RTFO consultation stakeholder workshop - Gov.uk

RTFO consultation stakeholder workshop 4 January 2017 Agenda Chair opening

RTFO proposals – overview and context RTFO cost benefit analysis NGOs UKPIA Renewable Energy Association Panel discussion Lunch Afternoon session on GHG 1

Moving Britain Ahead January 17

RTFO proposals overview and context

Moving Britain Ahead

4 January 17 An RTFO Christmas Carol

2

Consultations

• Launched 29 November • Ministerial Roundtables 15 December • Discussions today • Closes on 22 January

3


What are we trying to achieve?

4


Increase public confidence – genuine and cost effective carbon savings Baseline

5

Option 1

Option 2

Stakeholder workshop 4 Jan 2017 RTFO CBA

Option 3

Opt 1 Sens


Encourage UK investment

6


Set a long term direction for industry Focus increasingly on sectors difficult to electrify

7


Encourage strategically important fuels

8


Focus policy on meeting domestic carbon budgets

9


Feedback from the roundtables  Waste availability

 Investment opportunity

 Appropriate crop cap level

 Value of interim targets under GHG regs

 Appropriate development fuels

 E10 10


Brexit implications

While we negotiate our exit from the European Union the UK remains a full member of the EU and all the rights and obligations of EU membership remain in force. During this period the Government will continue to negotiate, implement and apply EU legislation.

11


What does Brexit mean longer term?

12


New Renewables Directive

 EU target of 27% renewables by 2030  Governance Framework Regulation (part of the wider legislative package)  Measures to mainstream renewables in heating and cooling and transport

13


Transport proposals  2020 target of 10% renewables in transport discontinued  Fuel supplier obligation of 6.8% in 2030 (from 1.5% in 2021)  Advanced biofuels sub-target of 3.6% in 2030 (from 0.5% in 2021)  Cap on UCO, tallow and molasses at 1.7%

 Aviation and maritime fuels to count 1.2 times their energy content  Crop cap of 3.8% in 2030 (from 7% in 2021)  Member States free to set cap at lower level and differentiate between different fuels (on the basis of ILUC)

 Sustainability criteria streamlined extended to gaseous and solid “biomass fuels” used in the electricity, heating and cooling and transport sector  For biomass fuels, Member States may set stricter criteria  Strengthened cooperation between Commission, MS and voluntary schemes

 Number of technical changes and updates to definitions and accounting (e.g. no double counting)

14


EU Timing  Council: Second half of 2017? (Estonian Presidency)  European Parliament: timetable tbc  We will engage with stakeholders on the UK approach this year

15


Next steps

Publish summary of responses by 15 April Publish Government response Consult on guidance Parliamentary debates

Introduce statutory instruments

16


Today

 Clarify areas of uncertainty  Highlight key issues  Hear others’ views

17


Consultation RTFO Amendments Cost Benefit Analysis Stakeholder Workshop 4 January 2017


January 17 Stakeholder workshop 4 Jan 2017 RTFO CBA

18

The consultation proposes to - increase the RTFO obligation

- incentivise development fuels - limit the use of crop derived fuels

- set policy to 2030 - make other amendments not quantified in the CBA

19



Three policy options …  Policy option 1

 Policy option 2

 Policy option 3

 High crop use allowed

 Current levels of crop, 2% volume

 Zero crop use

 Broad definition of development fuels

 Targeted definition of development fuels

 Targeted definition of development fuels

… many possible outcomes for fuel supply 20



The evidence base for the CBA was compiled jointly with stakeholders - Transport Energy Taskforce 2014/15

- Stakeholder Evidence Workshop December 2015 - ongoing work with LowCVP and the E10 working group through 2016

21



Using this evidence base, the CBA makes assumptions and presents illustrative scenarios Common assumptions for all three scenarios, following stakeholder consultation:

• Moderate uptake of E10 - 59.5% of E5 and 40.5% of E10 across entire petrol supply, overall ethanol content of 6.825% by volume. Mid-point between no E10 and high E10, reflecting uncertainty around actual E10 uptake. Crop ethanol in Options 1 and 2, cellulosic in Option 3

• Waste feedstock availability - up to 2.2bn litres of waste biodiesel possible, but more expensive at high levels of demand

• Development sub-target is met 22



Estimate of fuels supplied under the illustrative scenarios – basis of costs and benefits Baseline

