Stay Grounded is a network of 200 associations around the world advocating for a reduction of air transport. One argument recently heard is that the aviation community over-promises and under-delivers on the subject of its de-fossilization strategy. The example given stated that 10% SAF incorporation in 2020 was promised as early as 2010 and did not materialize at all. They hint the same will be true for the ambitious strategy toward 2050, as laid out by international bodies, like ICAO or IATA, or in regional regulations, like in the EU. Could there be some truth in such an argument? Should we worry about this possibility?
The EU ReFuel EU Aviation regulation to mandate SAF incorporation looks solid, promoting a fast-escalating mandate between 2025 and 2050, in line with the urgency to reach net zero emissions in 2050. The HEFA pathway, transforming sustainable lipids like waste, residual used cooking oil and animal fats into low-carbon aviation fuel, seems quite capable to meet the 2030 objective of 6% SAF incorporation.
Most oil majors have been investing in Europe to transform former crude oil refineries into biorefineries equipped with this technology. But a supply crunch of sustainable lipids is looming for the next decade, a strong limit to further expansion of HEFA production post-2030. And few investments are emerging to build SAF production capacity using other pathways, when incorporation mandate is at 15% in 2035, only five years later. Is there fear of regulation instability, raw materials scarcity or hesitations to invest hundreds of millions in technologies not having reached maturity? When it takes 5 to 6 years between investment decision and first oil-out, there is reason to worry that the 2035 objective may not be achievable.
And isn’t there as well some “biofuel fatigue” at play, once early enthusiasm starts to wane? Like what happened to ethanol in light duty road transport in the U.S. in the last ten years.
The 2008 Renewable Fuel Standard (RFS2) really kick-started the ethanol incorporation in gasoline. As early as 2012, the incorporation rate had sky-rocketed to 9.9%, showing a nationwide adoption of E10, gasoline with 10% ethanol content. In parallel, even if flex-fuel vehicles that can run on E85, remain a modest part of the car pool, 5% max, the natural renewal of the car pool made it possible to go beyond E10. E15 has automaker approval for new cars, allowing 30% of the fleet on the roads to be E15-compatible by 2018, 55% by 2022, likely two-third by 2024 and 90% by 2030.
But ethanol incorporation only slightly creeped upward, 10% by 2018, 10.2% by 2023, with 10.35% expected in 2025 for some experts. the math does not work here. The explanation lies in the regulation. RFS2 has a stable, long-term objective of 15 billion gallons per year of corn-based ethanol, the domestic, profitable production, which is roughly in line with 10% of the gasoline demand. As cellulosic ethanol has not emerged as a viable alternative or complement to corn-based ethanol, and sugar cane-based ethanol goes to California, there is little regulatory incentive to make E15 the new national standard when E10 allows to properly meet the regulation standard. Last, but not least, electromobility is the new objective for road transport, at least for the present U.S. administration. So, few experts bet on E15 making it big time.
Could hydrogen and e-SAF play the same role in low-carbon aviation fuel EU post-2030 future as electromobility in US road transport? Making the 6% HEFA-based SAF reached in 2030, an acceptable, but low-level, compromise, showing the aviation community some engagement for low-carbon air transport, but betting on miracle solutions that may not emerge as early as hoped for: recipe for future claims by Stay Grounded of over-promises, under-deliveries.
It is not too late to get serious about SAF production in Europe with close to maturity alcohol-to-jet or gasification-synthesis technologies, for instance, but the clock is ticking to meet the ambitious target for 2035 and later. And the answer is likely in a team effort, by all stakeholders, public and private, to take some risks. Possibly by being less severe on feedstock eligibility, when the pathway does show serious sustainability, as measured by lifecycle analysis.
Philippe Marchand is a Bioenergy Steering Committee Member of the European Technology and Innovation Platform (ETIP).