On 25 March the UK Department for Transport published its
log-awaited consultation on its proposals for how it intends to align UK
support for biofuels alongside that of its Europe partners to implement the
revised Renewable Energy Directive (RED), but also how it intends to extend the
remit of the UK’s Renewable Transport Fusel Obligation.
The consultation exhibits a balance in seeking as far as
possible to maintain uniformity with its European partners to facilitate trade
in biofuels while also ensuring that new and emerging sectors are effectively
catered for as the UK seeks to drive further transport decarbonisation.
Recognising that electrification will gradually reduce the
overall size of the fuel pool and introduction of E10 later in the year could
result in delivery of ethanol at the expense of waste-derived biodiesel, (which
delivers high greenhouse gas savings (GHG)), DfT is proposing to increase the
biofuel obligation on fossil fuel suppliers over time, rising to 12.1% of UK
transport fuel use (by volume) by 2032 and beyond, which represents a 2.5%
increase in the 2032 target. By this move it hopes to maintain progress on driving
the difficult process of reducing GHG emissions from transport.
In a European lead, the UK is also proposing to support
Recycled Carbon Fuels (RCFs) where these are derived from the fossil portion of
refuse derived wastes or industrial off-gas that would otherwise have been
combusted for power generation and also deliver development fuels that can assist
‘hard to decarbonise’ sectors such as aviation. This is welcome news for interests in waste gasification technologies. Supported
technologies will have to demonstrate that the GHG savings delivered are better
than energy from waste applications. The
target GHG saving required will also increase over time from 50% up to 65% by
2030 for all producers. Reward levels
will be set lower than for renewable development fuels, at the equivalent of
0.5 development RTFC’s per litre.
DfT is also consulting on the potential to allow Power
Purchase Agreements to be used to evidence ‘additional’ renewable power trading
across the grid to support production of renewable fuels of non-biological
origin (RFNBOs). DfT is also looking to extend support for use of RFNBO’s in
maritime applications and use of hydrogen in fuel cells for off-road use
(previously an excluded use).
DfT is also looking to seal off some reward routes including
hydrogen production from biomethane without carbon capture and sequestration
(CCS), which would otherwise be eligible for dRTFC’s. DfT deem that without CCS this should not be
considered as an advanced conversion process and therefore ineligible for elevated
levels of support.
Many of the other proposals represent opportunities to tidy
up the RTFO legislation, bring it into
line with the revised RED and improve definitions of sustainable feedstock and
land use. A new move is the proposal to
introduce a valuable GHG credit for biomethane generation from slurries and
manures (to reward better manure management) which will help to drive down the
GHG impacts of derivative fuels. However, in contrast to the RED, DfT will not
permit the averaging of GHG’s for fuels from feedstocks with different GHG
characteristics. So it will not be
possible to use such credits to improve the value of low GHG biomethane.
Overall, there are few real surprises as many of the
proposals had previously been discussed with industry, but the extension to
applicable fuel types and uses and the intention to introduce recycled carbon
fuels will be welcomed along with the additional certainty provided to UK
renewable fuel producers and developers.