants will also have the capability to \nincrease their GHG emissions reductions without any action or investment required.  \nGiven the decarbonisation of the grid is subject to significant uncertainty, it is not possible \nat this stage to set out exactly how the threshold will evolve over time for all types of SAF. \nHowever, based on the Treasury Green Book grid decarbonisation projections36, RCFs \nmade in the UK are expected to achieve around 65% GHG emissions reductions by 203537 \nshould the rate of grid decarbonisation progress as expected.  \nWe will consider the minimum GHG emissions reductions threshold as part of the regular \nreview process covered in questions 15 and 16. We will only make changes to the threshold \nif there is sufficient robust evidence to do so and this would be subject to consultation. As \npart of that review we will consider if it would be appropriate to grandfather existing SAF \nfacilities. This is unlikely to be necessary as SAF production plants will automatically reduce \ntheir emissions as the electricity grids in the UK and elsewhere decarbonise. Should we \nmake changes to the threshold, we will communicate these to stakeholders, giving sufficient \ntime for SAF plants and suppliers to make any necessary changes to meet the new threshold.  \nGHG emissions calculation methodology \nConsultation proposals \nFuel suppliers must be able to demonstrate that the carbon intensity of their supplied SAF \nachieves the minimum GHG savings threshold. The carbon intensity also determines the \nnumber of certificates to be rewarded. The consultation proposed that existing RTFO GHG \n \n35 We note that energy from waste facilities are expected to increasingly export useful heat and install CCS, \nwhich will impact the emissions savings of RCFs. The Administrator will define additional evidence-based \nfactors for heat export and/or CCS if and when this becomes relevant. \n36 https://www.gov.uk/government/publications/valuation-of-energy-use-and-greenhouse-gas-emissions-for-\nappraisal  \n37 https://assets.publishing.service.gov.uk/media/62f24849d3bf7f4fe5631088/supporting-recycled-carbon-\nfuels-through-rtfo.pdf  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n76 \ncalculation methodologies for biofuels, RFNBOs and RCFs will be adopted for the SAF \nMandate after an independent report commissioned by DfT confirmed these methodologies \nwould be appropriate for SAF. For nuclear derived SAF, we proposed to adopt a GHG \nmethodology that follows the same principles as the RFNBO methodology.  \nUnder the existing RTFO methodologies, default values are provided for either a complete \nprocess pathway (total default value) or specific lifecycle analysis elements (disaggregated \ndefault value). These provide a means for suppliers to submit a carbon intensity value of its \nfuel where certain GHG values are not easily measurable. In the Mandate consultation, we \nproposed that disaggregated default values will be provided for downstream emissions \nwhere data or robust assumptions are readily available. However, total default values will \nnot be provided. Where disaggregated default values are provided, suppliers will still be able \nto use and report actual values.  \nIn comparison to renewable energy, nuclear energy has ongoing upstream and operational \nactivities, such as processing and transport, which have GHG emissions associated with \nthem and should be accounted for in the methodology. We therefore proposed that suppliers \nprovide a GHG value for the upstream and operational emissions, either as an actual value \nor default value provided by DfT. We welcomed views and further evidence on what an \nappropriate default value is.  \nQuestion 27 \nDo you agree or disagree that the GHG methodologies used in the RTFO should be \nadopted in the SAF Mandate? \nSummary of responses \nFigure 30 Question 27 summary of responses. \nMost respondents agreed that the GHG methodologies used in the RTFO should be adopted \nin the Mandate. Of those that agreed, the main reason was that consistency with the RTFO \nis important to maintain a level playing field between types of LCF and reduce administrative \nburden for suppliers complying under both schemes. More broadly, a few respondents noted \nthat the RTFO methodologies have been developed from Renewable Energy Directive (RED) \nII methodologies, so adopting these will facilitate imports from the EU. Other key reasons \nfor agreeing included that, these methodologies have been developed and refined over time, \nthey are scientifically robust, and they are well understood by stakeholders. Several of those \nwho agreed pointed out the RCF methodology has not been published so they cannot \ncomment on this lifecycle analysis approach.  \nA few respondents preferred the methodologies to align with international schemes, in \nparticular, CORSIA. These respondents felt that this would make global comparisons more \nstraightforward and avoid any confusion or uncertainty in the market. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n44 \n 36 \n1 \n6 \n1 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n77 \nOther respondents disagreed with the methodologies on specific issues including co-\nprocessing for RFNBOs, additional renewable energy having zero emissions attributed to it \nat point of use, or that the methodologies are not aligned with the LCHS. \nOther comments made by individual respondents included: \n• flagging that they use a GHG methodology approved by a voluntary scheme;  \n• querying how the fossil fuel comparator may change over time; \n• underlining it is critical to distinguish between the biogenic CO2 released from \nbiofuels, fossil CO2 emitted from the combustion of RCFs, and the CO2 re-emitted \nafter upstream carbon capture (i.e. for PtL production); and \n• noting the importance of dealing with heat where an integrated nuclear facility \nprovides heat as well as electricity to a PtL plant. \nGovernment response \nIt is imperative that the scheme accurately calculates the carbon intensity of SAF production \nin order to correctly determine the number of certificates and to ensure that fuel meets the \nminimum GHG emissions savings threshold. At the same time, we recognise there is a \nbalance to be struck with minimising complexity for both government and industry when \nadministering the mandate.  \nWe are pleased that most respondents agreed with the proposal to use the RTFO \nmethodologies to assess the lifecycle carbon intensity of SAF. These methodologies have \nbeen developed over several years to ensure they accurately determine the carbon intensity \nof fuel production and, as a result, they are familiar to UK fuel suppliers. \nGovernment decision: we will adopt the same methodology for assessing the \nlifecycle carbon intensity of SAF as the RTFO does for renewable fuels.  \nFor biofuels and RFNBOs, these methodologies are already set out in guidance, while the \nRCF methodology was recently confirmed in the government response to the consultation \non RCFs 38. For nuclear derived fuels, this will adopt the same methodology as \nRFNBOs, with slight adjustments to account for the specificities of nuclear energy \ncompared to renewable energy.  \nThe UK biofuels methodology is broadly consistent with the methodology employed by the \nEU. The RFNBO and RCF methodologies have been developed by the UK, though the EU \nare developing similar methodologies using the UK methodology as a template. We have \nprovided a response in question 23 to those respondents that expressed preference for \nalignment with the LCHS.  \nAs stakeholders noted, consistency with the RTFO is important for fuel suppliers that will be \nusing both schemes as it reduces complexity and facilitates compliance. We anticipate that \nmost suppliers will use voluntary schemes, such as International Sustainability and Carbon \nCertification (ISCC), to prove compliance with the sustainability criteria. Importantly, the \n \n38\n https://www.gov.uk/government/consultations/supporting-recycled-carbon-fuels-through-the-renewable-\ntransport-fuel-obligation/outcome/supporting-recycled-carbon-fuels-through-the-renewable-transport-fuel-\nobligation-government-response  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n78 \nRTFO methodologies are an accurate lifecycle approach to determine the carbon intensity \nof fuel production and voluntary schemes are already familiar with them. \nWe recognise that there are differences with the CORSIA methodology. Although CORSIA \nadopts a similar approach for deriving core carbon intensity values, it also permits a range \nof additional indirect GHG factors that reduce the carbon intensity of fuels (for example \nresidual waste displacement from landfill or improvements to recycling), resulting in different \nvalues for the same fuel declared under the UK Mandate and these schemes. This is \nbecause CORSIA provides a wide-reaching framework that recognises certain behaviours \nassociated with SAF production. However, it does not prevent states from adopting more \nstringent methodologies. We will continue to work through ICAO to ensure that CORSIA \nprovides a robust framework for airlines to claim benefit for their SAF use, while not \npreventing fuel suppliers being subject to mandates in individual member states.  \nWhilst the methodology we will use to calculate the carbon intensity will be the same as \nunder the RTFO, the final GHG saving is calculated against a different fossil fuel comparator. \nWe previously confirmed that this comparator is 89 gCO2e/MJ in line with ICAO. This is \ndifferent from the RTFO as it more accurately reflects baseline emissions of the fossil fuel \nbeing replaced. On the specific points raised about distinguishing between types of CO2, \ntreatment of direct heat from nuclear energy, co-processing and additionality, further \ninformation will be made in the upcoming guidance.  \nQuestion 28 \nDo you agree or disagree that only disaggregated default values will be provided for \ndownstream emissions while the rest of the SAF lifecycle will require the use of actual \nGHG values? \nSummary of responses \nFigure 31 Question 28 summary of responses. \nMost respondents agreed that disaggregated values should be provided for downstream \nemissions only. A few of these pointed out the benefits of including defaults generally. \nNamely, that defaults reduce administrative burden, suppliers may not initially have the \nresource to carry out a detailed lifecycle analysis at every step and that actual values are \nnot always easily attainable. As such, some of those in agreement requested that when real-\nworld evidence becomes available, the government should introduce more default values.  \nA few respondents understood the question to mean that only default values would be \nprovided for downstream emissions while actual values would not be eligible, to which they \ndisagreed. They underlined that actual values should always be an option, as currently \nhappens in the RTFO. For further alignment with RTFO, some respondents proposed that \ndefault values for all appropriate emissions up to the point of final dispatch should be \nconsidered to provide a level field for all available technologies. One respondent suggested \nusing default values that have been developed under CORSIA to maintain global standards.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon’t know \n33 \n26 \n1 \n6 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n79 \nFinally, a couple of respondents suggested the creation of an international expert panel is \ncreated to maintain and update guidance and default values going forward, such that there \nis a dynamic process for amendments. Respondents noted that a similar proposal is being \nconsidered by the International Maritime Organization for marine fuel. \nGovernment response \nOur experience from implementing the RTFO has demonstrated the importance of providing \ndisaggregated default values to suppliers where possible. We will therefore endeavour to \nmaximise flexibility to suppliers by providing disaggregated default values where it makes \nsense to. However, we recognise that default values should be accurate to avoid incorrect \ncalculation of certificates and, at this given time, we consider there is insufficient data on \nmany elements of the lifecycle for each SAF production pathway. As a result, it is not \npossible to provide aggregated default values. When the mandate is introduced, we will \ntherefore only provide disaggregated default values for downstream emissions.  \nGovernment decision: disaggregated default values will be provided for downstream \nemissions. Where disaggregated default values are provided, suppliers will still have \nthe opportunity to provide actual values.  \nThese disaggregated default values will be published in the upcoming Mandate guidance. \nWorking with international voluntary schemes and industry, the default values will be \nreviewed regularly and updated if new evidence suggests it is necessary. ,  \nQuestion 29 \nPlease provide evidence to inform which default values should be provided by DfT \nfor downstream emissions. \nSummary of responses \nSixteen stakeholders responded to this question. Most of these respondents pointed out that \ntransport and distribution emissions are comparable to road fuel. Therefore, these default \nvalues could be taken from the RTFO. Other respondents suggested different sources \nincluding the Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation \n(GREET) model, CORSIA and Roundtable on Sustainable Biomaterials (RSB).  \nGovernment response \nWe have responded to questions 29 and 30 together – see government response following \nquestion 30.  \nQuestion 30 \nDo you agree or disagree that upstream and operational emissions should be \nincluded for nuclear power generation at the point of delivery? If yes, please provide \nevidence of what figure could be used for the default value. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n80 \nSummary of responses \nFigure 32 Question thirty summary of responses. \nMost respondents agreed that upstream and operational emissions from nuclear power \ngeneration should be included in the carbon intensity at the point of delivery. Many \nrespondents called for consistency with other schemes and to treat all technologies equally. \nAs such all emissions up to the point of final dispatch should be considered, including \nupstream emissions, regardless of the energy source. \nRegarding which default value could be used, a few respondents suggested specific sources \nwhile one respondent noted that any default used must still encourage investment in nuclear \npower to support SAF production.  \nGovernment response \nIt is imperative that all aspects of the fuel’s lifecycle are accounted for to ensure that \ncertificates are rewarded appropriately and that the GHG emissions reductions arising from \nthe Mandate are accurate.  \nGovernment decision: where additional nuclear energy is used as an energy source, \nupstream and operational emissions will be accounted for at the point of use. \nThis marks a difference from the use of renewable energy, which is considered to have zero \nemissions at the point of use in the RTFO and the SAF Mandate. We will provide a \ndisaggregated default value; however, suppliers reserve the right to provide actual values if \nthey wish.  \nWe continue to review the sources of information submitted in response to questions 29 and \n30, while working in cooperation with international schemes and industry, to determine \nappropriate disaggregated default values. These disaggregated default values will be \npublished in the upcoming Mandate guidance. The disaggregated default values will be \nreviewed regularly and updated if new evidence suggests it is necessary to change the \nfigure provided. \nOther emissions \nThe proposed GHG methodology focuses on accounting for CO2, CH4 and NO2 emissions. \nHowever, we recognise that aviation fuels, and indeed fuels more generally have \nenvironmental impacts which extend beyond these emissions.  \nResearch and analysis carried out so far suggests that SAF is expected to have a positive \nimpact on reducing aviation’s non-CO2 impacts. Nevertheless, significant uncertainties \nsurrounding the climate impact of non-CO2 emissions and non-CO2 benefits of SAF remain, \nand there is currently no scientific consensus over a suitable metric for comparing the \nclimate effect of CO2 with non-CO2 impacts, or for effective monitoring of non-CO2 impacts. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon’t know \n24 \n20 \n3 \n0 \n1 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n81 \nGiven the lack of certainty in this field, the government is not in a position to develop \nmitigation measures.  \nIn the Jet Zero Strategy, the government confirmed its objective to address aviation’s non-\nCO2 impacts by better developing our understanding of their impact and potential \nmitigations. On 13 October 2023, the Department for Transport alongside the Department \nfor Business and Trade and the Natural Environment Research Council launched a multi-\nyear research programme to support these commitments.  \n \n \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n82 \nThe Administrator \nThis section details our final position on who will act as the Administrator of the SAF Mandate \nand the powers and duties that the Administrator will have. The Administrator will be \nresponsible for enforcing the scheme and supporting fuel suppliers to comply.  \nThe government response to the first consultation confirmed that the SAF Mandate will be \nadministered separately to the RTFO. The second consultation set out the government’s \nintention to align the Mandate with the RTFO; that is, the Secretary of State for Transport \nacting as Administrator with delegated responsibility to an administrative unit within the DfT. \nWe proposed that the Administrator will have the same powers and duties as those set out \nunder the RTFO Order. \nConsultation proposals \nWe propose that the SAF Mandate will be administered by a specific body (the Administrator) \nthat will be responsible for enforcing the scheme and supporting fuel suppliers to comply. \nWe proposed that the Administrator will have the same powers and duties as those set out \nin the RTFO Order and the Energy Act 2004. Under the RTFO Order, the Administrator is \nthe Secretary of State for Transport, who delegates responsibility to an administrative unit \nwithin DfT. We proposed that the same approach is adopted in the SAF Mandate. \n Question 31 \nDo you agree or disagree that the Secretary of State should be the Administrator, with \nresponsibility delegated to a DfT administration unit? \nSummary of responses \nFigure 33 Question 31 summary of responses. \n3. Involved parties \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n34 \n25 \n4 \n5 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n83 \nMost respondents agreed with the proposal to delegate responsibility of administration to a \nunit within DfT. This was primarily due to it being the same approach as the RTFO, which \nhas been effective to date. Some respondents, however, added that it is necessary the \nadministrative functions are well structured and there is sufficient technical expertise to \noperate both the SAF Mandate and RTFO effectively. \nOf those that disagreed, respondents typically showed a preference for joint ownership and \nadministration by the DfT and DESNZ - with one respondent also suggesting Defra due to \nthe cross-sectoral nature of SAF in areas such as hydrogen, energy and feedstock \navailability. Other reasons for disagreeing were that the Administrator should secure cross-\nparty support given the long-term nature of the mandate, as well as the suggestion that the \nDfT administration unit should have a reduced role and be accompanied by a private sector \nbody that manages the daily operation of the scheme.  \nGovernment response \nWe have concluded that the current model has been effective at implementing the RTFO \nand would be equally effective for the operation of the SAF Mandate.  \nGovernment decision: the Secretary of State should be the Administrator, with \nresponsibility delegated to a DfT administration unit.  \nThis means that an administrative unit within DfT will act as the regulator of the SAF Mandate \nand ensure obligated parties comply with legislation. The unit’s primary responsibilities will \nbe management of accounts, ensuring that SAF claimed under the scheme meets the \nsustainability criteria and ensuring obligated parties meet their obligations. We will ensure \nthat the administrative unit has sufficient resource and expertise to deliver the functions and \nduties assigned to it.  \nWe recognise that some respondents requested the SAF Mandate to be delivered through \na cross-departmental administrative unit given the synergies with policy led by other \ngovernment departments, in particular, DESNZ. While much of the SAF Mandate policy has \nclose links with other departmental policy, the ‘RTFO Unit’ in DfT has experience in \noperating the RTFO independently since its inception. Throughout this period, it has \nmaintained close relationships with other government departments. We will take the same \napproach in the operation of the SAF Mandate and therefore do not feel it is necessary to \nincorporate other departments in the daily operation of the mandate. The same applies when \nconsidering the inclusion of private bodies to support the operation of the Mandate. \nNevertheless, we will continue to work with the Jet Zero Council and through other \nstakeholder engagement to monitor the Mandate as needed.  \nQuestion 32 \nAre there any additional powers or duties beyond those outlined above that the \nAdministrator should be granted? \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n84 \nSummary of responses \nFigure 34 Question 32 summary of responses. \nMost respondents did not see the need for any further powers or duties to be legislated for \nbeyond those listed in the consultation. A few respondents highlighted that the RTFO has \nbeen developed and updated over several legislative cycles in response to any issues with \nits operation, so no further changes are required.  \nA small number of respondents did suggest further powers or duties for the Administrator. \nThese included the power to introduce incentives for producers or revenue certainty \nmechanisms, the power to redistribute buy-out funds to industry, an arbitration role with \nother government departments, and powers to ensure continued supply of jet fuel during \nperiods where a SAF obligation cannot be met due to unexpected shortages.  \nGovernment response \nThe powers and duties of the Administrator of the RTFO have been revised several times \nsince the RTFO was launched to reflect issues that may have arisen during the \nimplementation of the RTFO. Upon reviewing these powers and duties, we do not believe \nthat the supply of SAF will require any further changes to the current powers and duties held \nby the Administrator of the RTFO. \nGovernment decision: the Administrator for the SAF Mandate will have the same \npowers and duties granted to it as it does under the RTFO Order.  \nThese powers and duties were set out in the consultation and will be written into the SAF \nMandate legislation.  \nIn response to stakeholder views on additional powers we have responded to each of these \npoints below: \n• Power to introduce a revenue certainty mechanism: the government has already \ncommitted to designing and implementing a revenue certainty mechanism for UK \nSAF projects as soon as possible. Furthermore, this power would fall outside the \nexisting scope of the primary legislation; \n• Power to redistribute buy-out funds: we will remain consistent with the approach \nunder the RTFO Order whereby payments go into the Consolidated Fund; however, \nwe will keep this under review; \n• Duty of arbitration between government departments: the Mandate has been \ndesigned in collaboration with other departments and DfT will continue to work across \ngovernment to ensure alignment of policy; \n• Power to ensure continued supply of jet fuel: where the Mandate cannot be met due \nto unexpected shortages or prices rises of SAF, the buy-out mechanism allows \nsuppliers to meet their obligation by paying a sum of money proportional to the \nshortfall of SAF supply. This mechanism will be written into legislation. We would \nTotal \nYes \nNeither \nNo \nDon't know \n21 \n3 \n1 \n17 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n85 \nanticipate that fossil jet fuel would be supplied in the absence of SAF and it is \ntherefore not necessary to include as a specific power or duty for the Administrator.  \n \nObligated parties and obligated fuel \nThe first consultation confirmed that under the SAF Mandate suppliers of fossil jet fuel to the \nUK will be subject to an obligation.  \nThis section sets out the government’s final position on the ‘assessment time’ in the Mandate. \nWhichever party owns the fuel at the assessment time will become obligated if supplying \nfossil jet fuel, or be rewarded with certificates if supplying eligible SAF. Rewards under the \nscheme will only be granted once proof of sustainability has been certified. This section sets \nout the assessment time for avtur, renewable avgas and hydrogen. \nThe response to the first consultation did not set out the assessment time; however, it noted \nthat for avtur the government was minded towards placing the assessment time at the \nblending and certification point. This position was amended in the second consultation \nbecause this assessment time would not cover all necessary fuel. For example, fossil jet \nfuel is not always blended and certified and SAF may be blended outside the country. The \nsecond consultation proposed that the assessment time for avtur and avgas will be the duty \npoint and the point of retail sale for hydrogen.  \nConsultation proposals \nWe proposed that the assessment time for avtur under the Mandate is at the duty point as \nthis aligns with treatment for road fuel under the RTFO. It will capture both imported and \ndomestically produced SAF and conventional avtur, and it is at a point in the supply chain \nwhere fuel volumes would be readily auditable. \nFor avgas, which is subject to duty, we proposed to use the duty point as the assessment \ntime in line with the current position under the RTFO, and the proposed approach for avtur. \nFor hydrogen, we proposed the point of retail sale as the assessment time in line with current \npractice under the RTFO and welcomed further views on this approach.  \nQuestion 33 \nDo you agree with the assessment time for avtur being set at the duty point? Please \nprovide evidence to support alternative approaches. \nSummary of responses \nFigure 35 Question 33 summary of responses. \nMost respondents to this question agreed with the assessment time for avtur being set at \nthe duty point. Respondents suggested that this aligns with similar legislation in other \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n26 \n 23 \n2 \n1 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n86 \nregions and helps to ensure that both imported and domestically produced fuel is covered \nby the legislation. Some respondents suggested that the government needs to consider the \npossible interactions with heating kerosene and ensure that there is a simple process in \nplace to ensure this fuel does not receive an obligation. One respondent highlighted that the \nscheme must ensure producers that decide to blend their SAF with fossil jet purchased from \nothers, do not inadvertently become obligated parties under the Mandate. Two respondents \nhighlighted that the avtur supply chain is very complex and often company-specific and \nsuggested that DfT engage with suppliers during the Mandate implementation period to \nensure that any process that is enacted works as intended.  \nThe one respondent who disagreed with the duty point as the assessment time suggested \nthat it should instead be set at the point of sale to the aviation operator, or the wingtip, in \norder to accurately reflect the volume of fuel used for aviation purposes. Another respondent \nsuggested that the wording ‘importer of record’ be used to cover imported avtur. \nGovernment response \nIt is critical that the assessment time takes place at the correct point in the supply chain to \nensure that the intended parties are either obligated or rewarded with certificates. The \nassessment time must only happen once, be clearly defined in legislation to remove \nambiguity, be identified the moment it happens, and ideally have data available to validate \nfuel volumes (see question 34). We proposed the duty point as the assessment time as we \nbelieved it met these minimum requirements and following stakeholder feedback we do not \nsee any reason to diverge from our proposal.  \nGovernment decision: the assessment time for avtur will be placed at the duty point.  \nAlthough avtur is fully rebated (no duty is paid), it is still a controlled oil as defined in section \n27 (1) of The Hydrocarbon Oil Duties Act 1979 (HODA) and has a duty point. This aligns \nwith the current assessment time for road fuels under the RTFO, making it administratively \neasier for suppliers of fuels to both the road and aviation markets. Under HODA, unblended \nSAF HODA would be treated as a “substitution” for the fuel that it is replacing (i.e. kerosene). \nIt would therefore have the same tax code and would not be subject to duty. \nWhere the duty point falls is determined by a number of factors including type of fuel, \nproduction process and whether the fuel is imported or domestically produced. Suppliers \nwill have to consider each of these factors when setting up their supply chains to ensure that \nthe intended party is either subject to an obligation or eligible of reward of certificates.  \nBroadly speaking: \n• Where fossil jet fuel is produced or refined in the UK, the duty point occurs when the \nfuel leaves the refinery warehouse. This fuel will be subject to an obligation.  \n• Where unblended SAF is produced in the UK, the duty point will occur when it leaves \nthe production facility and is set aside as a substitution for fossil kerosene to be used \nin UK aviation. This fuel will be subject to the reward of certificates. \n• Where a refinery produces a combination of both fossil kerosene and SAF and blends \nthem on the same site, the duty point occurs when the fuel leaves the refinery \nwarehouse. This fuel will be subject to an obligation and certificate reward.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n87 \n• Where fossil kerosene, blended SAF or unblended SAF is imported into the UK for \nthe purposes of aviation fuel, the duty point will occur when the fuel leaves the storage \nfacility at the point of import. Depending on the type of fuel being imported, the fuel \nwill be subject to either an obligation, reward of certificates, or both.  \nWe have been working closely with HM Revenue and Customs (HMRC) to ensure that our \npolicy proposals have the intended outcome. We will continue to engage with HMRC and \nstakeholders to consider if updates to the Hydrocarbon Oil Duties Act 1979 (HODA) are \nrequired. Further information on the assessment time will be provided in guidance.  \nQuestion 34 \nDo you agree that the duty point is the most suitable assessment time for renewable \navgas? \nSummary of responses \nFigure 36 Question 34 summary of responses. \nMost respondents to this question agreed with the assessment time for avgas being set at \nthe duty point. Respondents highlighted that this is consistent with avgas’ treatment in other \nregulations. Respondents also highlighted that the duty point works particularly well for \navgas because it has an uncomplicated supply chain and a lack of alternatives downstream \nof this point. One respondent who agreed with the use of the duty point highlighted that it \ncould cause issues with petrol but suggested that this was niche and did not provide \nexplanation for this point. \nOne respondent suggested that the wording ‘importer of record’ be used to cover imported \navgas.  \nGovernment response \nThe assessment time for avgas must follow the same principles as avtur, which were set \nout in the response to question 33. For the same reasons explained in the above response, \nand taking into consideration stakeholder responses, we will continue with our proposal to \nset the assessment time at the duty point.  \nGovernment decision: the assessment time for avgas will be placed at the duty point. \nAs stated above, we will continue to work with HMRC to ensure that our policy intent and \nlegislation is line with existing legislation. Further information on the assessment time will be \nprovided in guidance.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n23 \n 19 \n1 \n1 \n2 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n88 \nQuestion 35 \nDo you agree that the point of retail sale is the most suitable assessment time for \nhydrogen? Please provide evidence to support alternative approaches. \nSummary of responses \nFigure 37 Question 35 summary of responses. \nMost respondents to this question agreed that the point of retail sale should be used as the \nassessment time for hydrogen. The reasoning provided for this choice was that it aligns with \nthe treatment of hydrogen under the RTFO and under low carbon hydrogen agreements.  \nSeveral respondents highlighted that they were unclear on where the assessment time for \nhydrogen should be because the hydrogen for aviation market is still in early development \nand supply chains are not yet established. One respondent suggested that hydrogen into \naircraft may not follow the same supply chain as hydrogen into road. For this reason, some \nrespondents suggested that the assessment time be kept under review as the market \ndevelops.  \nGovernment response \nAs stated in the consultation, hydrogen does not have a relevant duty point. It is therefore \nnecessary to impose a different assessment time for its supply, which we proposed to be \nthe point of retail sale. However, the reference to retail implies that it is the final sale of the \nfuel and is primarily relevant to when fuel is sold in forecourts. We have therefore removed \nreference to retail in the definition of the assessment time so that it is more appropriate to \naviation. This is in line with the current wording of the RTFO.  \nGovernment decision: the assessment time for hydrogen will be the point at which it \nis sold to a customer in aviation. \nThis is the point at which the renewable hydrogen is sold to a customer (whether commercial \nor retail) for consumption in aviation and not for resale in the course of a trade or business. \nGiven there is insufficient evidence at this stage to assess the effectiveness of this \nassessment time, due to lack of hydrogen supplied to UK aviation, it is right to maintain \nconsistency with the RTFO. As hydrogen supply to aircraft increases, we will monitor the \nsituation and compare this to other transport sectors to ensure the assessment time is set \nin the correct place. If new evidence emerges that suggests the assessment time should be \namended, then government will take appropriate action. We do not expect significant \nvolumes of hydrogen to be supplied during the early years of the Mandate due to \ndevelopment of timeframe associated with relevant airframe technology. Therefore, \ngovernment will have sufficient time to consult stakeholders and alter legislation if necessary.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n17 \n 11 \n1 \n1 \n4 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n89 \nEnd point of chain of custody \nWhilst the duty point will be used as the assessment time, it is still necessary to ensure that \nSAF has been supplied for use in planes departing from the UK. It is therefore necessary to \ntrack the fuel along the chain of custody to its end use. This section sets out the \ngovernment’s final position on where the chain of custody ends under the Mandate.  \nThe chain of custody is the sequence of ownership of aviation fuel as it moves through the \nsupply chain from its origin e.g. where a waste feedstock arises to where the SAF is supplied \nfor use in aviation. The end point of the chain of custody is what will be used under the \nMandate scheme to identify when SAF has reached a ‘point of no return’ where the fuel \ncannot be used anywhere other than UK aviation. \nSuppliers become liable for obligations, or eligible for rewards, at the assessment time; \nhowever, there is no guarantee that once fuel has reached the assessment time that it will \nbe used in UK aviation. It is important that obligations and rewards only apply to fuel that is \nsupplied to UK aviation. Therefore, evidence of forward supply of fuel past the assessment \ntime is necessary for the obligations and rewards identified at assessment time to be placed \non, and granted to, fuel suppliers. The end point of the chain of custody will be used to \nidentify when SAF has reached a ‘point of no return’ where the fuel cannot be used anywhere \nother than UK aviation. \nThe first consultation confirmed that mass balance will be the only chain of custody permitted \nin the Mandate scheme. The response also noted that the government was minded towards \nending the chain of custody at the point the fuel is held in co-mingled storage. However, the \nsecond consultation amended this position and proposed that the end of the chain of custody \nbe set at the ‘point of no return’, to align with the process that has been successful under \nthe RTFO.  \nOur final position is to set the end of the chain of custody as the ‘point of no return’ of the \nrelevant fuel.  \nConsultation proposals \nWe proposed that the end point of the chain of custody should be the ‘point of no return’ of \nthe relevant fuel. This is the position adopted by the RTFO. Evidence that can be submitted \nto prove forward supply currently includes bills of lading or equivalent transport \ndocumentation showing delivery to an airport, proof of payment by airlines accompanied by \nevidence of transport up to, and including, entry into pipelines, and other arrangements as \nagreed with the Administrator.  \nQuestion 36 \nDo you agree with the end point of the chain of custody being the ‘point of no return’ \nof the relevant fuel? \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n90 \nSummary of responses \nFigure 38 Question 36 summary of responses. \nMost respondents to this question agreed that the end point of the chain of custody should \nbe the ‘point of no return’ of the relevant fuel. The main reasoning provided for this choice \nwas that it aligns with current treatment of avtur under the RTFO and that it will help to avoid \nthe double counting of emission reductions. \nSeveral of the respondents who agreed with the ‘point of no return’ as the end point of the \nchain of custody felt that further detail was needed on the practicalities of this. Two \nrespondents suggested that government needs to do further work to define what the point \nof no return would be in different supply chain scenarios. One respondent who agreed \nsuggested that the point of no return should be aligned with the approach taken in the UK \nETS legislation, which ensures that a variety of delivery methods into UK aviation fuel \nsystems can be accommodated.  \nSeveral respondents suggested the end point should be at the assessment time (duty point). \nThese respondents suggested that the original reason for an onwards chain of custody past \nthe assessment time was due to the RTFO assessment time for SAF sometimes occurring \noutside of the UK, and therefore proof being required that the fuel had reached the UK.  \nAlthough the question did not directly ask about chain of custody models, several \nrespondents suggested that a book and claim chain of custody be considered under the \nmandate to allow airlines to purchase SAF without being geographically connected to a SAF \nproduction site. \nGovernment response \nIt is essential that the chain of custody ends at the correct point to ensure that any fuel that \nis either obligated or rewarded with certificates at the assessment time is used in UK aviation \nonly and is not used for any other purposes further down the supply chain.  \nGovernment decision: we confirm that the chain of custody ends at the point of no \nreturn where fuel cannot be used anywhere other than UK aviation.  \nVoluntary schemes, which suppliers currently rely on to provide assurance over the chain of \ncustody for eligible fuels, typically only cover the chain of custody for SAF to the assessment \ntime. There is no guarantee that once fuel has reached the assessment time it will be used \nin UK aviation and for this reason, we propose that we will require evidence of forward supply \nof fuel past the assessment time. \nWe will adopt the same approach as the RTFO whereby the Administrator will regularly \nconduct compliance checks on random SAF consignments to require evidence of end use. \nHowever, fuel suppliers are not required to provide evidence of end use for every litre of fuel \nsupplied due to the significant administrative burden this would place on fuel suppliers.