23

Option 1

Option 2


Option 3

Opt 1 Sens


Fuels supplied, costs and benefits of options 1 and 2 appear similar - but the risks are very different

 Policy option 1

 Policy option 2

 Policy option 3

 RISK: switch to unsustainable crop fuels

 RISK: high cost

 RISK: high cost + buy out

24



Cost estimates are based on: volumes of renewable fuels supplied

X expected premium of renewable fuels over fossil Benefit estimates are based on: carbon savings value added to the UK economy by the biofuels sector

25



Summary costs and benefits central scenario Option 1 Resource Cost, £m (Cost range, central scenario)

Carbon Benefit, £m

Wider Economic Benefit, £m Total (NPV) (NPV range, central scenario)

26

Option 2

Option 3

2536

3107

4405

848 to 5733

1213 to 6313

2623 to 5976

1605

1773

1861

375

529

438

-556

-804

-2106

-3753 to 1132

-4011 to 1090

-3677 to -324



Sensitivity Analysis is undertaken for: The key driver of costs is the spread between fossil fuels and renewable fuels ► low/central/high projections for global spreads ► different levels of total policy cost Uncertainty around availability of waste derived feedstocks ► higher price projections for “waste scarcity” scenarios ► different levels of total policy cost Uptake of E10 ► sensitivity scenarios for high/low E10 uptake ► crop cap may limit use of E10 from crop feedstocks Dieselisation of the fleet ► reversal of dieselisation trend ► crop cap may limit use of E10 Valuing carbon savings, GLOBIUM ILUC factors … 27



E 10 and the crop cap

RTFO current (year 7, 2014-5)

Central E10, No E10, central petrol (2020) central petrol (2020) – E10 share of 40%

High E10, central petrol (2020) – E10 share of 85%

GHG savings (MTCO2e)

2.4

4.2

4.5

4.8

Crop ethanol supply

808 ml

586 ml

891 ml

1200ml

1.3%

1.9%

2.5%

Crop ethanol 1.6% share (volume)

28



Weaknesses of evidence available  Supply cost of advanced fuels  Availability of sustainable waste volumes  Marginal carbon emissions versus average carbon emissions

 Other methods of estimating value added to the UK economy  …? 29



NGO VIEWS ON THE RTFO JAMES BEARD CLIMATE CHANGE SPECIALIST, WWF-UK 30 5-Jan-17

© ASHLEY COOPER/WWF-UK

KEY MESSAGES

Focus on quality not quantity

31 5-Jan-17

Be cautious with wastebased fuels

Limited role for biofuels in carbon budgets & the bioeconomy

FOCUS ON QUALITY NOT QUANTITY • Q13: Crop cap should be set at 0%.

• Q1: Obligation level depends on crop cap and cost-effectiveness of CO2 reductions. • Sustainable biofuels should be promoted if (and only if) “carbon cost-effective”.

32 5-Jan-17

BE CAUTIOUS WITH WASTE-BASED FUELS • Waste-based fuels can offer carbon savings but sustainability criteria are needed. • Waste hierarchy concept should be expanded to cover the full product life (cascading use). • Use of non-residual waste can lead to lower carbon savings and indirect effects.

33 5-Jan-17

LIMITED ROLE FOR BIOFUELS IN CARBON BUDGETS & THE BIOECONOMY • Carbon budgets: Focus on (low-carbon) electrification of transport as far as possible. • Bioeconomy: Focus on material use, reuse and recycling as far as possible before recovery. • Learn from experience: Take a cautious approach to avoid policy paralysis and investment hiatus.

34 5-Jan-17

THANK YOU FOR LISTENING

Focus on quality not quantity

35 5-Jan-17

Be cautious with wastebased fuels

Limited role for biofuels in carbon budgets & the bioeconomy

DRAFT

DfT RTFO stakeholders meeting 4th January 2017

36

DRAFT – Preliminary comments

Context…. • Climate change policy – –

Reduction in GHG in transport fuel RED1, FQD up to 2020 then RED2

• UK Economy –

At least meet required standards at lowest cost to the consumer

• UK Strategy –

John Hayes: ‘Our strategy is to provide a positive investment environment beyond 2020 to further encourage the development of waste basted and advanced fuels , while limiting fuel made from crop’.

