Second UK SAF Mandate Consultation – Safe Landing Response

23 Jun, 2023

This week, Safe Landing responded to the second UK Sustainable Aviation Fuels (SAF) Mandate Consultation which closed on 22nd June 2023.

Our full response can be read here.

Back in 2021, we responded to the first UK “SAF” Mandate Consultation and stated that:

We believe that the quantity of ‘SAF’ produced in any given year should be strictly limited on a basis that ensures positive environmental and social impacts. We suggest that this quantity should be determined not by any given industry, but by governments at a national and international level, through careful economy- and society-wide assessment, and prioritisation of available resources. 

We reject any proposed ‘SAF’ mandate that fails to provide a cross-economy impact assessment of environmental and social risk. It is very clear to us that any ‘SAF’ mandate is of secondary importance to any policies required to constrain total fuel consumption by the aviation industry (and indeed other transport industries).

Two years on, and there has still been no cross-economy assessment of available feedstocks and prioritisation of those resources completed.

However, the UK Government’s response to the first SAF mandate consultation did explicitly commit to ensuring that feedstocks are used for the best environmental use possible. It said:

Government decision: a waste assessment will be conducted at feedstock level to determine whether or not a feedstock is eligible for support under the SAF mandate; this assessment will be informed by the waste hierarchy and alternative end uses.

Confidence that SAF production does not lead to unintended negative consequences is a critical component in securing support for its production and use. The waste hierarchy will ensure that the mandate only supports true wastes i.e. those which cannot be prevented, reused or recycled, and those wastes for which the use of biofuel represents the ‘best environmental outcome arising from that waste’.

We absolutely agree. So, where is this assessment and waste hierarchy?

The UK Government has delayed and is yet to publish it’s upcoming “Biomass Strategy”, so why does the UK “SAF” Mandate Consultation close before we’ve seen this strategy?

Regardless, despite the apparent complexity surrounding “SAF” and often perplexing ‘lifecycle assessments” we think that the UK, and other governments around the world, have some pretty straightforward decisions to make on aviation fuels.

Forget trying to scale any biofuels or electro-fuels for at least the next decade and introduce policies which target fossil kerosene reduction and more effectively price kerosene emissions. The money raised here can be used for a variety of things, not least loss & damage funds for those impacted directly by emissions today, but also cross-economy decarbonisation efforts. Scaling Green Hydrogen (H2) production and Direct Air Capture (DAC) facilities can be part of this, and their development will benefit aviation – but their outputs are more efficiently used elsewhere for the time being. Simple.

We advocate for the UK Government aviation fuel policy to involve:

  • A focus on capping and reducing total jet fuel consumption as a priority, in order to drive down fossil jet fuel use. Any proposed “SAF” mandate is of secondary importance to this.
  • Applying an emissions price to all aviation emissions in order to raise revenue for loss & damage funds and cross-economy decarbonisation.
  • Performing a cross-economy assessment and prioritisation of available non-fossil fuel feedstocks, i.e. biomass and renewable energy, before assuming any for aviation.
  • Prioritising non-fossil fuel feedstocks for applications which produce the greatest emissions savings, social utility, and distributed benefits across the population.

We conclude that the UK Government should therefore:

  • Introduce a carbon budget for UK aviation consistent with 1.5°C and allocate that budget.
  • Perform a cross-economy assessment of available non-fossil fuel feedstocks and allocate these.
  • Remove financial support for all aviation biofuels and remove biofuel ‘SAF’ mandate targets.
  • Prioritise biomass for other uses: mostly fertiliser production, heating, and Bioenergy Carbon Capture and Storage (BECCS) plants. Prioritise waste oil/fat for ‘HVO’ biodiesel production, with relatively small quantities of ‘HEFA’ biofuel co-produced during this process.
  • Remove financial support for electro-fuel (e-fuel) and e-fuel mandate targets in the near-term.
  • Prioritise renewable electricity for other uses: mostly grid, building and ground transport decarbonisation.
  • Focus financial support on grid decarbonisation, Green Hydrogen (H2) production and Direct Air Capture (DAC). Prioritise Green H2 produced for displacing Grey H2, and within aviation for hydrotreating kerosene. Prioritise DAC for carbon capture and storage (DACCS).
  • Minimise fuel supply chains in order to reduce transport emissions of the feedstock and fuel. This will mean primarily utilising domestic feedstock supplies.


Within aviation we would prefer to see any government funding directed towards Research & Development (R&D) related to more efficient, radical aircraft technology designs. These will be required given the higher fuel costs associated with any future scenario, regardless of fuel eventually used. The aviation industry is about to undergo a huge transformation across aerospace manufacturing, airline operations and airport configurations. This will not only help future-proof the sector, but also provide actual aviation jobs for actual aviation workers. Government support should primarily be targeted here, rather than squandered on further financing the fuels industry, particularly for fuel pathways with questionable sustainability.

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