Sustainable Aviation Fuel Bill (First sitting)

Luke Taylor Excerpts

Committee stage
Tuesday 15th July 2025 Public Bill Committees

[The Chair]

That is noted and recorded.

[Luke Taylor (Sutton and Cheam) (LD)]

As the chair of the all-party parliamentary group for the future of aviation, travel and aerospace, I have met a number of the groups that will be presenting today. In fact, I met Rob only yesterday for information on the Bill and its content.

[The Chair]

That is noted and on the record.

Examination of Witnesses

Paul Greenwood, Rob Griggs and Gaynor Hartnell gave evidence.

--- Later in debate ---

[Graeme Downie (Dunfermline and Dollar) (Lab)]

Q To pick up on an item raised by Mr Greenwood, we have heard the Government talking about how this is the first legislation of its kind in the world. What impact do the other members of the panel feel it will have on the global market for SAF, and for airlines more generally?

Rob Griggs: One of the key reasons why we support the RCM and see it as necessary is that we have a mandate that—unlike the EU mandate, for example—has an advanced subsection. We therefore require advanced SAF. At the moment, something like 85% of all the SAFs produced in the world are first-generation HEFA—hydro-processed esters and fatty acids. That is used cooking oil-type SAF; it is perfectly legitimate, but it is ultimately feedstock-constrained. The world will be drawing on more and more SAF, and at some point we will be likely to reach what people are calling a HEFA tipping point, where there just will not be enough of it.

The UK, through its policies, is focusing on second-generation advanced SAFs, which are technically more challenging and more expensive, but also more scalable. As airlines, the absolute worst-case scenario that we are trying to avoid, and that we think the RCM is really important in helping us avoid, is a situation whereby in 2030 the suppliers who are the mandated party simply cannot access through the market the advanced SAF they need to fulfil their mandate obligations. It is not being made anywhere at the moment. A lot of HEFA is being made, but not advanced SAF.

We need advanced SAF here in the UK. The US is making some advanced SAFs, but they have feedstocks that are not for our mandate—they are often crop-based. Without the RCM driving the production of advanced SAFs, we are concerned that we simply will not be able to access it. If that happens, the buy-out price kicks in for the suppliers, which is likely to be passed on to airlines.

The worst case scenario is that, in 2030, the mandate essentially fails because there is high buy-out, all the cost gets passed on to airlines, there are no SAFs, which means no decarbonisation, and then we are unable to claim our SAF against the emissions trading scheme obligations, for example. To be clear, we do not think that the RCM should cover all mandated volumes of advanced SAF; there needs to be competition. It should be there to get those first plants built, and to provide a quantity of that mandate—potentially a substantial quantity, but part, not all, of it.

If we can get a competitive scheme, where the market for advanced SAF is becoming competitive, and the RCM helps to get some of those first difficult plants built, the UK could be in an advantage position, because the global market for SAF, at some point, will need to expand into the advanced SAF area, and the UK could have got a head start on that through our approach. That is the upside of what we are doing, notwithstanding the challenges of getting it right.

Gaynor Hartnell: The question was about the impact on global supply. I think Rob is absolutely right that the UK’s policy is unique. It is very much envied. I have been at many conferences where the greenhouse gas basis, versus it being volumetric, was lauded. The existence of the RCM is envied by SAF developers in other jurisdictions. It is already having an influence globally by being visible in doing this special seeking-out of waste-based SAFs, which are incredibly challenging to develop. These projects are very complicated, which is why the RCM is totally necessary; I disagree with Paul Greenwood about that.

Paul Greenwood: Let me build on the question of necessity. To be clear, I know that everyone is trying to do the right thing here, but the reason this is being called for, for entities in the marketplace, is because it is very difficult to manufacture things in the UK, and that is because energy costs, carbon dioxide costs and labour costs are incredibly high. It is very difficult. Not very long ago, we used to have six refineries in the UK; one of them was shut down for operations and another has gone insolvent. There are four refineries left, so it is very difficult to manufacture things effectively in the UK at a profitable level.

What the Bill does is say, “Because of that problem, we’re going to incur more costs in a niche, new business, and we’re going to input that cost on to the existing fuel suppliers, which are already struggling to survive.” We need to be clear about what problem we are trying to solve. Effectively, I think this is a distraction. We need to look at the core fundamentals that are impacting our manufacturing base in the UK, because that is the primary struggle that we have.