• UK regulation – –

RTFO Motor Vehicles GHG emission regulations

37


RTFO consultation – 3 things to welcome • Sets out an RTFO trajectory to 2020 (but still unclear when it will start?) • DfT recognise key conclusion from the Transport Energy Taskforce that achieving 2020 targets is not easy and alternative abatement measures are in place. • Good that DfT has also outlined proposals for the longer term to 2030.

38


RTFO consultation – 3 key concerns • Restricted obligated supplier flexibility –

Given strong uncertainties about availability of sufficient volumes of double counting waste based fuel; more flexibility from E10, Crop cap, Marine fuel, NRMM…

• Advanced fuels – – –

Will they be commercially available in the required volumes? Therefore no need for sub targets prior to 2020. Allow all renewables, providing they meet the RED C&S criteria…. Advanced fuels suppliers need to ensure that their products will meet the CEN / BSI requirements for the relevant fuels supplied to ensure warranty compliance and prevent quality issues.

• Path to 2030; deviation from RED2 proposals –

Crop caps, advanced fuels, double counting, waste….

39


RTFO consultation – 3 recommendations for changes • To 2020, address the concerns of the previous slide – –

Obligated fuel supplier flexibility. Advanced fuels.

• From 2020-2030 –

Closer alignment with RED2; Need to maintain fungible fuels across the European continent which will need to continue following ‘Brexit’ outcome.

• Consultation Process –

These are major changes, three month consultation preferred.

40

DfT Quarterly Stakeholder Workshop – 4 January 2017

RTFO Consultation – Renewable Industry Perspectives

Clare Wenner – Senior Renewable Transport Adviser, REA

What we welcome First • Consultation is out. Pleased that this has taken into account the extensive debate that has taken place over the past few years • A lot of work done by the stakeholder community and the DfT, in particular the Transport Energy Task Force and subsequent work with officials • REA took on the challenge of examining more closely: o the role of renewable gases in transport o a definition of “advanced” fuels o sustainability • Hope that this work was a positive contribution to getting consensus all round on the direction of travel Second • Recognition that the RTFO has worked and can now be built on in setting the direction of travel to 2030 Third • Positive recognition of the need to give specific support to Development Fuels, including biomethane, HVO and aviation fuels

Key concern 1. – Obligation level to 2020 and 2030 (in light of the CCA) To 2020: • Current obligation level less than half what it needs to be by 2020 • Obligation level sets the level of demand – so less than half of where it should be for 2020 • Carbon saved about 30% less than it could have been – NB transport=25% of emissions and 40% of UK energy demand (biggest, and projected to be so for 20 years) • Size of the market has taken its toll on waste-based biodiesel and bioethanol alike, with biofuel producers taking the investment risk • So why is the obligation level proposed for 2017/18 so low? • Why do the proposals suggest a 5%-6% energy contribution when the Carbon Plan and the CCC June 2016 Progress report say 8%? To 2030: • Flat line from 2020 to 2030 is unambitious – leaves 90% open for fossil fuels if other developments are slower to materialise e.g. road electrification. Why? • Risk that transport does not contribute its share to the Carbon Budgets. Consultation acknowledges these proposals only deliver one third of GHG savings from transport by 2022 – so burden on other sectors of transport and the rest of the economy

Key concern 2. – Level of the crop cap •

•

DfT Cost Benefit Analysis - shows the higher the crop cap the more costeffective it will be in reducing carbon emissions and meeting UK’s targets – so most cost-effective for the consumer Crop-based biodiesel , especially use of palm oil, identified as the real problem: o o

o

• • • • •

No palm oil-based biodiesel in use in the UK in 2015/16 and to date 2016/17 (RTFO stats 3 November 2016) – no cap in place The transport members of the DEFRA Sustainable Palm Oil initiative, including the REA, are the only sector group not only to have reached the requirement for 100% certified palm oil, but to not use palm oil at all 0.01% (7 ml) from OSR/soy

So UK-produced bioethanol will take brunt of effects of the crop cap - 2% far too low to ensure a viable UK bioethanol industry Potential loss of nearly £1 billion investment and jobs and skills that go with this Shock waves in investing community – threatens advanced technologies Sales are showing that transition to electrification is via hybrids - over 90% are petrol hybrids which use bioethanol Latest FAO data (8/12/16) shows global cereal stocks in 2017 will be at their highest level ever and prices show little correlation with bioethanol production

