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22 June 2023

Pathway to net zero aviation: Developing the UK sustainable aviation fuel mandate

Sustainability & EnvironmentPolicy & GovernmentTechnology & InnovationConsultation responseAviation

The Chartered Institute of Logistics and Transport (CILT) is a professional institution embracing all transport modes whose members are engaged in the provision of transport services for both passengers and freight, the management of logistics and the supply chain, transport planning, government and administration. Our principal concern is that transport policies and procedures should be effective and efficient, based on objective analysis of the issues and practical experience, and that good practice should be widely disseminated and adopted. The Institute has a number of specialist forums, a nationwide structure of locally based groups and a Public Policies Committee which considers the broad canvass of transport policy. This submission draws on contributions principally by the Aviation Policy Group.

Our response to this consultation begins from the basic principle that the aviation sector is committed to achieving net zero by 2050 and that it will do everything it can to meet this target. As such, it is prepared to meet any target or mandate that is aligned with 2050 net zero, no matter the cost. Thus the sector is prepared to accept increased costs and will pass these on to passengers and shippers, accepting the reduction in demand that will inevitably result. It is also important to note that this consultation does not refer to the costs of SAF, or any particular type of SAF. Although the costs of net zero will undoubtedly be higher than not meeting the target, other measures will impact on the costs of SAF, in particular the costs of offsetting. If offsetting is less costly than SAF, it may reduce the size of the SAF market, in turn affecting the mandate.

 A particular concern about any of the measures mandated to assist in achieving 2050 net zero is unintended consequences. The consultation notes this in relation to tankering but, given the international nature of aviation, it is possible, indeed probable, that other nations which do not have the same mandates will be able to obtain a competitive advantage. The UK Government must therefore do all in its power to negotiate the alignment of international regulations with those proposed for the UK.

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