[Luke Taylor]

Q Thank you for joining us. I think we are in a slightly unusual position, in that we are all competing to try to make slight improvements to legislation that we all agree is necessary and positive. My question is about the source of the funding for the RCM. The Government made it clear that their preference is that it comes from a levy on users. An alternative, which we see in other jurisdictions, is that it comes from ETS sources, which would slightly more directly couple the emissions component to the consumption. The intention to not predicate the source of funding on the money being provided is clear. Do any of the panellists have an opinion on those two options and the path that the Government have taken for the funding source?

Gaynor Hartnell: There are really only two options for the levy: airlines or aviation fuel suppliers. A large part of why aviation fuel suppliers were chosen may have been because, administratively, they are the obligated party when it comes to the mandate. They are expected to pass the cost of the mandate through to airlines—their fuel customers. They would be expected to pass the cost of the levy to airlines, or indeed, if the levy actually brings in money—these are very small balances of money in comparison with the balances to do with the mandate—they would be expected to pass those costs back to the customers. The aim is to deal fairly with a fairly small amount of money. It is not the additional cost of the sustainable aviation fuel; it is just the cost of levelising and stabilising it, which is a sliver in comparison.

Rob Griggs: For us as airlines, the funding is a critical issue about fairness and accountability. As Gaynor said, the understanding is that the levy will be on the supplier. The issue for us is that we understand that the costs are likely to be passed through to airlines. We just want to make sure that that is transparent. We have seen through the early stages of the mandate that there is some concern that excessive compliance fees are perhaps being put on to the SAF. Voluntary SAF seems to be a lot cheaper than mandated SAF and there is not necessarily a clear reason for that. We want transparency in terms of how the levy is passed through.

As Gaynor said, in theory, if the market price for SAF is high—if there is relatively little of it—it is likely that the suppliers will actually pay into the counterparty. We want to make sure that if money is essentially being paid back to the counterparty from the producers, that money does not just go to the suppliers and sit there. There should be a transparent mechanism, however it works, through which that money then comes back to airlines and airline customers. It has to work both ways, essentially.

How do you do that? We have looked at ETS for a long time. You are right that in the European Union, the emissions trading scheme funds are used: for example, to help to close the price gap on SAF. We are not doing that, which has competitiveness implications for UK SAF, separate to the RCM. Of course there are ways to make sure that it is a two-way street.

Paul Greenwood: We have to recognise that if the desire is to pass the cost on to the passengers, the airlines and the people who are shipping freight around the world by plane, then we should put the charge on them. That is the most direct way of doing it. There are charges now that are put on airlines and on freight directly. There is no reason why you cannot do this as well. I do not buy the argument that it is a relatively small amount of money, therefore we should just put it on to the fuel suppliers and they should deal with it. I do not think that is right. I certainly do not agree with the idea that this is because “the polluter pays”—that is erroneous and a false statement.

We do not know how much this will be, because we do not know how many projects there will be, what the costs will be, or how the CFD mechanism will go. We do not know what the cost of this will be. I support what Rob is saying: if this is something imposed upon us, I do not wish to profit from it but I do want to pass 100% of it on to the consumer of my fuel. The only way I can do that is if I know what it is ahead of time, so that I can bill them the exact amount of money so they pay the exact amount. At the moment, this legislation talks about market share, but market share moves and changes. Therefore it is a very imprecise way of doing that.

Ours is a very fine margin business. If you get this wrong, you will make the UK a less attractive market. We have to understand that fundamentally people will do different things around their molecules. One data point worth remembering is that about 70% of the jet fuel consumed in the UK at the moment is imported. Effectively, we rely on people bringing jet to market to sell it profitably. If they are uncertain around the cost of that jet fuel, they will potentially look to sell it into different markets, which can lead to energy security and market dynamic issues. There are unintended consequences here that need to be thought through very carefully.

[Chris Vince (Harlow) (Lab/Co-op)]

Q I thank the panel for coming to give evidence. Rob, in your opening statement you spoke about this being an enabling Bill. Could you touch on what you think the next steps would be were the Bill passed? I also have a basic but important question: what do you all see as the impact of this Bill, whether positive or negative, in terms of environmental and economic benefits? Is there a risk in not getting on with it?

Rob Griggs: To take the second point first: on the environmental side, UK aviation is committed to net zero 2050. We have not wavered from that commitment, and SAF is a hugely important part of that. It is doing the physical and metaphorical heavy lifting for our road map to get there. We need to do a lot of things—there is no silver bullet—but the last industry road map we all agreed had SAF at around 40% of the decarbonisation to 2050. That number will obviously change, but it is hugely important. The UK has a world-leading aviation industry, which does a huge amount for the UK economy. We believe we can grow and decarbonise, but we cannot do that without SAF. It is hugely important for both its economic and social benefits.