Key concern 3. – Development Fuels sub-target •

•

• • •

Policy, including RTFO, should encourage sustainable low carbon renewable fuels to displace high carbon fossil fuels, NOT other sustainable low carbon renewable fuels Biomethane should be included as a Development Fuel: o Waste-derived methane meets aims of Development Fuels target, and is best option for decarbonising HGVs (replacing fossil fuels) o Low carbon truck trials have shown that methane slip issue has been resolved o Deployment will be limited by growth of gas vehicle fleet – several years before there is any danger of biomethane filling the sub-target Other low carbon non-conventional fuels should also be included, such as biopropane Eligibility of sustainable wastes and residues needs clarification Policy across low carbon energy should be joined up so that there is no multiple claiming of feedstocks, especially wastes and residues

Recommendation for change 1. – Obligation level To 2020 • Minimum 7.25% + straight line trajectory from there - when RTFO is amended: o to restore market demand to accommodate potential for waste-based biodiesel (to B7) and UK-produced bioethanol (to E10) o to ensure that 9.75% is reached to set UK transport on the path to a real contribution to meeting Carbon Budgets 3, 4 and 5

To 2030 • Increase percentage obligation level to 2030: o the higher the sub-target the lower the RTFO target for other fuels, including waste-based UCO – illogical o liquid fuel demand is expected to decrease to 2030 so market will shrink o single counted renewable fuels should not be displaced by Development Fuels under the overall RTFO obligation, so the Development Fuel subtarget should be additional to the RTFO target o investments need growth not a static or shrinking market o rules will ensure that all feedstocks are sustainable o provide flexibility if other developments are slower than anticipated – e.g. electrification

Recommendation for change 2. Crop cap Should stay in line with competitors in Europe, to: • maintain c. £1 billion investment in UK bioethanol production • provide an alternative market for UK arable farmers – post Brexit/post CAP • supply c. 1 million tonnes of high protein animal feed to substitute for imported soy and help UK balance of trade – food AND fuel • counteract market volatility and give incentive for increased sustainable productivity (all markets)

Recommendation for change 3. Development Fuels sub-target • Should be additional to the base line RTFO target • Buy-out price to be set at high end • Eligibility should be clarified • Process for reviewing eligible feedstocks and Development Fuels in the future to be clarified

THANK YOU Clare Wenner [email protected]

GHG Regulations consultation Stakeholder workshop 4 January 2017

Agenda GHG Regulations proposals – overview and context GHG Regulations - cost benefit analysis NGO UKPIA

Upstream sector view - Shell Panel discussion

50

3 Jan 2017 GHG Regs consultation - stakeholder workshop


GHG Regulations proposals: overview and context


4 January 17 3 Jan 2017 GHG Regs consultation - stakeholder workshop

51

Consultations Launched 29 November Ministerial Roundtables 15 December Discussions today Closes on 22 January Publish summary of responses by 15 April Publish Government response Consult on guidance

Parliamentary debates Introduce statutory instruments 52



What are we trying to achieve?

Waste, 4% Agriculture & land, 8%

Transport, 23%

Greenhouse gas emissions by sector 53


Power stations, 24%

Domestic buildings, 12%

Non-dom buildings, 5%

Industry, 24% Moving Britain Ahead January 17

Brexit implications

While we negotiate our exit from the European Union the UK remains a full member of the EU and all the rights and obligations of EU membership remain in force. During this period the Government will continue to negotiate, implement and apply EU legislation.

54



Reducing greenhouse gas emissions from transport By 2020, GHG emissions from transport should have reduced by 6%

55



Rewarding the best low carbon fuels  Trial GHG reduction period to 2020

 2% in 2018  4% in 2019  6% in 2020  Longer term role?  Drive investments and sourcing of better renewable fuels e.g.:  renewable fuels from wastes,

 advanced renewable fuels,  renewable fuels of non-biological origin, and  investments in efficient processing technologies…  Encourage electrification of the fleet  Longer term incentive? 56



Rewarding upstream emission reductions associated with extraction of crudes  E.g. reduced flaring and venting of methane/natural gas (associated petroleum gas or APG) which is often released as a co-product alongside oil

 Global potential is huge – 400 million tonnes of CO2 per year – equivalent to 30% of EU’s annual gas consumption  Across EU, savings from UERs of ~53 million tonnes of CO2 needed.  UK needs savings of ~2.5 million tonnes/CO2. 57



Increasing transparency  Reporting feedstock trade names (FTNs) to identify source of crude oils  Enables monitoring of GHG emissions  Requirement continues beyond 2020