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n30 \n 21 \n3 \n6 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n91 \nThere are several potential pieces of evidence that can be used to prove fuel has reached \nthe point of no return including bills of lading or equivalent transport documentation showing \ndelivery to an airport and proof of payment by airlines accompanied by evidence of transport \nup to, and including, entry into the pipelines. However, further information on the exact \nevidence that can be used as compliance will be provided in guidance.  \nIt is also important that the sustainability credentials for each consignment of SAF are \npassed through to end users, to allow SAF use to be claimed against obligations in other \nschemes. For example, airlines using SAF in UK ETS or CORSIA. We are working closely \nwith DESNZ, the Environment Agency and voluntary schemes to develop a solution that will \nallow sustainability credentials for a given SAF consignment to be passed down onto end \nusers, while ensuring that strict audit requirements continue to be upheld and there is no \ndouble counting of emissions savings. Further information on interactions between the \nMandate and these schemes will be provided in guidance.  \nThreshold amount below which fuel is not obligated \nThis section sets out the government’s final position on the threshold by which the supply of \nconventional avtur will not face an obligation.  \nA threshold will safeguard small amounts of fuel for end uses such as research and testing, \nfor which the amount of SAF obligated to be supplied would be negligible. To apply an \nobligation in these circumstances is considered a disproportionate burden. This is the \napproach successfully taken under the RTFO.  \nThe government response to the first consultation confirmed that the obligation on jet fuel \nsuppliers noted that the government was minded towards introducing a minimum threshold \nbelow which fuel is not obligated.  \nConsultation proposals \nWe proposed that suppliers that supply less than 370 tonnes (equivalent to approximately \n450,000 litres) of avtur within a reporting period will not have an obligation and will be exempt \nfrom the reporting requirements of the SAF Mandate. This aligns with the threshold currently \nin place in the RTFO.  \nQuestion 37 \nDo you agree with the use of a 370 tonne (approximately 450,000 litre volume) \nthreshold under which conventional avtur is not obligated within the mandate? If not, \nplease provide an alternative and any evidence to support this. \nSummary of responses \nFigure 39 Question 37 summary of responses. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n23 \n 20 \n1 \n2 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n92 \nMost responses to this question agreed with the use of a 370 tonne threshold within the \nMandate scheme. Most respondents who agreed did not provide an explanation for this, but \nthose who did highlighted that avtur suppliers supply much larger volumes of fuel than the \nthreshold stipulates, so it should capture all those who supply into aviation. Several \nrespondents were also pleased to see consistency with the RTFO threshold.  \nTwo respondents who agreed with the proposal felt that it would be helpful to have \nclarification that a small supplier who supplies over 370 tonnes of road fuels and avtur in \ntotal will not be obligated under the mandate or RTFO. \nOf the respondents who disagreed, one felt that a threshold would create a potential \nloophole for private aircraft to avoid the Mandate by resetting their obligation every year. \nAnother respondent suggested that in order to reach net zero emissions in aviation, the \nMandate should cover all avtur supply regardless of the volume supplied. \nGovernment response \nGiven most respondents agreed with our proposed approach, and that it aligns with the \napproach that has worked effectively in the RTFO we will not diverge from this approach \nwhen we introduce the SAF Mandate.  \nGovernment decision: any fuel supply under the equivalent of 370 tonnes will not be \nsubject to an obligation. Note that the SAF mandate obligation is applied on an energy \nbasis and this equates to 15.9 terajoules (TJ). \nThis figure relates to the total amount of fuel owned by the supplier for UK aviation, including \nboth fossil jet fuel and SAF. This threshold only applies to suppliers that supply less than \n8,000 tonnes. If a supplier supplies 8,000 tonnes (equivalent to 344 TJ) or more then the full \namount will be subject to an obligation.  \nIn addition to maintaining consistency with the RTFO approach, we believe it is necessary \nto safeguard small amounts of fuel supplied for end uses such as research and testing and \nthat it would be disproportionate to apply an obligation to suppliers of small volumes of fuel. \nSuppliers of small amounts of fuel who would not be obligated under the Mandate are not \nrequired to register an account. This will help to avoid unnecessary administrative burden \nfor both the non-obligated parties and for the Administrator.  \nThis minimum threshold is unlikely to impact on the obligation of established avtur suppliers, \nas they deal in much larger amounts of fuel than the threshold stipulates. It will therefore \nhave minimal impact on the GHG emissions savings of the scheme. For context, \napproximately 12.4 million tonnes of jet fuel are expected to be supplied to the UK in 2030 \nleading to an obligation of 1.24 million tonnes of SAF to be supplied equating to 2.7 MtCO2e \nsaved in that year.  \nThe SAF Mandate and RTFO are two separate schemes. Therefore, this threshold applies \nonly in relation to aviation fuel, while the 450,000 litre threshold will continue to be in place \nunder the RTFO Order for all relevant fuels (which will not include aviation fuel once the \nMandate is operational from 2025).  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n93 \nIn response to the point raised about private aircraft avoiding their obligation, it must be \nemphasised that the obligation is placed on suppliers of jet fuel. Avgas typically fuels aircraft \nused in general aviation, which would not be subject to an obligation regardless of whether \na threshold is imposed.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n94 \n4. Calculating the obligations and certificate \nreward \nObligation period \nThis section sets out the government’s final position on the obligation period under the \nMandate and the specific dates by which obligated parties and the Administrator must take \naction following the end of the obligation period. \nThe obligation period is the timeframe over which obligated suppliers will be required to \nsupply their mandated amount of SAF.  \nConsultation proposals \nWe proposed that each obligation period is one year in length and runs on a calendar year \nbasis, in line with the RTFO. This time period gives suppliers sufficient flexibility to meet their \nobligations, simplifies compliance for suppliers obligated under both the RTFO and Mandate \nand allows for a straightforward transition of SAF support from the RTFO to the Mandate.  \nFollowing the end of each obligation period, we propose that deadlines that suppliers and \nthe Administrator must adhere to align with those in the RTFO. That is, in the months \nfollowing an obligation period end: \n• suppliers will be able to submit claims for SAF certificates for the previous obligation \nperiod until 12 May; \n• the deadline for the Administrator to revoke certificates is 17 June and the deadline \nfor appeal against revocation is 15 August; \n• the obligations will be calculated on 15 August and shared with suppliers, at which \npoint suppliers will be able to redeem their certificates against their obligations up \nuntil 15 September; and \n• the Administrator will calculate the buy-out sums on 21 September and share with \nsuppliers. Suppliers will have until 26 October to pay the buy-out sums.  \nQuestion 38 \nDo you agree or disagree that the obligation period should run for a one-year period \nand on a calendar year basis? \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n95 \nSummary of responses \nFigure 40 Question 38 summary of responses. \nAll respondents agreed with this proposal on the basis that it is consistent with other \nschemes including the RTFO and other domestic and international GHG reporting schemes. \nFor suppliers, aligning with the RTFO will ensure a straightforward transition to supporting \naviation fuel under the Mandate and will reduce the administrative burden for those \nsupplying fuel under both schemes.  \nGovernment response \nGovernment decision: the SAF Mandate obligation period will be one year in length, \nrunning on a calendar year basis.  \nThis means that the first obligation period will run from 1 January 2025 up to and including \n31 December 2025.  \nThis obligation period aligns with that of the RTFO ensuring that there is no point at which \nSAF is not supported or is eligible to receive certificates under more than one scheme. This \nobligation period has been effective under the RTFO as it provides a sufficient length of time \nover which obligated parties can source SAF to meet their obligation. Furthermore, \nconsistency with RTFO is important for suppliers or other parties operating under both \nschemes as it imposes processes with which they are already familiar and simplifies \ncompliance. For the Administrator regulating the scheme, aligning with the RTFO will reduce \ncomplexity. We therefore think it would cause undesirable consequences should we diverge \nfrom imposing an obligation on a calendar year basis.  \nQuestion 39 \nDo you agree or disagree with dates for which actions must be completed following \nthe end of the obligation period? \nSummary of responses \nFigure 41 Question 39 summary of responses. \nMost respondents agreed with this proposal to be consistent with the RTFO and provide a \nclear framework for processes following the obligation period. A few respondents suggested \nincluding these dates in the review process to ensure that unforeseen issues can be \naddressed. For example, coinciding administrative deadlines with the RTFO could result in \nadministrative burden for the Administrator if the same resource is expected to operate both \nschemes. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n33 \n33 \n0 \n0 \n0 \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n26 \n25 \n1 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n96 \nGovernment response \nBased on our operational experience of the RTFO and feedback from the consultation, we \nbelieve that there is no need to amend the actions and dates that are in place. \nGovernment decision: we will legislate that, following the obligation period, the \nAdministrator and relevant parties must complete the above actions by the following \ntimelines:  \n• suppliers will be able to submit claims for SAF certificates for that obligation period \nuntil 12 May (see question 50 for more information on submitting claims); \n• the revocation deadline is 17 June and the revocation appeal deadline is 15 August \n(see question 59 for further information); \n• the obligations will be calculated on 15 August, at which point suppliers will be able \nto redeem their certificates against their obligations up until 15 September (see \nquestion 46 for more information); and \n• the Administrator will calculate the buy-out sums on 21 September and suppliers are \ndue to pay the buy-out sums by 26 October. \nSuppliers’ obligations will be determined according to the \namount of energy supplied through aviation fuel \nThis section sets out how an obligated parties’ obligation will be calculated.  \nConsultation proposals \nThe second consultation proposed to determine each supplier’s obligation to supply SAF \nbased on the energy they have supplied through fossil aviation fuel. Obligating based on \nenergy will allow us to include emerging technologies in the future through the certificate \nreward system. An obligation on energy supplied will reduce emissions to the same level, at \nthe same rate, as a GHG emissions reductions obligation.  \n \nQuestion 40 \nDo you agree or disagree that the calculation of each supplier’s obligation to supply \nSAF should be determined on the basis of energy? \nSummary of responses \nFigure 42 Question 40 summary of responses. \nMost respondents agreed with the proposal to determine each supplier’s obligation on the \nbasis of energy. Reasons for agreeing included that it is an accepted unit within industry, it \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n34 \n31 \n1 \n2 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n97 \nis easily linked to carbon intensity and ensures that the energy density of different fuels are \naccounted for fairly.  \nHowever, of those that agreed, five respondents were not in entire agreement with the \nproposal. Generally, these respondents raised points about the lower heating value (LHV). \nSpecifically, that fuel suppliers often trade in litres so an LHV (in MJ/litre) is needed to \ncalculate the obligation. These respondents requested that DfT provide a default value for \nthis conversion rather than requiring suppliers to measure their own as this would be an \nexcessive administrative burden, costly and could lead to inaccuracies. While agreeing with \nusing the basis of energy, a different respondent questioned why the target is based on \nfossil fuel supplied rather than total fuel supplied, resulting in high and confusing targets.  \nThose that disagreed did so on the basis that the market uses volumes as a standard unit, \nmaking the use of energy confusing and complex. Furthermore, one respondent flagged that \nthe buy-out has been presented in litres and tonnes and would therefore need to be \nconverted to energy using LHV.  \nGovernment response \nGovernment decision: the calculation of each supplier’s obligations to supply SAF \nshould be determined on the basis of energy. We will use mass (kilograms) for the \ncalculation of the obligation, rather than volume (litres).  \nThis means that the Mandate will require obligated suppliers to ensure that a given \nproportion of the total energy provided by the aviation fuel it supplies comes from SAF for \nboth the standard obligation and PtL obligation, in line with the targets set out in questions \ntwo to six and questions 10 to 11, respectively. \nThe obligations are calculated by applying the target (as a percentage) to the amount of \nfossil kerosene (in terms of energy) using the following equations: \n𝑂𝑂𝑂𝑂𝑂𝑂= 𝑚𝑚𝑓𝑓× 𝐿𝐿𝐿𝐿𝑉𝑉\n𝑓𝑓× 𝐸𝐸𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡  \nStandard obligation \n𝑂𝑂𝑂𝑂𝑂𝑂𝑃𝑃𝑃𝑃𝑃𝑃= 𝑚𝑚𝑓𝑓 × 𝐿𝐿𝐿𝐿𝑉𝑉\n𝑓𝑓× 𝐸𝐸𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡\n𝑃𝑃𝑃𝑃𝑃𝑃\n \nPtL obligation \nWhere: \n• 𝑂𝑂𝑂𝑂𝑂𝑂 is the standard obligation incurred by the fossil jet fuel supplier as a result of \ndelivering a fossil kerosene consignment to the UK, in MJ; \n• 𝑚𝑚𝑓𝑓 is the mass of fossil kerosene supplied, in kg; \n• 𝐿𝐿𝐿𝐿𝑉𝑉\n𝑓𝑓 is the lower heating value of the fossil kerosene consignment (i.e. the energy \ncontent), in MJ/kg;  \n• 𝐸𝐸𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡 is the standard Mandate target, as a percentage of energy from produced by \nfossil kerosene supplied to the UK market; \n• 𝑂𝑂𝑂𝑂𝑂𝑂𝑃𝑃𝑃𝑃𝑃𝑃 is the PtL obligation incurred by the fossil jet fuel supplier as a result of \ndelivering a fossil kerosene consignment to the UK, in MJ; and \n• 𝐸𝐸𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡\n𝑃𝑃𝑃𝑃𝑃𝑃\n is the PtL target, as a percentage of energy produced by fossil kerosene \nsupplied to the UK market; \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n98 \n \nTargets will be set based on the total amount of SAF (on an energy basis) that needs to be \nsupplied annually into the UK’s aviation fuel mix. In setting these we have translated what \nthis means for GHG emissions reductions that will be achieved, assuming that SAF achieves \n70% GHG emissions reductions relative to fossil kerosene on average. Therefore, our \nobligation on energy supplied will reduce GHG emissions to the same level, at the same \nrate, as a GHG emissions reductions obligation. \nWe note that several fuel suppliers suggested litres are more commonly used within industry \nfor trading and distribution through pipelines and would therefore be preferable to report in \nlitres rather than kilograms. Volume is subject to external factors, such as a temperature \nand pressure, whereas mass is not. Therefore, mass is more accommodating of fuels such \nas hydrogen, which could be in liquid or gaseous form. However, we recognise that industry \ncurrently reports jet fuel in litres at 15 degrees Celsius to HMRC. Given these are \nstandardised at a given temperature, the Department will convert these figures into mass, \nthereby avoiding additional burden for suppliers.  \nRegarding the LHV, we understand that it can be burdensome or risk inaccuracies for \nsuppliers to measure and report the energy density of each individual consignment. \nTherefore, we can confirm that the government will provide a standard value for LHV \nin guidance. This value will be embedded in the IT system such that suppliers will only need \nto provide the volume of fuel supplied during the obligation period. The LHV used in \ncalculations is yet to be confirmed as we continue to develop the guidance. However, it will \nbe taken from a reputable source or similar scheme, such as the EU Renewable Energy \nDirective (RED) or ICAO, to maintain consistency and fairness on a global scale.  \nCalculation of certificates \nThis section sets out the government’s final position on how the provision of certificates \nunder the Mandate should be calculated.  \nThe government’s final position is to adopt the calculations proposed in the consultation. We \ncan also confirm that the GHG reductions from CCUS will be rewarded under the Mandate, \nincluding where the final net lifecycle emissions are negative. This will ensure that the \nMandate incentivises the use of CCUS in SAF production, delivering increased GHG \nemissions reductions. \nConsultation proposals \nTo discharge their obligation in full, a supplier will be required to redeem a number of \ncertificates equal to their obligation or pay the buy-out price (see section on discharging the \nobligation). To acquire certificates, a supplier can: \n• supply SAF into the UK aviation market; \n• purchase certificates from other SAF suppliers through a trading system (see section \non transfer of certificates); or \n• pay the buy-out fee. \n \nThe second consultation proposed an approach to the calculation of certificates for \nsupplying SAF. We proposed the number of certificates for each consignment is based on \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n99 \nthe energy of the fuel (MJ) and the carbon intensity factor. We also proposed an approach \nof calculating the carbon intensity factor that rewards SAF on a continuous, linear basis, with \nincreasing certificates for every 0.1 gCO2e/MJ savings achieved. This calculation uses a \nreference carbon intensity, which we sought views on. Full details of the calculations are \nconfirmed in the relevant government response sections. We welcomed views on whether \nalternative reward systems should be considered, for example an exponential relationship, \nor banding the reward.  \nThe consultation also asked for feedback on whether emissions savings achieved through \nCCUS technologies should be rewarded under the Mandate, and if so, whether the Mandate \nshould reward negative emissions.  \nQuestion 41 \nDo you agree or disagree with the calculation of certificates set out above? \nSummary of responses \nFigure 43 Question 41 summary of responses. \nMost respondents agreed with the calculation of certificates set out in the consultation. There \nwas broad support for an approach that rewards certificates proportionate to the carbon \nintensity of the fuel, as this will encourage the adoption of the lowest carbon technologies to \nbe adopted in the production of SAF. One respondent also noted that fuels with different \nenergy densities will be rewarded accordingly.  \nA couple of respondents noted that this calculation is tied to the buy-out when considering \nthe level of reward that the mandate offers. They added that most fuels will not be 100% \nGHG saving, therefore the reward per unit mass is reduced substantially.  \nOther comments included recognising the need to have an accurate and robust method of \ndetermining the mass, LHV and carbon intensity, stating a preference for litres or tonnes \nand disagreeing with the baseline lifecycle carbon intensity (see further comments in \nresponse to question 44).  \nGovernment response \nGovernment decision: for SAF that meets the technical and sustainability criteria, the \ncertificates will be determined by the energy of SAF supplied multiplied by a carbon \nintensity factor.  \nWe will calculate the certificates in line with the original proposal in the consultation, with the \nexception that we will use volume instead of mass (as explained in the previous response),  \n  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n32 \n28 \n1 \n3 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n100 \n𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶= 𝑚𝑚 × 𝐿𝐿𝐿𝐿𝐿𝐿\n𝑖𝑖 × 𝐶𝐶𝐶𝐶\n𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 \n𝐿𝐿𝐿𝐿𝐿𝐿\n𝑓𝑓\n \nWhere: \n• 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 is the number of certificates rewarded to a given SAF consignment; \n• 𝑚𝑚 is the mass of a given eligible fuel consignment, in kg; \n• 𝐿𝐿𝐿𝐿𝐿𝐿\n𝑖𝑖 is lower heating value of the eligible fuel (i.e. energy density), in MJ/kg; and \n• 𝐶𝐶𝐶𝐶\n𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 is the carbon intensity factor, as defined in response to question 43 \n• 𝐿𝐿𝐿𝐿𝐿𝐿\n𝑓𝑓 is the lower heating value of jet fuel (i.e. energy density), in MJ/kg. \nAs confirmed in question 17, we will allow fuels other than avtur to be eligible for certificates, \nfor example avgas and hydrogen. Therefore, by basing the number of certificates on energy, \nwe will accommodate the varying energy densities of these fuels such that certificates can \nbe rewarded appropriately without putting certain fuel types at a disadvantage. This will \nultimately lead to decarbonisation across the aviation sector, regardless of the propulsion \nsystem. Should any fuels be added to the mandate in the future, the appropriate LHV can \nbe inserted into the equation without the need to develop an energy multiplier, which should \nhelp avoid inaccuracies. The exact LHV used will be provided by the Administrator in \nguidance and will be based on sound scientific evidence as well as consider equivalent \ndomestic and international schemes.  \nWe have divided the total energy supplied by the energy density of fossil aviation turbine \nfuel so that certificates are issued relative to the energy held in a kilogram of aviation fuel. \nThis will reduce the number of certificates in the system to a manageable level, while still \nensuring the energy densities of specific fuels are accounted for. \nBy scaling the energy with the lifecycle carbon intensity of the SAF, the carbon intensity (CI) \nfactor fulfils one of the key asks from industry for the certificate reward of SAF to be \nproportionate to the GHG emissions reductions it achieves. This approach means that fuel \nwith higher GHG emissions reductions will likely be worth more in monetary value per unit \nenergy supplied and will help industry to develop the most cost-effective carbon abatement \nsolutions.  \nQuestion 42 \nDo you consider there to be any potential issues with fraud adopting a continuous \napproach compared to a banded approach? \nSummary of responses \nFigure 44 Question 42 summary of responses. \nNo respondents thought that there would be a greater risk of fraud associated with a \ncontinuous approach compared to a banded approach. Many respondents argued the \nopposite, given that there will be significant financial incentive for those fuels falling at the \nTotal \nYes \nNeither \nNo \nDon't know \n24 \n0 \n0 \n23 \n1 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n101 \nedge of bands. A couple of respondents noted that the mandate should have suitable \nverification processes in place to ensure any potential issues with fraud are addressed, \nregardless of which reward system is adopted.  \nIn addition to this, most respondents underlined that a continuous system is far more \neffective at incentivising GHG emissions reductions. This is because a continuous system \nwill encourage producers to make any possible improvement in carbon intensity, whereas a \nbanded approach does incentivise savings beyond the minimum level of the band. \nFurthermore, if bands are too wide, it would not fairly differentiate between fuels with \ndifferent GHG emissions reductions.  \nFinally, some respondents also considered that a banded approach may have unintended \nconsequences, with SAF that falls on the wrong side of a band being exported if they can \nclaim a higher reward elsewhere.  \nGovernment response \nWe have considered the responses to questions 42 and 43 together - see government \nresponse following question 43. \nQuestion 43 \nDo you agree or disagree with the calculation of the carbon intensity factor? \nSummary of responses \nFigure 45 Question 43 summary of responses. \nMost respondents agreed with the proposed calculation of the carbon intensity factor. \nHowever, most of these respondents did not provide any further justification. One \nrespondent commented that the proposed approach is a fair way of ensuring SAF with a \nlower carbon intensity is rewarded a greater number of certificates.  \nAll three of those that disagreed did so on the basis of the baseline lifecycle carbon intensity. \nOne respondent proposed that the value of the baseline lifecycle carbon intensity should be \n35.6 gCO2/MJ (equal to 60% reduction). The other two respondents did not think that the \nsupply of SAF should ever receive below one certificate and instead preferred the baseline \nlifecycle carbon intensity to equal the minimum GHG emissions savings threshold.  \nGovernment response \nThe primary objective of the Mandate is to deliver GHG emissions reductions contributing \nto our 2050 net zero target and in line with the 2022 Jet Zero Strategy. The proposal \npresented in the consultation was designed to ensure that the SAF mix will deliver its GHG \nreduction targets, averaged over all of the SAF supplied in the UK during an obligation \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n26 \n22 \n0 \n3 \n1 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n102 \nperiod. We are therefore pleased that many respondents agreed with the calculation set out \nand can confirm the calculation of the CI factor as originally proposed. \nGovernment decision: the CI factor for a given SAF consignment will reward SAF on \na continuous, linear basis relative to the CI of a reference SAF consignment. We will \nintroduce a reward SAF with increasing certificates for every 0.1 gCO2e/MJ savings \nachieved per unit of energy of SAF supplied.  \nThe CI factor is expressed in the following equation:  \n𝐶𝐶𝐶𝐶\n𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓= 𝐶𝐶𝐶𝐶\n𝑓𝑓−𝐶𝐶𝐶𝐶𝑆𝑆𝑆𝑆𝑆𝑆\n𝐶𝐶𝐶𝐶\n𝑓𝑓−𝐶𝐶𝐶𝐶𝑏𝑏\n \nWhere: \n• 𝐶𝐶𝐶𝐶\n𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 is the carbon intensity factor; \n• 𝐶𝐶𝐶𝐶\n𝑓𝑓 is the lifecycle carbon intensity of fossil kerosene, in gCO2e/MJ (this is fixed at 89 \ngCO2e/MJ for Jet-A1); \n• 𝐶𝐶𝐶𝐶𝑆𝑆𝑆𝑆𝑆𝑆 is the lifecycle carbon intensity of the supplied SAF consignment, calculated in \nline with the GHG emissions methodology prescribed by the Mandate, in gCO2e/MJ; \nand \n• 𝐶𝐶𝐶𝐶𝑏𝑏 is the lifecycle carbon intensity of a reference SAF which is assumed to achieve \nthe average GHG emissions reductions, in gCO2e/MJ (see response to question 44 \nbelow for value for reference SAF CI). \nThis means that, depending on the CI of SAF supplied, the factor could be more or less than \none. Therefore, the CI factor will influence the amount of SAF needed to generate sufficient \ncertificates to offset a given obligation, but this will ensure that a fixed emissions saving is \nachieved for SAF overall.  \nThroughout the consultation responses and wider evidence reviewed, we did not see any \nsignificant risk of increased fraudulent activity of a continuous system versus a banded \napproach. By implementing a continuous system, this will introduce an incentive for \nsuppliers to continually improve the CI of the fuel mix. This will broaden the routes to \nreducing the CI of the SAF to encourage even incremental savings to be achieved, for \nexample, efficiencies in the production process. Ultimately, this will lead to emission \nreductions throughout the lifecycle of SAF. \nQuestion 44 \nIs 26.7 gCO2e/MJ an appropriate assumption for the average carbon intensity of SAF? \nPlease provide any available evidence if suggesting an alternative value. \nSummary of responses \nFigure 46 Question 44 summary of responses. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n29 \n16 \n3 \n8 \n2 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n103 \nMost respondents agreed that 26.7 gCO2/MJ is an appropriate figure for the average carbon \nintensity of SAF as it reflects current assumptions about its achievable GHG emissions \nreductions. One respondent agreed on the basis this carbon intensity is the same as the \nminimum GHG emissions savings threshold of the EU for RFNBOs. Another respondent \npointed out that this figure is in line the US Renewable Fuel Standard figure of SAF produced \nfrom municipal solid waste (MSW).  \nOf those that disagreed, half suggested that the baseline lifecycle carbon intensity should \nbe 65% reduction (31.15 gCO2/MJ) to align with the RTFO requirement for development \nfuels. Similarly, one respondent suggested 60% while another felt that 70% would be too \nlow. Another key reason for disagreeing was that the calculation should not be based on an \nassumption and will likely lead to a moving target as it is updated over the years. If possible, \nsome respondents requested that the government uses actual values while others \nsuggested following a similar mechanism to CORSIA to incentivise carbon savings. Finally, \none respondent disagreed because the 70% figure is based on the unweighted average \ncarbon intensity of all SAF pathways and does not account for the growth of different \npathways.  \nA few respondents requested that the government provides clarity on how this figure will \nevolve over time. This included suggestions that the figure should be kept under review and \nupdated to reflect the carbon intensity of real world SAF supplied under the mandate. \nHowever, other respondents requested that the government fixes the carbon intensity for \nthe duration of the mandate to provide certainty.  \nFinally, a couple of respondents noted that it is critical the government considers the buy-\nout price when setting the baseline carbon intensity as this will significantly impact project \neconomics.  \nGovernment response \nThe reference CI which is integral to calculating the carbon intensity factor and in turn reward \nof certificates for a given SAF consignment. If SAF supplied has the same CI as the \nreference SAF, it will have a CI factor of one and therefore receive one certificate per unit of \nenergy supplied. Therefore, setting the reference SAF is critical to ensuring that the mandate \ndeliver the GHG reduction objectives it is set out to achieve. If it is set too low, then SAF will \nbe over rewarded and vice versa.  \nGovernment decision: the reference CI of SAF will be set at 26.7 gCO2e/MJ (equal to \n70% reduction to fossil jet fuel).  \nWe recognise that the SAF industry is nascent and therefore there is limited actual data to \nreview beyond HEFA production. Rather, estimates must be made based on modelling and \nprojections which can vary between projects even if adopting the same technology and \nfeedstock. It is therefore challenging to accurately assess the average lifecycle CI across all \nSAF pathways until production scales up and more real-life data becomes widely available.  \nAll projections and modelling to date show that 70% reduction compared to fossil jet fuel is \na reasonable assumption for an average SAF consignment. Critically, it will ensure that the \nmandate achieves the GHG reductions target. Furthermore, it is in line with minimum \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n104 \nrequirement of the EU mandate, so that we can maintain consistency on an international \nscale of the GHG emissions reductions that SAF should achieve.  \nQuestion 45 \nIn your view, should GHG reductions from CCS be rewarded under the SAF Mandate? \nIf so, should the reward extend to net negative emissions (i.e. less than 0 gCO2e/MJ \non a lifecycle basis), or should these be supported by an alternative GGR policy or a \ncombination of policies? \nSummary of responses \nFigure 47 Question 45 summary of responses. \nMost respondents answered that the Mandate should reward CCUS and extend this reward \nto net negative emissions. The main reason being that this will maximise the GHG emissions \nreductions by delivering SAF with lower carbon abatement costs, helping realise the key \nobjective of the Mandate to maximise GHG emissions reductions from aviation. \nRespondents viewed it as a critical technology to achieve net zero aviation by 2050, \nparticularly considering the need to ensure best use of limited biogenic feedstock. Other \ncomments included that rewarding CCUS would reduce costs to airlines and consumers, \nincrease investment in SAF production and GGR technologies, and be a logical inclusion to \nthe GHG incentive scheme in the Mandate.  \nIf the Mandate did not reward CCUS and negative emissions, respondents felt this would \nintroduce unnecessary complexity, uncertainty and risk. This is due to other policies, such \nas the GGR business model, not yet finalised. As a result, there is no guarantee that SAF \nproduction plants will qualify for these DESNZ CCUS support schemes or that the \ninteractions between these schemes and the mandate may not be favourable to the SAF \nproduction plant. This would ultimately lead to greater uncertainty on revenue for SAF plants \nand negatively impact investment decisions. Respondents felt that treating production \npathways that have greater potential for CCUS or negative emissions differently to others \ngoes against the technology neutral approach and does not create a level playing field.  \nSome respondents recognised that there are complexities, such as how CCUS outside of \nthe UK is accounted for and interactions with other domestic policy, which need to be \naddressed. One respondent felt that uncertainty on other domestic policy means that a \ndecision on the Mandate cannot be made yet on what policy instrument is most suited to \nrewarding negative emissions. Only one respondent argued that DESNZ Greenhouse Gas \nRemoval (GGR) policy would be better placed to support emissions reductions from net \nnegative emissions. However, many respondents suggested that suppliers should have the \nflexibility to decide whether they claim emissions reductions from CCUS or negative \nemissions under either the Mandate or an alternative scheme. \nReward \nTotal \nYes \nNo \nDon't know \nCCUS \n40 \n38 \n1 \n1 \nNegative \nemissions \n36 \n30 \n4 \n2 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n105 \nSeveral respondents underlined the importance of adopting robust carbon accounting \npractices and avoiding any double counting of negative emissions. Comments included \nensuring that CCUS reductions are certified and permanent, avoiding the use of \nassumptions such as avoided methane, including other forms of sequestration such as \nbiochar in the lifecycle analysis and following the Climate Change Committee (CCC) \nguidance to remove upstream negative emissions from the GGR sector.  \nOther comments in response to this question noted that net negative emissions are already \nrewarded under other similar schemes such as EU RED and CORSIA, that CCUS rewards \nshould not allow sub-standard pathways to become eligible, the need for use of CO2 \nabatement credits from existing schemes for those that do not have access to CCS capacity, \nand that SAF cannot ever achieve net negative emissions due to its combustion.  \nGovernment response \nThe primary objective of the Mandate is to deliver GHG emissions reductions. One of the \nkey enablers to reduce the lifecycle GHG intensity of certain SAF pathways is CCUS. The \neffectiveness of this technology is dependent on the feedstock and production pathways. It \nis most effective in pathways that release highly concentrated CO2 streams, which ensures \nthe emission reductions are maximised. In some cases where biogenic feedstock is used, \nthe addition of CCUS in SAF production could result in net negative emissions across the \nproject lifecycle. As stated in the consultation, we are therefore keen to encourage the \nincorporation of CCUS in SAF production. Although other schemes are designed to \nspecifically encourage the uptake of CCUS installations and CO2 transport and storage \n(T&S), we agree with respondents that the Mandate should reward the emission reductions \nfrom SAF production using CCUS.  \nGovernment decision: the emission reductions from CCUS will be rewarded under \nthe Mandate, including where the final net lifecycle emissions are negative.  \nSAF production is one of several sectors that are compatible with CCUS and will facilitate \nthe establishment a UK CCUS market that unlocks economic opportunities and maximises \nGHG emissions reductions. Since 2021, the government have established the roll-out \nprocess and identified the first four CCUS clusters for deployment in the UK by 2030 to \ndelivering an ambition to capture 20-30 MtCO₂ per year. To deliver on this ambition, the \nUK’s CCUS Programme offers government support to companies via various Contract for \nDifference style business models to support the addition of CCUS technology to a facility. \nThe business model most relevant to SAF production39 is the Waste Industrial Carbon \nCapture (ICC) business model, which is designed to support decarbonisation of the waste \nsector. The business model comprises (i) a capital grant to support during the construction \nphase, and (ii) revenue support for 10-15 years, to cover capex, opex and CO2 transport \nand storage (T&S fees) and (iii) access to the T&S network. \nAs confirmed in the response to question 25 of this document, the Mandate will reward \ncertificates in proportion to the GHG emissions reductions of a given SAF consignment. The \nadditional certificates and therefore revenue from the mandate reward is likely to provide a \n \n39 SAF producers and other relevant stakeholders are advised to look up guidance to determine which \nbusiness model the SAF production plant is eligible for.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n106 \nsignificant incentive for a producer to utilise CCUS. Therefore, if a SAF plant is subsidised \nvia the Waste ICC Business Model in combination with the Mandate, the plant may receive \nrevenue significantly beyond what is required to incentivise CCUS deployment.  \nThe ICC business models are designed to alleviate the barriers preventing industrial facilities \nfrom deploying CCUS independently. Whilst access to the T&S network will still be required \nby these projects, as the financial barrier to CCUS may be reduced or removed with the \nintroduction of the Mandate, the support required through an ICC business model may be \nless or, in some cases, no longer needed. In an update published in March 202440, DESNZ \nconfirmed that business model support may therefore be adjusted. The exact mechanism \nthrough which this adjustment will occur is still to be confirmed.  \nIn terms of what the Mandate considers as eligible CCUS technologies, we plan to align with \nthe definitions that are being developed by DESNZ, which outline key aspects such as \npermanence and viable storage solutions.  \nDischarge of obligation \nThis section sets out the government’s final position on the administrative processes for \nsuppliers and the Administrator to discharge obligations and the calculation of the HEFA \ncap.  \nConsultation proposal \nGiven that the Mandate will prescribe a maximum amount of HEFA that can be used to meet \nthe standard obligation and a separate PtL obligation, we proposed that: \n• HEFA will generate HEFA certificates; \n• PtL will generate PtL obligation certificates; and \n• all other types of SAF, including low carbon hydrogen and low carbon drop-in \nreplacement for avgas, will generate standard Mandate certificates. \nAt the end of the obligation period, we proposed the same actions to discharge the obligation \nas currently in practice in the RTFO. That is: \n• The final obligations are calculated on 15 August following the obligation period as \nsum of obligations incurred through the supply of fossil kerosene, throughout the \nobligation period; \n• Each supplier must redeem certificates against the relevant obligation by 15 \nSeptember; and \n• The obligation is wholly discharged once a supplier redeems an equal number of \nrelevant certificates against the obligation.  \nThe government is keen to encourage the supply of SAF beyond the target set in the \nMandate. In particular, where a supplier has an excess of PtL certificates but does not have \nsufficient certificates to fulfil the main obligation. Therefore, it was proposed that:  \n \n40 Carbon capture, usage and storage (CCUS): business models - GOV.UK (www.gov.uk)  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n107 \n• a PtL obligation can only be redeemed using PtL certificates; and \n• a standard obligation can be redeemed using any type of certificates, though the \nmaximum number of HEFA certificates that can be used is determined by the cap. \nAs set out in Chapter two, we propose to introduce a cap on the amount of HEFA than can \ncount towards the standard obligation. In the consultation, we proposed the maximum \nnumber of HEFA certificates that can be redeemed against the main obligation is calculated \nby applying the HEFA cap (as a percentage of SAF supplied) to the amount of fossil \nkerosene (in terms of energy). \nWe proposed that the amount owed by the supplier that does not wholly discharge the \nobligations will be calculated by multiplying the main and PtL buy-out price by the respective \ncertificate shortfall, which will be sent to suppliers on 27 September and should be paid by \n26 October. We proposed that any unpaid buy-out amount will be subject to an annual \ninterest of 5% above the base rate set by the Bank of England.  \nQuestion 46 \nDo you agree or disagree with the steps taken by the Administrator and the supplier \nto discharge the obligation at the end of a period? \nSummary of responses \nFigure 48 Question 46 summary of responses. \nAlmost all respondents agreed with the steps set out in the consultation, largely on the basis \nthat these steps and timings are logical and consistent with the approach taken under the \nRTFO Order, which has been successfully implemented over several years.  \nSome of those who agreed suggested amendments including setting a deadline where SAF \ncertificates can no longer be revoked, reviewing the 5% above the base interest rate and \nconsidering options to provide more flexibility for suppliers complying with the mandate for \nthe first time to allow time for them to adapt.  \nThe one respondent that did not agree outright did not provide any justification.  \nGovernment response \nGovernment decision: we confirm that the steps taken by the Administrator and the \nsupplier to discharge the obligation at the of an obligation period will be the same as \nthe RTFO as set out in the consultation.  \nThe steps set out are identical to those that currently take place under the RTFO Order, \nwhich has been implemented effectively since its inception and refined over time to ensure \nthe process is as clear and efficient for both the Administrator and obligated parties. Many \nrespondents pointed to the effectiveness of the RTFO process and urged the Mandate to \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n24 \n23 \n1 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n108 \nfollow the same process for these reasons. We have not seen any evidence to suggest that \nthe RTFO process for discharging the obligation should not be replicated under the SAF \nMandate. Detailed guidance will set out all the actions to be taken by relevant parties and \nby which dates.  \nQuestion 47 \nDo you agree or disagree with the approach to calculating the HEFA cap? \nSummary of responses \nFigure 49 Question 47 summary of responses. \nMost respondents did not agree with the approach to calculating the HEFA cap. Of these \nrespondents, nine stated that they were against the principle of the HEFA cap, as discussed \nin questions seven and nine.  \nRegarding the calculation itself, many respondents identified an error in the formula \npresented in the consultation. Specifically, that the calculation is using a mixture of fossil \nfuel and SAF terms, such that the cap would not be calculated correctly. A few respondents \nsuggested that the approach to the HEFA cap should mirror that of the crop cap in the RTFO \nwhere the government simply provides a percentage, which would provide greater certainty \nfor suppliers. Furthermore, some respondents asked the government for more clarity on how \nthe HEFA cap applies to individual suppliers given that the obligation will be applied in \nenergy terms.  \nThose respondents in agreement simply stated that they approve of the methodology.  \nGovernment response \nWe recognise many respondents disagreed with the proposal out of principle of including a \ncap on HEFA feedstocks in the Mandate. These responses have been addressed in Chapter \nOne.  \nIt is important that the cap on HEFA feedstocks is calculated accurately and in proportion to \nthe obligation itself. Several respondents pointed out during the consultation the original \ncalculation proposed did not meet these objectives due to using a combination of both fossil \njet fuel and SAF variables. The confirmed calculation has been amended since the \nconsultation.  \nGovernment decision: the HEFA feedstock cap will be calculated as a percentage of \nthe total fossil jet fuel or SAF that does not meet the sustainability criteria.  \nThis is determined using the calculation below: \n \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon’t know \n26 \n9 \n0 \n17 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n109 \n𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝑐𝑐𝑐𝑐𝑐𝑐= 𝑚𝑚𝑓𝑓× 𝐿𝐿𝐿𝐿𝑉𝑉\n𝑓𝑓 × 𝐸𝐸𝑐𝑐𝑐𝑐𝑐𝑐\n𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻  \nWhere: \n• 𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝑐𝑐𝑐𝑐𝑐𝑐 is the maximum amount of HEFA certificates that can be redeemed against \nthe standard obligation; \n• 𝑚𝑚𝑓𝑓 is the total volume of fossil kerosene supplied in that obligation period, in kg; \n• 𝐸𝐸𝑐𝑐𝑐𝑐𝑐𝑐\n𝐻𝐻𝐻𝐻𝐻𝐻𝐻𝐻 is the HEFA cap, as a percentage of the fossil jet fuel supplied (see Chapter \nOne); \n• 𝐿𝐿𝐿𝐿𝑉𝑉\n𝑓𝑓 is the lower heating value of the fossil kerosene consignment (i.e. the energy \ncontent), in MJ/kg.    \nThe above calculation has been amended so that the amount of HEFA that can be redeemed \nagainst the obligation is in proportion to the fossil jet fuel jet fuel and SAF that does not meet \nthe sustainability criteria. It is also determined using volume instead of mass, in line with \nboth the obligation and calculation of certificates for a given consignment of SAF. This \nfollows the same method by which the crop cap is calculated under the RTFO; however, \nunder the Mandate it is based on energy supplied while under the RTFO Order it is based \non the volume of fuel supplied. This means that, in absolute terms, the greater the energy \nof fossil jet fuel supplied, the greater the number of HEFA certificates that can be redeemed \nby that supplier. \nQuestion 48 \nDo you agree or disagree with the approach to paying the buy-out amount when a \nsupplier does not wholly discharge its obligation? \nSummary of responses \nFigure 50 Question 48 summary of responses. \nWhere a supplier does not redeem sufficient certificates against the obligation, they must \npay a fee equal to main or PtL buy-out price multiplied by the respective certificate shortfall. \nThis is considered a legitimate form of compliance but does not provide any GHG emissions \nreductions.  \nAlmost all respondents agreed with the steps set out in the consultation. The key justification \nwas that the process outlined is consistent with that of the RTFO, which has been successful \nin its implementation and has fair levels of engagement and an appropriate timeframe.  \nRegarding additional penalties if the obligation is not met, a couple of respondents were in \nfavour of either a fixed penalty or applying an obligation “roll-over” to the following obligation \nperiod, to drive the uptake of SAF. However, a couple of respondents explicitly argued \nagainst any additional penalties above paying the buy-out amount, including fixed monetary \npenalties or obligation roll-over. These respondents argued that there are valid reasons for \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon’t know \n28 \n26 \n0 \n2 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n110 \nnot meeting the obligation, such as feedstock availability or supply chain issues, and it would \ntherefore not be proportionate to penalise suppliers.  \nOther comments in response to this question included the need to protect airlines and \nconsumers by prohibiting the passing on of the buy-out fee to suppliers, questioning the 5% \nabove the base interest rate, or outright disagreeing with the buy-out.  \nGovernment response \nAs explained in question 46, any supplier that does not wholly discharge the obligation will \nbe required to pay the buy-out price for the remainder of their obligation. This mechanism is \na critical design element of the Mandate to ensure that suppliers have a viable option to fulfil \ntheir obligation without being subject to disproportionate penalties.  \nGovernment decision: any supplier that does not wholly discharge the obligation will \nbe required to pay the buy-out for the remainder of the obligation by 26 October \nfollowing the obligation period. \nThe buy-out is a legitimate form of fulfilling the obligation. Although the buy-out does create \nan alternative way for suppliers to discharge their obligation, it does not lead to emission \nreductions. It is therefore not intended to be used as a long-term form of compliance, but \nonly for use in exceptional circumstances. For example, in the case of supply chain issues, \nor if there are unusually high spikes in SAF costs. \nGiven that the obligation is determined in energy (see question 40), the buy-out prices will \nbe expressed in pound per megajoule. They will be equivalent to the prices confirmed in \nresponse to questions 12 and 13. \nIn the case where a supplier does not wholly discharge their obligations, the amount owed \nvia the buy-out will be calculated by multiplying the standard and PtL buy-out price (set out \nin question 45) by the respective certificate shortfall. Following the window within which \nsuppliers can redeem certificates against their obligation, we can confirm that suppliers that \nhave a certificate shortfall will be notified of the buy-out amount owed on 27 September and \nwill be required to pay it by 26 October. Should the supplier not wholly discharge the \nobligation with the buy-out by this date, the unpaid buy-out amount will be subject to an \nannual interest of 5% above the base rate set by the Bank of England, but to be calculated \non a daily basis starting from 27 October. This approach, including the dates by which \nactions must be taken, aligns with the RTFO. Generally, respondents approved of aligning \nwith the RTFO and we have not seen sufficient evidence, either via the consultation or \notherwise, to make amendments to this approach. \nSeveral respondents raised points, either in support or opposition, about applying additional \npenalties if the obligation is not wholly discharged. The buy-out price has been set at a level \nthat is above the project market price of SAF so that suppliers are already encouraged to \nredeem certificates as the preferable option of meeting their obligations. As explained above, \nthe purpose of the buy-out is to provide a way for suppliers to discharge their Mandate \nobligation in exceptional circumstances where there is no SAF available (or SAF at a cost \nbelow the buy-out price). As such, any supplier required to pay the buy-out will be subject \nto higher costs than if they had supplied SAF. We therefore do not think it is appropriate to \napply to additional penalties, such as a fixed penalty or an obligation roll-over, on top of \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n111 \nsuppliers paying the buy-out. We have reserved issuing civil penalties to cases where \nsuppliers have intentionally avoided meeting their obligation or failed to meet other \nrequirements stipulated in the legislation (see Chapter Five).  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n112 \n5. Submitting claims, reporting the required \ndata, and fulfilling the SAF obligation \nIt is critical that the fossil jet fuel information submitted by suppliers, as well as the carbon \nand sustainability information of SAF, is credible and accurate such that the obligation and \nreward of certificates can be calculated correctly. It is therefore necessary that the Mandate \nincludes robust processes that suppliers must undergo when providing any relevant data to \nDfT. We propose that an IT system will be developed, which will function as the principal \ntool for both the Administrator implementing the requirements of, and suppliers complying \nwith, the Mandate.  \nRequirement for each obligated party to have an account \nEach obligated supplier will be required to apply for an account with the Administrator. In \nthe consultation we set out the proposed process for registering an account which aligns \nwith current practice under the RTFO Order. This includes the Administrator assessing \nwhether there is sufficient evidence or information in application and the requirement that \neach supplier must create its account within 28 days, starting from the date on which the \nsupplier becomes obligated. We also proposed that the Administrator has the power to close \naccounts in certain situations. \nQuestion 49 \nDo you agree or disagree with the approach to creating and closing accounts? \nSummary of responses \nFigure 51 Question 49 summary of responses. \nAlmost all respondents agreed with the proposed approach to creating and closing accounts, \nwith most respondents not providing further justification. However, a small number of \nrespondents noted their approval for consistency with the RTFO which has ensured only the \nrelevant stakeholders supplying fuel into the market will take part in the scheme. A few \nrespondents broadly agreed with the proposal but noted that some of the verification steps \ncan be burdensome for suppliers. In the case where the same companies are already \nobligated under the RTFO and have undergone a verification process, it was suggested that \nthese companies should be automatically enrolled in the Mandate to avoid duplicating the \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n23 \n22 \n1 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n113 \nverification process. Finally, one respondent suggested that government conducts induction \nprogrammes for new suppliers that may not be familiar with the scheme.   \nGovernment response \nOur proposed approach aligns with that of the RTFO, and we do not see reason to amend \nit.  \nGovernment decision: we will confirm the approach set out in the consultation to \ncreating and closing accounts.  \nWe note that some suppliers stated that the process for creating an account can be \nburdensome. We are planning on using the same IT system for the RTFO and the Mandate. \nWhere suppliers are approved under the RTFO, we will therefore not require them to \nundergo the account creation process again as they will already have an account with the \nAdministrator. However, we will require existing account holders to alert the Department if \nthey will be supplying aviation fuel so that we can amend the account as needed. \nThe duties of the Administrator include identifying suppliers that are expected to be obligated, \nand publicise the obligation appropriately. In line with the Administrator’s powers it will \ntherefore engage with relevant parties ahead of the Mandate commencing to build good \nworking relationships and conduct induction programmes to facilitate compliance.  \nSubmitting claims for SAF certificates \nBefore a supplier can apply for SAF certificates, it was proposed that the supplier must: \n• submit carbon and sustainability (C&S) information and a verifier’s assurance report; \n• submit evidence of the amount of fuel supplied to the UK aviation market; \n• meet the other administrative stipulations discussed in this consultation; and \n• declare that the fuel has not been used towards the targets in other schemes. \nThe Administrator will be required to evaluate the application against the requirements \nstipulated. In the consultation, we underlined that suppliers may choose how often to apply \nfor certificates within the given reporting period. In line with the RTFO, we proposed all \napplications for certificates must be submitted by 12 May following the obligation period. \nWhere each of the requirements described have been met and the application is successful, \nwe proposed that the Administrator will issue the certificate as soon as is reasonably \npractical by crediting the supplier’s electronic account on the IT system. The Administrator \nwill specify whether the certificate awarded is a HEFA, standard or PtL certificate. \nQuestion 50 \nDo you agree or disagree with the approach to submitting claims? \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n114 \nSummary of responses \nFigure 52 Question 50 summary of responses. \nAll respondents to this question agreed with the proposed approach to submitting claims. \nThe main reason given by respondents is that consistency with the RTFO is important and \nthis approach has been successfully implemented for many years as an effective way of \nproviding evidence to support certificate allocation. However, a few respondents asked for \nclarity on the expected requirements on suppliers when submitting evidence on the amount \nof fuel supplied to the UK aviation market, as this will be reported on either a volumetric or \nmass basis rather than energy. A couple of other respondents requested that the \ngovernment keeps the compliance procedure as simple as possible. Finally, one respondent \nmade two additional points: \n• guidance on how to manage the scenario whereby fuel is sold as “dual purpose \nkerosene” and it is not possible to demonstrate that this has been supplied to the UK \naviation market; and \n• timetabling for issuing certificates mirrors that of the RTFO, under which RTFCs are \nissued within a month (subject to the Administrator being satisfied), which is timely \nand considered an important aspect for suppliers.  \nGovernment response \nAs with other proposals in the consultation, alignment with the RTFO processes is preferable \namong stakeholders and we do not see reason to diverge from this approach.  \nGovernment decision: we will confirm the approach set out in the consultation to \nsubmitting claims.  \nThat is, before a supplier can submit claims for certificates for the supply of SAF, it must: \n• submit carbon and sustainability (C&S) information and a verifier’s assurance report; \n• submit evidence of the amount of fuel supplied to the UK aviation market; \n• meet the other administrative stipulations discussed in this consultation; and \n• declare that the fuel has not been used towards the targets in other schemes. \nThis approach aligns with the RTFO in terms of requirements before submitting claims. We \ncan also confirm that the timetabling of issuing certificates will be the same as the RTFO to \nmaintain consistency and ensure that suppliers have continuous opportunity to receive \ncertificates. Our experience from the RTFO is that this process is straightforward and does \nnot cause complications or excessive administrative burden. Regardless, the Administrator \nwill provide induction programmes for suppliers to ensure they are familiar with the process \nahead of the mandate commencing.  \nRegarding the reporting of volumes, each obligated supplier will be required to submit \ninformation on the mass of all fossil, renewable or partially renewable fuels that are covered \nby the SAF Mandate Order. Where necessary, these can be reported in volume (litres at 15 \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n25 \n25 \n0 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n115 \ndegrees Celsius) and the Administrator will convert into mass using standard factors, from \nwhich the energy obligation will be determined. These will be validated by the Administrator, \nas described in more detail in response to question 31.  \nThe assessment time for aviation fuel in the RTFO is set at the blending and certification \npoint, while we have confirmed that the assessment time will be at duty point in the Mandate. \nDuring the first year of the obligation, as SAF moves from the RTFO, a situation may arise \nwhereby SAF has been blended and certified in December 2024 and then passes through \nthe duty point in January 2025, therefore being subject to two assessment times. In this \nspecific case, SAF that meets the RTFO assessment time should not be claimed again when \nit passes the Mandate assessment time as per their declarations of not claiming multiple \nincentives. \nRegarding the comment on dual purpose kerosene, this is addressed in response to \nquestion 50.  \nCarbon and sustainability information \nWe proposed that suppliers must report C&S information demonstrating compliance with the \nsustainability criteria for each application and must arrange for this data to be independently \nverified before submitting an application for SAF certificates. We proposed the process \nwould adopt current practice under the RTFO meaning that suppliers submit data via the IT \nsystem.  \nWe previously confirmed that voluntary schemes (i.e. recognised sustainability assurance \nschemes) would be eligible to count as a route to demonstrate compliance with sustainability \ncriteria. Voluntary schemes are sustainability assurance schemes recognised by the \nAdministrator as demonstrating compliance with one or more of the sustainability criteria. \nExperience from the RTFO shows that verification effort is likely to be reduced where the \nfuel meets a voluntary scheme’s requirements, particularly where those schemes cover the \nfull chain of custody and all of the sustainability data. They are therefore recommended but \nare not mandatory to use to demonstrate compliance.  \nIn the consultation, we underlined that voluntary schemes could be recognised for a specific \nscope and that any C&S data not covered by the scope of the voluntary scheme will be \nsubject to third party verification. We also stated our intention to provide a list of approved \nvoluntary schemes with their respective scope before 2025. Where a supplier does not use \na voluntary scheme, we will set out in guidance how suppliers demonstrate compliance. \nAs confirmed in the government response published in July, suppliers must use a mass \nbalance chain of custody (or a more a stringent chain of custody system) to demonstrate \ncompliance with the SAF Mandate. Where part, or all, of a supply chain is not covered by a \nvoluntary scheme operating a mass balance system, we proposed that suppliers must set \nup their own chain of custody, ensuring that a mass balance approach is used. We stated \nour intention to publish guidance on how to set up a chain of custody and operate a mass \nbalance system.  \nAs confirmed in the government response, C&S data will need to be verified in accordance \nwith the ISAE 3000 standard (or an equivalent standard), by a person who is independent \nof the supplier and who has the necessary expertise. To maintain consistency with the RTFO, \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n116 \nwe proposed that verification should be carried out to the limited level of assurance. \nIt is anticipated that suppliers and verifiers can share data and reports via the IT system. We \nstated our intention to publish guidance on appointing a verifier and the verification process. \nQuestion 51 \nDo you agree or disagree with the approach to reporting, demonstrating compliance \nwith and verifying the carbon and sustainability information? \nSummary of responses \nFigure 53 Question 51 summary of responses. \nMost respondents agreed to the proposed approach of reporting, demonstrating compliance \nwith and verifying the carbon and sustainability information. Reasons included that it is \nconsistent with the RTFO, will minimise administrative complexity and is robust enough such \nthat unverified or falsified data will not be accepted from suppliers. However, a few \nrespondents queried why there is a need to introduce duplicative measures that increase \ncost when a proof of sustainability endorsed under the ISCC or RSB framework would be \nsufficient.  \nRegarding the assurance level, a few respondents did not agree with the proposal on the \nbasis that “limited” assurance allows fraudulent feedstocks in the fuel supply and would not \nbe sufficient to meet the necessary requirements for use in UK ETS or CORSIA.  \nRegarding the sustainability criteria, one respondent pointed out that it is related to the \nfeedstock rather than the SAF itself, while another requested that it be extended to consider \nother factors such as water use, embedded emissions and particulate numbers.  \nFinally, one respondent underlined the role that the UK could have in being a leader in \nestablishing an international standard for book and claim, which will be an important system \nfor a market where supply and demand are geographically distributed.  \nGovernment response \nAs set out in Chapter Two, in order for SAF to be rewarded with certificates it must meet \nstrict sustainability criteria. It is therefore necessary to have processes in place to ensure \nthat suppliers can demonstrate compliance with the carbon and sustainability criteria and to \ngain certificates. This will reduce the need to introduce duplicative measures and minimise \nadministrative complexity.  \nGovernment decision: we confirm that we will adopt the approach to reporting, \ndemonstrating compliance and verifying the carbon and sustainability information as \nset out in the consultation.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n35 \n29 \n3 \n3 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n117 \nWe have aligned our approach with the current rules under the RTFO Order to maintain \nconsistency and facilitate compliance for suppliers operating under both schemes. Although \nthe broad approach to submitting claims will be the same, there may be specific differences \nbetween the RTFO and the Mandate in exceptional circumstances. These will be explained \nin guidance.  \nFor each application (i.e. an amount of fuel that has an identical set of sustainability \ncharacteristics) suppliers must report carbon and sustainability (C&S) information and have \nthis independently verified before submitting a claim for SAF certificates. This is to ensure \nthat SAF meets the stipulated sustainability criteria and to calculate the certificates, which \nare based on the lifecycle carbon intensity of the SAF consignment.  \nC&S reports must contain the information required to demonstrate compliance with the \nsustainability requirements. This will be submitted through the IT system, which will be \ndesigned in a way that is easy for the supplier to use. This includes: \n• feedstock type and country of origin; \n• lifecycle carbon intensity; \n• land criteria; \n• forest criteria; and \n• soil carbon criteria. \nAlthough some stakeholders suggested further information should be reported, we believe \nthat the information required is sufficient to demonstrate the compliance with the \nsustainability criteria. However, we will continue to monitor this closely and consider \nreporting wider environmental impacts that are outside the minimum sustainability criteria, \nfor example, water use and embedded emissions. At the same time, we want to ensure the \nprocess minimises administrative complexity for suppliers as much as possible, while still \nensuring we receive the necessary information to confirm compliance with sustainability \ncriteria.  \nWe previously confirmed that voluntary schemes (i.e. recognised sustainability assurance \nschemes) would be a viable option of complying with sustainability criteria. Using voluntary \nschemes which have been recognised as meeting some or all of the sustainability criteria \nhas been the recommended option for demonstrating compliance as it reduces the \nadministrative burden on suppliers and reduces the verification effort. Under the RTFO, most \nsuppliers use voluntary schemes to demonstrate compliance with C&S requirements. The \ngovernment will publish details on the process of approving voluntary schemes ahead of the \nMandate commencing and will publish a list of approved schemes. However, it will most \nlikely align with the approval process under the RTFO to maintain consistency. Our intention \nis that those schemes approved under the RTFO will be recognised under the Mandate, \nproviding they have demonstrated they can work to the requirements of our legislation. In \nsaying this, suppliers will be eligible to use other means to provide C&S data. Detailed \nguidance on alternative options for demonstrating compliance with each of the sustainability \ncriteria will be published ahead of the mandate commencing.  \nAs confirmed in the previous government response, C&S data must use a mass balance \nchain of custody. This is to ensure C&S data can be tracked back to its original source to \ndemonstrate the fuel supplied meets the sustainability criteria. For wastes and residues, it \nis particularly important that a robust chain of custody is in place to ensure traceability and \nsufficient auditing.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n118 \nVerification of the C&S data is an essential step in the process for submitting claims. It will \nprovide the Administrator with assurance over the information provided by suppliers as a \ncondition of issuing certificates. Verifiers will check that the data submitted to the \nAdministrator meets the requirements of this guidance, and therefore the mandatory \nsustainability criteria. We will be requiring verification to be carried out to limited assurance \nin line with ISAE 3000 standards (or equivalent). A review of the RTFO has concluded that \nit would not be necessary to increase this to reasonable assurance level. However, in some \ncases the Administrator will have the power to require a 'reasonable' level of assurance level. \nFurther information on verification, including appointing a verifier; the roles and \nresponsibilities of suppliers, verifiers and the Administrator in respect of this process; and \nan outline of the steps a verifier will undertake will be provided in guidance. \nSubmitting C&S data, demonstrating compliance sustainability criteria, and verification of \nC&S information are critical processes that suppliers and other relevant parties must follow \nin order for the mandate to operate effectively. The guidance published ahead of the \nMandate commencing will contain comprehensive guidance to ensure these processes are \nfollowed correctly, particularly where complex or unconventional circumstances may apply. \nThis includes, but is not limited to, allocation of GHG emissions, aggregating multiple \nconsignments and changing C&S data.  \nValidating fuel amount information \nWe previously confirmed that obligated suppliers will need to report information on the \naviation fuel supplied to DfT. In the consultation, we proposed that suppliers must provide \ninformation on the mass of fuel, by fuel type, that is owned at the assessment time. We also \nunderlined the necessity to have this information validated, with the simplest approach to \ncheck HMRC duty data against fuel amounts submitted by the supplier. \nWhere a fuel amount is not checkable against HMRC data, we proposed the Administrator \nwill have the power to require further evidence. This could include:  \n• requiring the supplier to provide evidence for each submission;  \n• assessing the systems and processes that the supplier uses to derive these \nquantities on a periodic basis and requiring the supplier to provide assurance to the \nAdministrator that these systems have been used for each submission; or \n• requesting that a supplier obtains independent verification of the quantities. \nQuestion 52 \nDo you agree or disagree that the Administrator should validate fuel amount \ninformation? \nSummary of responses \nFigure 54 Question 52 summary of responses. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n25 \n25 \n0 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n119 \nAll respondents agreed with the proposed approach that the Administrator should validate \nfuel amount information. Most respondents did not provide further justification, although a \nsmall number of respondents noted their approval for consistency with the RTFO. A few \nrespondents broadly agreed but suggested a few amendments including allowing the \nAdministrator to delegate responsibility to a third body and that the validation is between the \nSAF data and the HMRC data, rather than verification of the HMRC data itself (which is the \ncurrent approach under the RTFO Order). Finally, a couple of respondents underlined the \nimportance of protecting commercially sensitive information and ensuring data privacy.  \nGovernment response \nIt is essential that the Administrator has the ability to be able to check that data reported by \nfuel suppliers is accurate, particularly in relation to the volume of obligated fuel and the \nnumber of SAF certificates to be issued.  \nGovernment decision: the Administrator will validate fuel amount information.  \nThe Administrator must validate fuel amounts to avoid suppliers either intentionally or \nunintentionally misreporting jet fuel supplied to the UK. If validation was not in place, these \ninaccuracies would lead to errors in calculation of obligations or certificates, as well as \ncarbon accounting.  \nUnder the RTFO, fuel amounts have been validated by the Administrator since the scheme \ncame into being in 2008. The current approach whereby the Administrator takes \nresponsibility has been effective and is not overly burdensome. Therefore, we will continue \nto use the Administrator to validate fuel amount information, though the approaches by \nwhich the Unit carries this out may differ to the RTFO Order (see question 31).  \nCurrently under the RTFO, the principal method that the Administrator uses to validate \nvolume submissions is to check a supplier's submitted figures against HMRC duty payment \ndata. However, given aviation fuel is typically not subject to duty, it may not be possible to \nuse the same approach. Further information on how the Administrator will validate fuel \namount information where is not checkable against HMRC data is provided in response to \nthe question below.  \nQuestion 53 \nDo you agree or disagree to the powers granted to the Administrator to validate fuel \namounts where information is not checkable against HMRC data? \nSummary of responses \nFigure 55 Question 53 summary of responses. \nAll respondents agreed with the proposed powers. Although no further comments were \nprovided in support of agreement, a few respondents had further clarification points. This \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n23 \n23 \n0 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n120 \nincluded that these powers are unlikely to be used to a significant extent given the coverage \nof HMRC data, the level of evidence verification required should be consistent with other \ninformation such as carbon and sustainability information, and the government must protect \ncommercially sensitive information and ensure data privacy. \nGovernment response \nCurrently, under the RTFO, we use HMRC data as a third-party data source to verify that \nthe volumes suppliers provide us are correct. This is still the preferred option for verification \ndue to ease for both the Administrator and supplier. However, whilst aviation fuels should \nbe reported to HMRC, it is not a complete dataset and the current reporting does not \ndifferentiate between fossil jet fuel and SAF. Therefore, we need to consider a second option \nto provide assurance that the volumes being uploaded are accurate. \nGovernment decision: the Administrator will require suppliers to seek verification of \ntheir aviation fuels by a third party verifier. \nWe have considered several options to find a simple solution to sourcing a complete dataset. \nSince the consultation, we have informally consulted with stakeholders most likely to be \nimpacted by this delivery decision, to discuss the option of increasing the scope of verifiers \nto provide assurance of volumes. Most respondents were in favour of the solution and saw \nthe efficiency benefits it would bring.  \nSome respondents suggested that it would increase costs and an alternative option could \nbe for HMRC to change their forms to improve reporting. We will explore this option however \non the basis that this may not be possible in time for 1 January 2025 we will continue with \nusing third party verifiers to verify the aviation fuel. Whilst asking verifiers to provide \nassurance over volumes might increase costs, these are expected to be minimal. It is up to \nthe fuel suppliers where they allocate those costs within their business.  \nThe RTFO Unit already have the power to request verifiers to provide volume assurance \nunder the RTFO Order, so this decision also aligns the approach to the Mandate. Verification \nof aviation volumes will be built into the online reporting platform.  \n \nTransfer of certificates \nWe previously confirmed that suppliers will be able to trade certificates. It was proposed that \nthe process of transferring certificates between suppliers will be the same as that in the \nRTFO currently meaning that the pricing and financial aspects of the trade will be outside \nthe Administrator’s scope and systems. However, in order to perform the transfer, the \naccount holder is expected to notify the Administrator of basic information via the IT system \nincluding name and account number, date of transfer and number of certificates. In the event \nof there being an insufficient number of certificates for multiple transfer, we proposed the \nAdministrator will give priority to the transfer which was first notified. We intend to allow \nsuppliers to be eligible to transfer certificates as many times as they wish. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n121 \nQuestion 54 \nDo you agree or disagree with the approach to transfer of certificates? \nSummary of responses \nFigure 56 Question 54 summary of responses. \nAlmost all respondents agreed with the proposed approach to the transfer of certificates. \nRespondents recognised the benefit of a tradeable certificate scheme to offer flexibility in \nmeeting the obligation and noted the consistency of the approach with the RTFO which has \nbeen successful in its implementation. One respondent suggested that transfers should not \nbe limited to obligated parties and “trading only” accounts included. One respondent \ndisagreed with the proposal as they felt it would be used to circumvent obligations.  \nGovernment response \nWe are pleased that respondents reacted positively to our proposal on the transfer of \ncertificates. We view this mechanism as a key part of the mandate as it provides SAF \nsuppliers with a direct price support mechanism and allows obligated suppliers to meet their \nobligation in a flexible and cost-effective manner. We proposed an approach that aligns with \nthe RTFO, and we have not seen sufficient evidence to diverge from this approach. \nGovernment decision: we confirm the approach to transfer of certificates as set out \nin the consultation.  \nSuppliers will have the option to transfer certificates from one account to another for a \nmonetary value determined by the account holders involved (this includes accounts that are \nnot subject to an obligation). The transfer will be actioned via the same IT system that \nsuppliers will use to their manage accounts and discharge their obligation. As with the RTFO, \nwe will allow suppliers to set up delayed transactions to occur in the future. Further \ninformation on special circumstances surrounding the transfer of certificates will be provided \nin guidance, for example, where there are disputes.  \nIntroducing flexibility in fulfilling obligation \nIn the consultation, we proposed that excess certificates can be used to fulfil up to a given \nproportion of the obligation in the following obligation period. More explicitly: \n• standard certificates can be used to fulfil up to 25% of a supplier’s standard obligation \nin the following obligation period; \n• PtL certificates can be used to fulfil up to 25% of a supplier’s PtL obligation in the \nfollowing obligation period; and \n• HEFA certificates can be used to fulfil the standard obligation in the following \nobligation period up to 25% of the HEFA cap.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n30 \n29 \n0 \n1 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n122 \nWe also proposed that excess PtL certificates can be used to fulfil the main obligation. \nQuestion 55 \nDo you agree or disagree that excess certificates can be used to fulfil the obligation \nin the following period? If so, do you agree or disagree with the proportion of the \nobligation that the excess certificates can fulfil? \nSummary of responses \nFigure 57 Question 55 summary of responses. \nMost respondents agreed that excess certificates can be used to fulfil the obligation in the \nfollowing period. The main arguments put forward in support of this were that it provides \nflexibility for obligated suppliers, it provides certainty to SAF suppliers, and it is consistent \nwith the RTFO.  \nNine respondents commented on the proportion of the obligation that can be filled with \nexcess certificates, of which four of these respondents agreed with 25%. Two respondents \nsuggested 20% instead as this would align with US Renewable Fuel Standard, a higher \nproportion could dampen the certificate price and suppliers should not be incentivised to \npurchase SAF a year in advance. Other suppliers suggested that the proportion should be \nhigher or have no limit at all. Finally, one supplier suggested 10% to ensure stable SAF \nsupply and scale up throughout the years and facilitate better demand planning for jet fuel \nsuppliers.  \nA couple of respondents disagreed with the proposals on the basis that these could be used \nto circumvent obligations.  \nGovernment response \nThis mechanism has been in place under the RTFO and has been an effective tool for \nsuppliers to manage fluctuations in supply of renewable fuel over obligation periods and to \nmeet their obligation in a cost-effective manner.  \nGovernment decision: we confirm that excess certificates gained during an obligation \nperiod can be used to discharge the obligation in the following obligation period. For \nstandard certificates and PtL certificates, excess certificates can be used to fulfil up \nto 25% of the obligation period in the following year. For HEFA certificates, excess \ncertificates can be used to fulfil up to 25% of the cap of the following year.  \nA key benefit of this approach is that suppliers are not required to obtain the exact number \nof certificates within a given obligation period to offset their obligation. This will lead to cost \neffective compliance and greater certainty for suppliers which will always be rewarded with \ncertificates for the supply of SAF (even where supply has exceeded targets). This \nmechanism could encourage suppliers to go beyond their target, potentially increasing the \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n30 \n26 \n2 \n2 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n123 \noverall amount of SAF supplied to the UK aviation market. We have found this approach to \nbe effective under the RTFO. The figure of 25% has been used under the RTFO which we \nbelieve it an appropriate amount to provide the flexibility to suppliers while also ensuring the \ncontinuous supply of over consecutive obligation periods. A higher amount would risk \ngreater fluctuations in fuel supply, while a lower amount limits flexibility for suppliers. \nThis mechanism is termed “carry-over” whereby obligations are met with certificates issued \nin the preceding period. The IT system will not allow certificates to be redeemed against \nobligation that meet more than 25% of the main and PtL obligations with certificates from \nthe previous obligation period. \nIf targets are being met and a significant amount of excess certificates are available for use \nin the next obligation period, we will consider whether to increase targets. \nQuestion 56 \nDo you agree or disagree that excess PtL certificates can be used to fulfil the main \nobligation? \nSummary of responses \nFigure 58 Question 56 summary of responses. \nMost respondents agreed with the proposal that excess PtL certificates can be used to fulfil \nthe main obligation. Respondents in agreement recognised that it would offer flexibility to \nsuppliers and is consistent with the RTFO approach of development fuel certificates. Given \nthe higher value of PtL certificates, one respondent suggested that a multiplier should be \nconsidered while another stressed that standard certificates must not be used to fulfil the \nPtL obligation.  \nThose in disagreement did so on the basis that they disagree with the introduction of a \nseparate PtL obligation, rather than the specific proposal to allow excess PtL certificates to \nbe used in the main obligation. Please see question 11 for more information on the \nresponses to an introduction of a PtL obligation.  \nFinally, a couple of respondents pointed out an error in the consultation text which stated \nthat any development fuel certificates in the RTFO awarded in 2024 would not be able to be \nused in 2025.  \nGovernment response \nWe are pleased that most respondents agreed with the proposal to allow PtL certificates to \nbe used to fulfil the standard obligation. This is a similar approach to the RTFO, where \ndevelopment fuel certificates can be used to fulfil the main obligation.  \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n33 \n28 \n0 \n5 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n124 \nGovernment decision: we confirm that PtL certificates can be used to fulfil the main \nobligation.  \nThis will ensure that suppliers with excess PtL certificates can utilise their certificates if they \ndo not wish, or are not able, to sell them to other suppliers. Furthermore, if PtL is available \nto the market earlier than anticipated and precedes the introduction of the PtL obligation, \nsuppliers that have received PtL certificates will still have a viable use of these certificates. \nThe IT system will allow any amount of PtL certificates to be redeemed against the standard \nobligation in that year, or 25% of the standard obligation in the following year. However, it \nwill not be possible for standard certificates to be redeemed against the PtL obligation – this \ncan only be fulfilled with PtL certificates or by paying the buy-out for any certificate shortfall.  \n \n \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n125 \n6. Interactions with other policies and airline \noperations \nClaiming support for SAF across multiple schemes  \nIt is important that the Mandate does not allow fuel suppliers to claim reward under multiple \nschemes, avoiding over-subsidisation of low carbon fuels. As a result, the government \nresponse to the first consultation confirmed that the SAF Mandate legislation, will include \nprovisions that, from 1 January 2025, SAF will no longer be eligible for certificates under the \nRTFO. \nThe first government response also confirmed that SAF that has been produced from \nindustrial plants or clusters which have received competitive grant funding from the \ngovernment will still be eligible for support under the proposed Mandate. This is necessary \nto secure long-term investment in these plants and develop the UK SAF industry. \nIn the consultation we proposed that, as far as possible, the Mandate should align with \nmultiple incentive rules set out in the RTFO Order. We also underlined that work is ongoing \nto ensure that multiple incentive rules are adjusted following the UK’s exit from the EU, \nbalancing the need for a level playing field under the SAF Mandate and the operations of \nthe UK's Trade Remedies Authority.  \nQuestion 57 \nDo you agree or disagree with the proposed approach to align Mandate multiple \nincentives rules as much as possible with the RTFO? \nSummary of responses \nTotal  \nAgree  \nNeither agree nor disagree  \nDisagree  \nDon't know  \n32 \n23 \n8 \n1 \n0 \nFigure 59 Question 57 summary of responses. \nMost respondents either agreed or broadly agreed with the proposal to align the multiple \nincentives rules as much as possible with the RTFO. There was a broad preference for \nconsistent policy design alignment as it reduces complexity and facilitates compliance for \nsuppliers already familiar with the RTFO.  \nHowever, many respondents requested further details on the specific interactions between \nschemes. For example, whether airline operators will be able to claim SAF under the UK \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n126 \nETS or CORSIA. Generally, these respondents felt that there are challenges with the current \nmultiple incentive rules in the RTFO that need to be worked through for the Mandate. \nThe key issue raised by respondents was that of stacking incentives. Several respondents \npointed out that other countries or regions are building competitive SAF industries by \ncombining support schemes, available throughout the SAF supply chain, to improve the \nfiscal package and provide greater assurance to investors. Among respondents, there was \ngeneral concern that the current rules put UK SAF producers at a disadvantage as the \nMandate will allow multiple incentives abroad, but not domestically.  \nSome respondents argued that SAF supplied in the UK should be able to access other \nsubsidies along the supply chain, which would be consistent with the EU approach. One \nspecific example raised by respondents was allowing access to hydrogen that has received \nsubsidy under the Hydrogen Production Business Model, which would dramatically reduce \nthe cost of SAF. Other respondents suggested that production incentives out of the UK must \nbe excluded for any fuel that wishes to claim SAF Mandate certificates. Regardless, there \nwas consensus that the Mandate should treat domestic SAF and international SAF equally.  \nRelated to multiple incentives, several respondents urged the government to provide clarity \non how information for a given SAF consignment is passed between the Mandate and the \nUK ETS so airlines are able to make ERCs. These respondents suggested that the UK could \nadopt a dual certificate system covering both schemes. Alternatively, a clear mechanism to \nallow airlines to confirm that the SAF has not been claimed in other jurisdictions to decrease \ntheir UK ETS obligations. \nGovernment response \nGovernment decision: We confirm that we will align the rules for multiple incentives \nin the SAF Mandate with the RTFO as much as possible, subject to the outcome of \nthe multiple incentives targeted consultation.  \nA targeted consultation on multiple incentives ran from 29 February 2024 – 18 March 2024. \nOur intention is that any changes to the multiple incentives rules will be implemented from \nthe start of the SAF mandate. This will be supplemented with appropriate guidance for \nsuppliers.  \nThe decision to align the rules for multiple incentives in the Mandate and RTFO is \nunderpinned by the need to ensure that we are maintaining a level playing field for suppliers \nacross the two schemes. The rules will also ensure a level playing field on an international \nbasis following the UK’s departure from the EU. This approach will allow us to maintain fair \nreward for low carbon fuel and chemical precursors41 under both the RTFO and Mandate, \nwithout adding complexity to an already familiar compliance process. \nWe recognise there is stakeholder appetite for further clarity on how the multiple incentives \nrules will work with other existing schemes such as UK ETS and CORSIA. Our multiple \nincentives rules will ensure that SAF Mandate legislation allows a given SAF consignment \n \n41 Chemicals used in the production of fuel that contribute atoms and energy to the final product.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n127 \nto be rewarded under the Mandate as well as being used by airlines to make emissions \nreduction claims under the UK ETS or CORSIA.  \nIt is also important that the sustainability credentials for each consignment of SAF is passed \nthrough to end users, to allow SAF use to be claimed by airlines against their obligations in \nother schemes, such as UK ETS or CORSIA. We are working closely with DESNZ, the \nEnvironment Agency and voluntary schemes to develop a solution that will allow \nsustainability credentials for a given SAF consignment to be passed down onto end users, \nwhile ensuring that strict audit requirements continue to be upheld and there is no double \ncounting of emissions savings. Further information on interactions between the Mandate \nand these schemes will be provided in guidance. We will also reflect on information \nsubmitted as part of the upcoming UK ETS Authority consultation on the future of SAF in \nthe UK ETS to ensure the UK ETS and Mandate operate effectively together. \nWe recognise the RTFO and Mandate regulations will need to account for the establishment \nof new support schemes, such as the revenue certainty mechanism.  \nAs these schemes are developed, we will consider if further changes to the eligibility criteria \nwould be necessary. \n \nTankering \nIn the consultation, we considered the risk of the mandate increasing ‘tankering’ – the \npractice whereby airlines opt to take on additional fuel for inbound trips to the UK to cover \nthe outbound trip and avoid paying the additional SAF costs from refuelling in the UK. In \nresponse to the first consultation, some stakeholders suggested the introduction of a \nrequirement for airlines to uplift a minimum amount of fuel when departing UK airports. This \nmechanism has also been proposed by the EU.  \nAlthough we were not able to quantify potential tankering scenarios, we welcomed views \nand supporting analysis on whether the extent of tankering as a result of the Mandate \njustifies the introduction of a minimum uplift requirement. \nQuestion 58 \nDoes the risk of tankering as a result of the SAF Mandate justify the introduction of \na minimum uplift requirement? Please provide supporting evidence if available. \nSummary of responses \nTotal  \nAgree  \nNeither agree nor disagree  \nDisagree  \nDon't know  \n40  \n17  \n10  \n13  \n0 \nFigure 60 Question 58 summary of responses. \n \nThose who agreed argued that this approach is consistent with the approach taken in the \nEU under the ReFuelEU initiative. Respondents flagged that if the UK is not consistent with \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n128 \nthe EU, there is a risk of trade distortions created by the unequal cost frameworks. Another \nkey reason for agreeing was the notion that tankering already occurs which increases GHG \nreductions4243 and will be exacerbated by the mandate.  \nOne respondent suggested both a minimum and a maximum uplift requirement would be \nmore beneficial for the climate, as it would limit the amount of additional fuel uplifted and \nconsequently reduce CO2 emissions. Some respondents referenced an International \nCouncil on Clean Transport (ICCT) report44 which showed that in 2025 tankering levels are \nprojected to be minimal. However, under more ambitious SAF targets post-2030 \napproximately 80% of the flights into the EU region could be affected by this leading to a \nprojected 22% decline in SAF sales.  \nThe respondents who disagreed believed the requirement would impact economic viability, \ncause unnecessary complexities and that other price incentives should take priority. They \nargued that the UK needs to offer similar incentives to the EU, such as the additional free \nallowance in the EU ETS, to ensure a level playing field. This could otherwise cause \nsignificant market distortion due to the high cost of SAF. Others recognised how carrying \nextra fuel may be for safety reasons or standard business practice, so this requirement \nwould add unnecessary complexity. Furthermore, one respondent argued that this \nrequirement would put the UK at a commercial disadvantage, affecting airline operations \nand commercial decisions. \nThose who neither agree nor disagree mainly believe this requirement should be kept under \nreview. Although industry is aware of the potential tankering risk, especially on short haul \nflights, these respondents indicated that the UK should monitor and be prepared to intervene \nquickly to introduce minimum lift requirements if necessary. Finally, one respondent thought \nthat alignment with international standards is crucial for an effective strategy, while another \nraised concern over how reduced demand for SAF in UK airports as a result of tankering \ncould deter industry growth.  \nGovernment response \nThe government wants to ensure that GHG emissions reductions are maximised under the \nMandate. We welcome the views from respondents on the extent of tankering and whether \ngovernment should take action to mitigate any negative impacts. Tankering is practiced \ntoday for several reasons, but evidence suggests that the primary incentive is fuel price \nreasons. Therefore, any differences in fuel price relative to other regions is likely to increase \ntankering.  \nStudies conducted on the impact of tankering suggest it could significantly reduce the impact \nof a mandate on GHG emissions reductions. As a result, the EU have included a minimum \nuplift requirement for airlines departing EU airports. These studies have either focused on \n \n42 EUROCONTROL Think Paper #1 - Fuel tankering in European skies: economic benefits and \nenvironmental impact | EUROCONTROL \n \n43 Climate change: British Airways reviews 'fuel-tankering' over climate concerns - BBC News \n44 https://theicct.org/wp-content/uploads/2021/06/tankering-eu-SAF-mandate-apr2021.pdf \n \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n129 \nthe EU (and not considered the impact of a UK Mandate) or have not provided sufficient \nevidence.  \nFurthermore, respondents suggested a range of alternative measures that address price \nincentives could instead be more effective in mitigating tankering behaviour, while some \nrespondents noted some unintended consequences of a minimum uplift requirement. Many \nrespondents also noted the uncertainty of the extent of tankering as a result of the mandate \nand its impact on emission reductions. This is particularly true while other policy that will \nimpact SAF price, such as the UK ETS, is subject to further development.  \nThe government does not therefore consider it appropriate to introduce a minimum uplift \nrequirement, or any other mitigation measure at this stage. In any case, the primary \nlegislation that we are using to implement the Mandate (the Energy Act 2004) would not \nprovide the powers to implement such a requirement in the Mandate. \nGovernment decision: we will not introduce any mitigation measures when the \nmandate starts in 2025.  \nWe will instead conduct further research into the extent of tankering once the Mandate is \noperational and examine how this impacts emission reductions. We will also carry out an \nassessment of mitigation options beyond a minimum uplift requirement on airlines to ensure \nthat we impose the most appropriate solution, if required. We plan to use information from \nthe mandate during the initial years to inform our further work in this area.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n130 \n7. Enforcement \nThis chapter sets out our approach to fair and transparent enforcement of the scheme. This \nwill only be necessary in specific circumstances where issues cannot be resolved. The \nRTFO Administrator has a long history of working with obligated parties and carrying out \ncompliance checks to ensure that any problems are addressed before further enforcement \nis required. We endeavour to continue this same working relationship with obligated jet fuel \nsuppliers.  \nWe did not ask any questions on enforcement in the first consultation; however, in the \nsecond consultation we proposed that, where parties fail to meet obligations, proportionate \nsanctions can be applied, which will also reassure the compliant majority that they will not \nbe disadvantaged by those that do not meet their obligations. We confirm here that this will \nbe done by revoking certificates as a first response, followed by issuing civil penalties if \nnecessary.  \nRevocation of certificates \nWe proposed that the Administrator should have the power to revoke certificates if \ninsufficient, inaccurate, or fraudulent information is present in information submitted by the \nsupplier. In the consultation we set out a similar process to the RTFO including the role of \nthe Administrator to notify the supplier and to consider any representations and the \nopportunity for suppliers to appeal to the Administrator. However, in contrast to the RTFO, \nwe proposed that where a supplier notifies the Administrator of a mistake and requests a \nrevocation, the Administrator has the power to revoke the certificate immediately. This is so \nthat a certificate can be immediately revoked in a situation where both parties agree on the \nneed for revocation to mitigate the risk of the certificate being traded with other account \nholders.  \nQuestion 59 \nDo you agree or disagree with the approach to revoking certificates? \nSummary of responses \nFigure 61 Question 59 summary of responses. \nAll respondents to this question agreed with the proposed approach to revoking certificates. \nWhere justification was provided, respondents approved of the consistency with the RTFO, \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n27 \n27 \n0 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n131 \nwhich has been implemented successfully and provides familiarity for suppliers. A couple of \nrespondents also commented on the clarity of the framework, stating that it provides a clear \ntimeline and set of actions.  \nRegarding the proposal that, in the case where a supplier notifies the Administrator the \nAdministrator has the power to revoke the certificate immediately, a couple of respondents \ncommented that this would not make much difference as the supplier would know not to \ntrade the certificates anyway. Though, this proposal was welcomed by other respondents. \nFinally, one respondent urged government to allow suppliers sufficient time and opportunity \nto provide additional information in cases where they are at risk of revocation due to \ninsufficient information.  \nGovernment response \nEnforcement is an important element of any regulatory scheme as it is the method through \nwhich a regulatory body can ensure compliance in a fair and transparent manner. One way \nin which the Administrator can ensure compliance is through the revocation of certifications.  \nGovernment decision: we confirm the approach to revocation of certificates as set \nout in the consultation.  \nThe approach to revocation of certificates aligns with that of the RTFO with the exception of \nwhere a supplier raises the need to revoke a certificate to the Administrator, the revocation \ncan be actioned immediately rather than wait 28 days.  \nIt will only be necessary to revoke certificates or take further action in specific circumstances \nwhere issues cannot be resolved. The Administrator will carry out regular compliance checks \nto identify issues and will notify suppliers promptly so that, where possible, there is an \nopportunity for issues to be addressed.  \nWhere parties fail to meet obligations, proportionate sanctions can be applied, which will \nalso reassure the compliant majority that they will not be disadvantaged by those that do not \nmeet their obligations. We plan to do this by revoking certificates as a first response, where \nthere is insufficient, inaccurate, or fraudulent information present in the application for the \ncertificate. This includes information in the carbon and sustainability data, the verifier’s \nassurance report and any declarations involved in the process. If further action is necessary, \nor a different offence is committed, civil penalties will be issued (see response to question \n60 and question 61 for further information on civil penalties).  \nAlthough the legislation will apply revocation to individual certificates, in practice, the \nAdministrator will revoke all the necessary certificates in one action. The Administrator will \nnotify the supplier of its intent and grounds for revocation of the certificates but will allow \nsuppliers sufficient opportunity to make representation against a revocation proposal or \ndecision. This approach is consistent with the RTFO, which has been effective in its \nimplementation. In practice, revocation of certificates for enforcement purposes is rarely \nused. Revocations are more commonly used at a supplier’s request - in which case the \nrevocation process can be expedited to allow the supplier in question to amend any errors \nand resubmit a claim for a certificate as soon as possible.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n132 \nFurther guidance on the process of revocation of certificates, including the actions taken by \nthe Administrator, rights held by the Administrator and supplier, and the timeframe, will be \nset out in guidance, alongside clear examples.  \nCivil penalties \nWe set out our intention to give the Administrator powers to issue civil penalties for certain \ninfringements to ensure compliance with the mandate. This includes where a supplier fails \nto apply for an account, has not wholly discharged the obligation and not paid the buy-out \namount, and has not provided accurate information or sought to rectify inaccuracies that \nhave been identified. The infringements set out follow those in RTFO legislation.  \nWe proposed to issue two different types of penalty: \n• where an account holder has gained, or attempted to gain, one or more certificates, \nthe penalty will be proportionate to the buy-out price of that certificate; and \n• where an account holder has made any other infringement, a fixed penalty will be \nissued.  \nWe sought comments on which of the following penalties would be appropriate where \nrelating to gaining certificates45: \n• 1.5 x buy-out price = £3,850 per tonne of standard SAF; £5,287 per tonne of PtL; \n• 2 x buy-out price (preferred option) = £5,134 per tonne of standard SAF; £7,050 per \ntonne of PtL; and \n• 3 x buy-out price = £7,701 per tonne of standard SAF; £10,575 per tonne of PtL. \n \nAnd relating to other infringements: \n• £50,000 - in line with the RTFO \n• £65,000 – approximately 25% higher to reflect the difference between the proposed \nSAF Mandate buy-out price and RTFO development fuel buy-out price \n• £100,000 – double the value of the RTFO penalty \nIn addition to this, we proposed a daily 5% increase to the penalty for every day that it is not \npaid in full, starting on the day following the issue of the penalty. Further, it was proposed \nthat any objections to civil penalties will follow the current process in the RTFO.  \nQuestion 60 \nDo you agree or disagree with the reasons for receiving penalties and the approach \nto issuing penalties? \n \n45 These values are based on the preferred buy-out prices in the consultation. We have confirmed higher \nbuy-out prices for both the main and PtL obligations than originally consulted on. See responses to \nQuestions 12 and 13 for further information.  \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n133 \nSummary of responses \nFigure 62 Question 60 summary of responses. \nMost of the respondents agreed with the approach to issuing penalties set out in the \nconsultation and recognised the need to include penalties. Only a few respondents provided \nfurther comment in support of the proposal, which largely referred to approval of the \nconsistency with the RTFO. However, a few respondents underlined that penalties issued \nto obligated suppliers must not be passed on to airlines and consumers. Finally, one \nrespondent noted that it is extremely unlikely obligated suppliers would incur penalties due \nto non-compliance, as can be seen by the limited number of cases throughout the RTFO.  \nGovernment response \nWe have responded to question 60 and question 61 together – see response following \nquestion 61.  \nQuestion 61 \nWhich penalty values do you consider to be high enough to be a deterrent but \nproportionate to the infringement? \nSummary of responses \nRespondents typically preferred a £65,000 penalty although a small number of respondents \neach suggested £50,000 or £100,000. Where a penalty relates to the gaining of a certificate, \nfour respondents stated it should be twice the price of the buy-out, with respondents arguing \nfor consistency with the RTFO or that a penalty any less than this would bring the cost of \nnon-compliance too close to the buy-out price.  \nMany respondents did not provide comment on a specific figure but instead outlined the \nconsiderations that need to be taken when setting an appropriate penalty. Some \nrespondents underlined that penalties must be high enough to act as a deterrent and keep \nup in line with inflation, with a few respondents stating that the penalty values should be \nconsiderably higher than those included in the consultation. Other respondents argued for \nconsistency with the RTFO or other similar international schemes. Although, one respondent \nquestioned whether the RTFO penalty value would still be appropriate given it has not been \naltered since 2008. Finally, it was noted that suppliers should not be able to pass the cost \nof the penalty on to airlines and end users.  \nGovernment response \nAs noted in response to question 59 we will give the power to the Administrator to issue civil \npenalties. We welcome the responses from stakeholders on the reasons for issuing civil \npenalties, the process for issue civil penalties and the level at which these should be set. \nTotal \nAgree \nNeither agree nor disagree \nDisagree \nDon't know \n25 \n22 \n3 \n0 \n0 \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n134 \nmeaning that, should an obligated supplier or an account holder applying for certificates fail \nto meet certain criteria, DfT can impose civil penalties as an act of enforcement. As with the \nRTFO, such penalties will only be issued for specific infringements and imposed after the \nAdministrator has given sufficient notification to the party in question and provided \nopportunity to rectify the issue.  \nGovernment decision: we confirm the reasons for receiving penalties and the \napproach to issuing penalties in line with current practice under the RTFO and as set \nout in the consultation.  \nThe reasons for issuing a penalty include where a supplier fails to apply for an account, has \nnot wholly discharged the obligation and not paid the buy-out amount and has not provided \naccurate information or sought to rectify inaccuracies that have been identified. We will set \nout all infringements in legislation to provide clarity and certainty to account holders without \nthe risk of changes being made without thorough consultation. These are the same as the \nRTFO and we have not seen sufficient evidence to amend any of these infringements for \nwhich an account holder maybe liable for a penalty. As noted by one respondent, it is highly \nunlikely that any penalty will be issued as the Administrator will endeavour to address any \nmistakes before reaching this stage. There have only been a few instances of penalties \nissued under the RTFO since it started in 2008.  \nWe will issue two types of penalties, depending on the infringement: \n• where an account holder has gained, or attempted to gain, one or more certificates \nby contravening one points set out, the penalty will be twice the buy-out price for each \ncertificate gained or attempted to gain. In response to questions 12 and 13, we \nconfirmed the buy-out price will be £5,875 for standard certificates and £6,250 for the \nPtL buy-out, meaning the penalty will be £11,750 and £12,500 for each of these \ncertificates respectively; and  \n• where an account holder has made any other infringement, a fixed penalty will be \nissued. The fixed penalty will be set at £100,000.  \nWe recognise these penalties are higher than that of the RTFO. However, we believe that \nthey are proportionate to the offence, comparable to other similar schemes and account for \nthe relative cost of SAF, higher proposed buy-out price and impact of inflation. As such, they \nstrike the right balance between acting as a deterrent without being too severe. As with the \nRTFO, we confirm that: \n• a supplier has the opportunity to object to a civil penalty within 28 days of the penalty \nbeing issued which will then be considered by the Administrator; \n• an appeal can be made if the recipient considers that they are not liable to pay the \npenalty and/or that the amount of the penalty is too high; and \n• to encourage account holders to pay the penalty in a timely manner, for any penalty \nthat is not paid to the Administrator, we will apply a daily 5% increase to the penalty \nfor every day that it is not paid in full, starting on the day following the issue of the \npenalty. \nAgain, each of the above will be written into legislation to provide certainty to account holders \nthat may be liable for penalties. Any changes to these rules or processes will be subject to \nthorough consultation to provide stakeholders an opportunity to provide feedback. In \naddition to the legislation, comprehensive guidance will be provided for relevant parties prior \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n135 \nto the mandate starting to ensure they are made aware of the processes, the actions that \ncan be taken by the administrator and the account holder’s rights. \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n136 \n  \nAIA \nAviation Impact Accelerator \nASTM \nAmerican Society of Testing and Materials \navgas \nAviation gasoline \navtur \nAviation turbine fuel \nBAU \nBusiness as usual \nC&S \nCarbon and Sustainability \nCBA \nCost benefit analysis \nCCC \nClimate Change Committee  \nCCUS \nCarbon capture, usage and storage \nCI \nCarbon intensity \nCORSIA \nCarbon Offsetting and Reduction Scheme for International Aviation  \nDAC \nDirect air capture \nDefra \nDepartment for Environment, Food and Rural Affairs \nDEF STAN \nDefence Standard \nDESNZ \nDepartment for Energy Security and Net Zero \nDfT \nDepartment for Transport  \nEU RED \nEU Renewable Energy Directive \nGA \nGeneral Aviation  \nGGR \nGreenhouse gas removal \nGHG \nGreenhouse gas \nGREET \nGreenhouse Gases, Regulated Emissions, and Energy Use in \nTransportation \nHEFA \nHydroprocessed esters and fatty acids \nHMRC \nHM Revenue & Customs \nHODA \nThe Hydrocarbon Oil Duties Act 1979 \nHVO \nHydrotreated vegetable oil \nICAO \nInternational Civil Aviation Organization \nICCT \nInternational Council on Clean Transport \nILUC \nIndirect Land Use Change \nIRA \nInflation Reduction Act \nISCC \nInternational Sustainability and Carbon Certification \nLCF \nLow Carbon Fuel \nLCHS \nLow carbon hydrogen standard \nLHV \nLow Heating Value \nGlossary \n\n\n Supporting the transition to Jet Zero: Creating the UK SAF Mandate \n137 \nMOD \nMinistry of Defence \nMSW \nMunicipal Solid Waste \nNDF \nNuclear derived fuel \nOEMs \nOriginal Equipment Manufacturers \nPtL \nPower-to-liquid \nRCF \nRecycled carbon fuel \nRED \nRenewable Energy Directive \nRFNBO \nRenewable fuel of non-biological origin \nRSB \nRoundtable on Sustainable Biomaterials \nRTFO \nRenewable Transport Fuel Obligation \nSAF \nSustainable aviation fuel \nUCO \nUsed cooking oil \nUK ETS \nUK Emissions Trading Scheme \nUKRI \nUK Research and Innovation \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n\n\n1/2\nChristopher Surgenor\n24 April 2024\nLeisure airline Jet2 to use SAF at Stansted and Bristol as\nit prepares for UK mandate\ngreenairnews.com/\nUK leisure airline Jet2.com has purchased around 650 tonnes of SAF from Shell\nAviation, which will be used to add a 1% SAF blend onto a number of departing flights\nfrom London Stansted this year, with a further 350 tonnes purchased from Q8 Aviation\nfor use at Bristol Airport. The airline, the UK’s third biggest, has made an equity\ninvestment in the Fulcrum NorthPoint SAF production facility due to be constructed in\nnorth-west England. However, said the company, without a fully-fledged domestic SAF\nindustry, the UK remained reliant on fuel imported at a high cost or airlines would\notherwise in future under the mandate be required to pay a buy-out price, “putting UK\nairlines and holidaymakers at a competitive disadvantage.”\nAshleigh McDougall, Shell Aviation’s General Manager for Europe and Africa, said scaling\nthe supply and use of SAF required a concerted effort from across the aviation sector. “The\nannouncement with Jet2.com is a great example of the collaborative actions that are\nrequired to drive forward the use of SAF and help decarbonise flight,” she said.\nCommented Steve Heapy, CEO of Jet2.com and Jet2holidays: “We see SAF as critical in\nhelping the industry decarbonise and we can use this supply to ensure our operations are\nready for SAF uptake both now and in the future, when we anticipate its use will grow\nmaterially. We very much see 1% as the starting point and we want to grow this over the\ncoming years.”\nHe called for greater support to incentivise the uptake of SAF in the UK and reduce its cost.\n“The UK government must implement a price revenue mechanism earlier than the current\ntimeline of 2026, which means we can secure investor confidence, build the UK SAF plants\nthat we need, and turbocharge the UK SAF industry,” he said.\nUnder the airline’s investment in Fulcrum NorthPoint, it expects to receive over 200 million\nlitres of SAF over a 15-year period from the proposed NorthPoint waste-to-fuels facility when\nit becomes operational, which will achieve net emissions reductions totalling around 400,000\ntonnes of CO2.\nIn line with government policy, Jet2 has a target of net zero emissions by 2050 but aspires to\nbring this date forward. As part of its sustainability strategy, it has 110 Airbus A320/A321 neo\naircraft on firm order, which could extend up to 146 aircraft. Its holiday arm has recently\n\n\n2/2\nlaunched a hotel sustainability labelling scheme so that customers and travel agents can\neasily find and choose from a collection of certified sustainable hotels that meet Global\nSustainable Tourism Council recognised standards.\nPhoto: Jet2 plc\nChristopher Surgenor\nEditor\nLinkedin\n\n\n1/3\nChristopher Surgenor\n25 April 2024\nUK SAF Clearing House opens its doors to new aviation\nfuel producers\ngreenairnews.com/\nThe UK government-funded SAF Clearing House, led by the Energy Institute at the\nUniversity of Sheffield and supported by Ricardo UK, has been officially launched. It\nwill provide advice and support to fuel producers on the development, testing,\nqualification and production of new fuels entering the aviation market. All new\naviation fuels must meet strict performance standards before they can be qualified as\nsafe to use in aircraft and must undergo stages of testing in accordance with industry\nrecognised standards. The cost and complexity of testing can be a significant barrier\nto new fuels entering the market and to help overcome this, the UK SAF Clearing\nHouse will provide advice to producers on testing, guidance on testing facilities and\nsupport qualification. It is now accepting applications from producers for technical\nsupport and funding.\n“It is great to see there is now a lot of activity in the development of SAF,” said Professor\nChris Lewis from the University of Sheffield and the new Director of the UK SAF Clearing\nHouse. “However, the increase in a diverse range of raw materials and processes means a\nmajor shift in the industry, which is both an opportunity to reduce aviation emissions but also\na challenge to get these increasingly diverse SAF products to market.\n“The UK SAF Clearing House, in cooperation with the EU and US Clearing Houses, will\nprovide technical advice and information, funding to support with testing, and help in\nunderstanding how the industry works, as well as helping producers engage with the industry\nin a positive way. We are delighted to announce we are open for business, so please do\ncome and talk to us.”\nThe clearing house is receiving £700,000 ($870,000) in government funding, with another\n£5.35 million earmarked to support costs associated with fuel testing.\n“The UK SAF Clearing House will accelerate the testing of fuels by streamlining the process,\nin order to help companies get the qualification for use they need,” said Natasha Robinson,\nDeputy Director of Low Carbon Fuels at the UK’s Department for Transport.\n“It will reduce the bottleneck in testing, ensuring a greater availability of SAF from a diverse\nrange of feedstocks, which will enable the UK to achieve its target of 10% SAF by 2030 and\nwill also help with the creation of new jobs and skills in this innovative green sector.”\n\n\n2/3\nAdded Anthony Browne, Minister for Aviation and Decarbonisation of Transport: “As the UK\nSAF industry goes from strength to strength, it’s important it also has the capabilities to test\nthe fuel being made, making the transition from the labs to the sky faster and easier than\never before.”\nSujith Kollamthodi, Director of Policy, Strategy & Economics at engineering and\nenvironmental consultancy Ricardo, which is supporting the clearing house, said it would be\na free-at-the-point-of-use service to support fuel producers, working in collaboration with\nother international clearing houses and also coordinate a programme of fuel qualification with\nthe support of aerospace original equipment manufacturers.\nThe University of Sheffield’s Energy Institute hosts the Sustainable Aviation Fuels Innovation\nCentre (SAF-IC), which provides state-of-the-art facilities to test, certify and deploy new\nsustainable aviation fuels. It is a development hub for the research and scaling up of SAF,\noffering laboratory and testing space as well as coordination and networking facilities.\nPhoto: University of Sheffield Energy Institute","difficulty":"hard","domain":"Multi-Document QA","length":"medium","question":"How does the UK government ensure the supply and use of SAF to achieve the expected goal of reducing carbon dioxide emissions?","sub_domain":"Multi-news"}

Source: https://huggingface.co/datasets/zai-org/LongBench-v2

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