In terms of next steps, we fully support the Bill, and we hope the process can go as quickly as possible to get that certainty for investors and help to get those first plants built. For us, it is then down to the importance of scheme design and ensuring that we look to get that balance right for the most cost-effective decarbonisation to meet all those objectives: what size of scheme, how many and what type of projects are supported, what proportion or volume of SAF it would be looking to support and, through that, how you ensure there is competitive tension between those projects that are bidding for support and those projects that do not think they need support. It is about getting that right to ensure that we are getting best value from the projects that will deliver best bang for their buck and can produce the volumes that we need quite quickly. There are a lot of different technical elements.

Then there is funding and the transparency around that—how do we ensure it works and is accountable? If we have a scheme in place that is delivering SAF as cost-effectively as possible, it is starting to produce some, we have the quantities we need by 2030 and we are avoiding buy-out—if all those things happen together, enabled by the RCM, that is the outcome we are looking for.

Gaynor Hartnell: In terms of what is next, yes, there is a lot of detail involved in thinking about how the contracts are structured. We expect to engage with officials in great depth on that.

You asked about the environmental benefits; do you mean the environmental benefits of SAF generally, or the specific environmental benefits of producing SAF in the UK, which is what the Bill is about?

--- Later in debate ---

[Lewis Atkinson (Sunderland Central) (Lab)]

Q Building on the point Mr Ervine made about the potential wider economic contribution of SAF, I am particularly interested in the jobs. We have heard that 70% of existing fuel is imported, and therefore a significant part of your economic supply chain is essentially providing economic benefit overseas. Could you say a little more about—if we get this off the ground, as it were—how far you think that value chain and economic benefit will shift into the UK from imports? In particular, could you talk about the potential regional economic benefits of SAF, as opposed to being concentrated on London and the south-east?

Jonathon Counsell: From our modelling and analysis, we still want to have the flexibility to import SAF, because there is a global market there and we do not want to put ourselves at a competitive disadvantage by saying that all mandated SAF has to be produced in the UK. We still want access to imported SAF, particularly 1G SAF; we do not think the UK has much competitive advantage in producing 1G SAF. We think roughly 50% feels about right, and you have to compare it around that. Our view is that, of the mandated SAF, approximately 50% should be produced here in the UK—but, as I said earlier, not all of that will need the revenue certainty mechanism.

One of the key points that I want to make is that the revenue certainty mechanism is for those plants that cannot get funding: they are early stage, first-of-their-kind technology, and cannot get tracker funding because it is perceived to be too high risk by the investment market, and they cannot get that revenue certainty through any other mechanism, so therefore they rely on this mechanism. We think that roughly half of that 50% will need the revenue certainty mechanism.

A good example is LanzaJet in Teesside, the speedboat project that I mentioned earlier. That does not need the revenue certainty mechanism because we at IAG are providing the company with a long-term committed take-or-pay offer. We are giving the revenue certainty to LanzaJet, so that project does not need it; but other projects do, typically including the municipal solid waste projects that take black bag waste. They are at a very early stage, using less mature technology, and they are massively capital intense projects. They definitely need the revenue certainty mechanism, so we must ensure that it is targeted.

As Luke said, we think that by 2030 there could potentially be 10,000 extra jobs in the UK from that UK production. We can share a piece of analysis that we did through Sustainable Aviation that showed what that looks like for each region of the UK. We think there is certainly potential to build plants in Wearside, Teesside, Humberside and south Wales; if we get the policy right, we think there could be up to 14 plants within the next 10 years, which will deliver £1.8 billion in GVA by 2030.

However, the big prize will come in 2050: 60,000 jobs and £10 billion in GVA. We are creating a new energy industry for the UK. I have to congratulate the Government: we have potentially the most powerful package of SAF policy in the world, with the mandate, the revenue certainty mechanism and the advanced fuels fund. Taken together, they mean that we are the envy of the world and we have a huge chance to be a world leader on SAF production.

Lahiru Ranasinghe: To add to that, it would also enable UK aviation to grow. Our estimates are that each aircraft based in the UK supports around 400 jobs and £27 million of GVA. We have over 150 aircraft in the UK as it is, we have three aircraft going to a new base in Newcastle shortly and we absolutely intend to continue with the growth in the UK. By having the RCM unlock SAF production and SAF supply, that opens the doors to us to continue growing, while also decarbonising. That is a massive part of the economic benefit that the RCM helps to unlock, beyond the obvious effects of supporting jobs and production on the ground in the SAF industry.

