UK SAF Mandate Consultation – Betting it all on ‘SAF’

14 Sep, 2021

Safe Landing responded to the UK Government’s ‘SAF Mandate’ consultation, which lays out various options for scaling up ‘Sustainable Aviation Fuel (SAF) in the UK.

Pilots and safety critical aviation workers are trained to always have a plan B. If we find ourselves with an uncertain outcome and we don’t have a credible back-up plan, we have failed to manage the risk – we’ve failed to do our job. All ‘SAF’ or ‘alternative jet fuel’ pathways carry substantial risk of exacerbating environmental and social crises – they require intensive use of limited global resources, during a period in human history when we are battling to decarbonise our societies. If the UK and global aviation sector proceeds down a path that is reliant on the development of fuels which carry huge uncertainty and risk, and this strategy fails, then we have no back-up. The jet fuel has been burned, the temperature has risen, there may be no going back. Aviation as we know it may have to halt completely for some time – there will be no Safe Landing.

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).

We also reject any proposed ‘SAF’ mandate that fails to place a cap on total fuel consumption first. This cap should be set by assuming all fuel burned is fossil fuel kerosene (given the uncertainties of technological readiness, and environmental & social impacts of alternative fuels produced at scale) and by assuming an emissions reduction trajectory compliant with limiting global warming to 1.5°C. 

We advocate for a ban or strong restriction on the use of the ‘HEFA’ process for converting waste oils/fats into jet fuel, or at least for government policy to favour other fuel pathways. Such feedstocks are severely limited and can be more efficiently utilised by other sectors.

The aviation industry is about to undergo a huge transformation across aerospace manufacturing, airline operations and airport configurations – we believe that government support should primarily be targeted here – rather than squandered on further financing the fuels industry.

Read our full response here.

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