Executive Summary: Fueling nature: how e-fuels can mitigate biodiversity risk in EU aviation and maritime policy
Nuala Doyle
Policy Officer
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The SASHA Coalition
Decarbonising aviation must not put nature in crisis
It's no secret that the solutions available to decarbonise aviation are not all unique to the sector – across transport modes, from road transport to maritime shipping, we see commonalities in the solutions emerging. While for road transport, electric vehicles are at a mature stage of development, for aviation, zero emission flight is a little way off commercial roll-out. And when drawing parallels between aviation and maritime shipping, green hydrogen will be required in both sectors to a greater or lesser extent, for all pathways to decarbonisation (excluding direct electrification).
A pathway that has had a long-established role in decarbonising road transport is biofuels. This solution is gathering momentum as a key part of aviation's decarbonisation thanks to sustainable aviation fuel (SAF) mandates from places such as the UK and EU. But what if this part of the solution for decarbonising aviation risked putting nature at risk? As we are in the midst of a twin biodiversity and climate crises, this is a consideration that should not be ignored.
Learning from other industries
By using biofuels in road transport, we can already see clear risks associated with their use. In the UK, biofuels have been required in the majority of road transport fuel distributed since the introduction of the Renewable Transport Fuel Obligation (RTFO) in 2008. But over the years, reports have highlighted significant risks of land degradation, increased emissions from land-use change (due to deforestation) and increases in food prices (due to the growth of first-generation biofuel crops over food crops) from producing biofuels.
The aviation industry is in part learning from some of these risks. By not allowing the use of first-generation biofuels – those produced from food and animal crops – and instead focusing on wastes, used oils and residues, the UK SAF Mandate and ReFuelEU Aviation minimises the risks associated with land use change such as deforestation and lower food production. However, a study by Transport & Environment suggests that even with robust sustainability considerations in place, there is an emerging risk that with increased demand for limited supplies of used cooking oil, we may see higher levels of fraud in the supply chain. In this case, fraud takes the form of virgin oils (such as palm oil) being mis-labelled as 'used'.
E-fuels best for biodiversity
Even with safeguards in place against fraudulent claims of oils being used, and use of crop-based fuels, biofuels still place a significant strain on biodiversity. Recent research from the SASHA Coalition has found that any sustainable fuel pathway for the aviation and maritime sectors that prioritise biofuels will be incompatible with EU biodiversity targets for 2050. Prioritising e-fuels, on the other hand, would reduce pressure on natural habitats and land demand and better support the EU’s Biodiversity Strategy.
So what can we do to minimise the risk that biofuels present to nature? In short, minimise the use of biofuels. Aviation must learn from the issues that the road transport sector has identified in the use of biofuels, and go further than just placing sustainability considerations on feedstocks to incentivise the use of e-fuels, which do not come with the same biodiversity risks, over biofuels. This could be done through mechanisms such as e-fuel sub-mandates being strengthened, revenue support mechanisms targeting e-fuels over biofuels, and offering greater incentives to e-fuels over biofuels through mechanisms such as emission trading systems (ETSs).
With the risks well known, we need to make sure we don't lock in a decarbonisation pathway for aviation that is incompatible with nature.