58



Looking forwards – European Commission proposals

 On 30 November 2016, the Commission adopted the package on Clean Energy for All Europeans.  Of relevance to the FQD is the Proposal for a Regulation of the European Parliament and of the Council on the Governance of the Energy Union (COM(2016) 759 final): http://ec.europa.eu/energy/sites/ener/files/documents/1_en_act_part1_v9_759.pdf

 Proposes to remove supplier reporting requirement from FQD7a (and Directive 2015/652) – but timing is uncertain and certainly after the deadline for transposition  A later proposal will apply this instead to the refinery - potentially through amending the 95 Regulations

 Also proposes to bring MS reporting deadline forwards from 31 December to 31 August – may have implications for supplier reporting deadlines. We need to consider further.

59



Renewable electricity in transport is proposed to be included in EU supplier targets after 2020

60



Today

 Clarify areas of uncertainty  Highlight key issues  Hear others’ views

61



GHG Regulations Cost Benefit Analysis Stakeholder Workshop 4 January 2017


January 17 Stakeholder workshop 4 Jan 2017 RTFO CBA

62

GHG System Design Implementation of the GHG target will closely resemble and complement the current Renewable Transport Fuels Obligation (RTFO). This will include: • GHG obligation requiring fuel suppliers to reduce GHG intensity of fuel • Buyout price creating demand for GHG credits and a cap on costs • Certificate trading scheme giving suppliers increased flexibility to meet the target at least cost 63

Stakeholder workshop 4 Jan 2017 GHG CBA


Policy Options (1) Six different policy options are assessed in GHG regulations cost benefit analysis. The policy options vary in two key respects: (1) level of buyout price (£7/tCO2, £74/tCO2 and £174/tCO2); and (2) duration of target – either 1 year (2020) 3 years (2018 to 2020)

64



Policy Options (2) option 1a 1b 2a 2b 3a 3b

implementation period 1 year 3 years 1 year 3 years 1 year 3 years

buyout price (nominal prices) £6/tCO2 £6/tCO2 £74/tCO2 £74/tCO2 £146/tCO2 £146/tCO2

Preferred Option: 3 year target duration (2% in 2018 to 6% in 2020) with £74/tCO2 buyout price (option 2b)

65



Why Option 2B? • Buyout price consistent with wider government policy - buyout price set in line with ‘non-traded’ sector carbon price (£74/tCO2 in 2020)

• 3 year target trajectory gives more time for adaptation and assessment -3

year trajectory (as opposed to single year) gives additional time for suppliers to become familiar with the scheme and for officials to assess performance

66



Interaction with RTFO

67



Target Compliance Options Our analysis assumes that suppliers have 3 broad options for complying with : (1) switching to lower GHG energy sources; (2) improving biofuel GHG savings; and (3) Upstream emission reductions (UERs)

68



Uncertainty – costs and benefits • Significant uncertainty over what abatement options will be used and associated costs and benefits – therefore wide ranges used in CBA

• Buyout price provides certainty on upper limit for costs. • Upstream Emissions Reductions (UERs) will be eligible for GHG credits. However, proving that a UER project is ‘additional’ and has led to genuine GHG savings typically relies on economic/financial assumptions

• Suggestions on how to ensure additionality of GHG savings are being sought during the consultation 69



CBA Outputs 2018 max pump price impact

2019 max 2020 max pump pump price price impact impact

GHG Net savings present (MtCO2e) benefits (£m)

NPV (£m)

Option

Net present cost (£m)

1a (1 year, £7 buyout)

0.3 to 12

0.00

0.00

0.03

0 to 1.3

0 to 74

-12 to 62

0.3 to

0.00

0.004

0.03

0 to 1.4

0 to 82

-13 to 69

0.3 to 148

0.00

0.00

0.42

0 to 2.5

0 to 148

-148 to 136

0.3 to 166

0.00

0.05

0.42

0 to 2.8

0 to 165

-166 to 152

0.3 to 293

0.00

0.00

0.84

0 to 2.5

0 to 148

-293 to 136

0.3 to 327

0.00

0.09

0.84

0 to 2.8

0 to 165

-327 to 152

1b (3 years, £7 buyout) 13 2a (1 year, £74 buyout) 2b (3 years, £74 buyout) 3a (1 year, £146 buyout) 3b (3 years, £146 buyout)

70



GHG Reporting Regulations • The FQD requires fuel suppliers to report ‘origin (feedstock trade name)’ and ‘place of purchase’ data for fossil fuels supplied into the UK market • We understand that it is possible to collect most of this data at the refinery and therefore we have assumed that passing this information further down the chain to the supplier (where relevant) should not place any significant additional burden on fuel suppliers. Do you agree?

71



VIEWS ON THE GHG REPORTING REGULATION Laura Buffet, Oil & Biofuels officer London, 04 January 2017

T&E: 27 COUNTRIES 5 UK MEMBERS

73

KEY MESSAGES

74

GHG target: focus on quality

Tighten UERs eligibility criteria

Electricity support is welcome

Oil reporting requirements too weak

UERS – QUALITY NOT QUANTITY 1. Ensure additionality. 2. Avoid multiple counting. 3. Limit eligible offsetting schemes to CDMs in Least Developed Countries. Exclude credits from JI and unconventional oil projects. 5. No accumulation of credits over the years. 6. Adequate monitoring and full transparency.

75

UERS – QUALITY NOT QUANTITY Q6

Main characteristics

• Proposal needs stronger safeguards: additionality, eligibility, transparency. • Unclear what happens when legislation on flaring/venting already in place.

Q7

Standards for additionality

• Requiring minimum standard for each criterion listed at ISO 14064-2 5.4 is crucial to ensure additionality.

Q10

CDM & JI projects

• EU Commission guidance – coherence with ETS rules. • Limit eligibility to CDMs in LDCs. Exclude JI and unconventional oil projects.

76

SUPPORTING ELECTRICITY Q12

Credits for electricity suppliers

• Welcome the inclusion of electricity used in EVs - important to reward electrification of the fleet. • Infrastructure operators could also receive GHG credits, to ensure direct reward. Cf Californian LCFS.

Q13 & Q16 Data • Proposal to use both actual and estimated data is fine. • Important to ensure that actual data used as much as possible.

Q14

Methodologies

• Methodology C – EV usage value specific to charge point type - would be the most accurate.

77

STRENGTHEN OIL REPORTING Reporting origin & place of Q27/28/29 purchase • Concerns with weak proposed approach. • Multiple exemptions could lead to very limited/no information being collected. • How to control the fact that suppliers don’t have the information? • Chain of custody is needed – not only for biofuels, also for oil products.

78

KEY MESSAGES

79

GHG target: focus on quality

Tighten UERs eligibility criteria

Electricity support is welcome

Oil reporting requirements too weak

DRAFT

DfT FQD stakeholders meeting 4th January 2017

80


Context…. • Climate change policy – –

Reduction in GHG in transport fuel RED1, FQD up to 2020 then RED2

• UK Economy –

At least meet required standards at lowest cost to the consumer

• UK Strategy –

John Hayes: ‘Our strategy is to provide a positive investment environment beyond 2020 to further encourage the development of waste basted and advanced fuels , while limiting fuel made from crop’.

• UK regulation – –

RTFO Motor Vehicles GHG emission regulations

81


Motor Fuels GHG reporting regulations – 3 things to welcome • Sets out the mechanisms for reaching the 2020 target • DfT recognise key conclusion from the Transport Energy Taskforce that achieving 2020 target is not easy and alternative abatement measures are in place. • Practicable approach to reporting of ‘origin’ and ‘place of purchase’

82


Motor Fuels GHG reporting regulations – 3 key concerns • Interim targets in 2018 and 2019 – –

Not in the FQD, GHG come from biofuels added to the fuel.. Preparation 2020 target can come from ‘report’ only...

• Limited scope for obligated suppliers, e.g. –

No Marine, NRMM, Crop cap…

• UERs and Alternatives –

Will UERs be commercially available?

–

Essentially may become a tax on the consumer.

–

Buyout needs to be at a level just above the traded ‘market’ level, double penalty in RTFO and FQD.

83


Motor Fuels GHG reporting regulations – 3 recommendations for changes • Interim targets –

Report basis only.

• More supplier flexibility –

Allow Marine, NRMM, Crop cap… as Directive.

• UERS and Alternatives – –

Separate fuels target from EV (to be consistent with the RTFO) Buyout level & allow bought out RTFCs to contribute.

84

RTFO consultation stakeholder workshop - Gov.uk

RTFO consultation stakeholder workshop - Gov.uk

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