Luke Ervine: Just to add a note on benefits, it is important to recognise the cost of not having the RCM. We have spoken a lot today about the buy-out. The UK is unique in its ambition to have a 2G SAF mandate, so the cost of not having the RCM is important. If we do not have it, we pay buy-out, and then we are going to lose out regionally to other areas, such as Europe and the US, that do not have those 2G SAF mandates, so it is important that we recognise that there is a cost of not having the RCM.

[Luke Taylor]

Q Thank you all for joining us. The evidence that you have given so far has been very helpful. There was a question earlier about waste hierarchy and the availability of waste feedstocks as one source of raw fuel or raw material for some of the second-generation SAF. Is enough being done across Government, in a holistic way, to ensure that the goals of the SAF mandate, the RCM and this Bill are achieved? Is enough being done to ensure that the things that are needed—waste feedstocks, the reforms to planning and energy production for eSAFs—are in place? What is going to hold back what we are trying to achieve in this Bill, and what needs to be done elsewhere?

Jonathon Counsell: That is a really strong point. There is a key question about the waste hierarchy, which Gaynor spoke to. Currently, waste going to SAF is treated the same way as incineration or energy from waste, but the analysis is clear that we can get twice as much energy capture from producing SAF than from producing energy from waste. We feel that you are getting a lot more bang for your buck from using waste to produce SAF than from other things, which we think should be reflected in aviation being prioritised in the waste hierarchy.

On renewable energy, last year the Sustainable Aviation road map made it quite clear that 3G SAF—where you basically electrolyse water to get hydrogen and you capture CO₂ from the atmosphere—is going to take a lot of renewable electricity. We are going to need a lot more of that within the UK if we are going to support a domestic power-to-liquid market.

Luke Ervine: In addition to that, we need to think about other areas of SAF, when we talk about SAF having a nominal value associated with its ability to reduce greenhouse gases. We are working alongside the Department for Energy Security and Net Zero and the Department for Business and Trade to understand how carbon can form part of the solution, and decarbonising the SAF that we are producing is also key. We are also working side by side with the Treasury to understand what the revenues from the ETS look like.

That has been quite successful in the last few years, especially since the advent of the jet zero taskforce, which was a really key turning point. I think we are going to continue in that vein to work cross-departmentally and across industry to work through some of these finer details. I think it has been very useful to be part of the Jet Zero Council; we are actually a co-chair, alongside Mike Kane, of the jet zero taskforce. Carrying on in that vein is very important and useful.

Lahiru Ranasinghe: This also enables us to reduce our dependence on used cooking oil imported from elsewhere in the world as a feedstock for first generation SAF. A strategic move towards 2G and 3G also gives more flexibility and capability for the market to scale up in the long-term, and allows it to use waste products from the UK, as opposed to having to ship it in from China or south-east Asia.

[Graeme Downie]

Q You alluded to this earlier, but have you done any work with your customers—either passenger or freight—on how much they care about SAF specifically, or sustainability more generally? If you were not working towards the kind of targets that you are, do you think that would impact customer choice? Do you see this as a competitive advantage between yourselves, or globally as well? Also, to pick up on something that Jonathon mentioned earlier, do you think there is enough in this legislation on what needs to happen after, if it is passed, to encourage the necessary investments, particularly in third-generation SAF and beyond that?

Jonathon Counsell: On the customer perspective, we did a lot of surveying of our customers, and it is no surprise that there was a bit of scepticism about offsets and all the history with those. When it comes to SAF, I think there is general recognition and support: people think, “You burn a lot of fuel, so it just makes sense that you are trying to find a lower carbon fuel.” There is a lot more acceptance of that. We have always offered voluntary schemes for our customers to offset their emissions. We provide offsets, carbon removals and SAF. The uptake is very low, but SAF is proving quite popular, so I think there is greater acceptance of SAF as a solution for aviation than some of the others.

What I will say is that corporates have gone gangbusters—if I can use that technical term—on SAF, and we do something called SAF Scope 3. A lot of the big corporates set very ambitious net zero targets by 2030, particularly professional services firms such as consulting firms, banks and law firms. When they do their carbon footprinting, a huge proportion is from their flying activity, so they come to us and say, “I want to address my carbon emissions”, and we can offer them SAF. We can sell the carbon attributes as what they call a Scope 3, and that has literally taken off. Most of the SAF that we bought last year came with a SAF Scope 3 deal from a corporate. That is fantastic, because we can use that revenue to reinvest and buy more SAF. From a corporate market, there is definitely very good acceptance of the power of SAF to reduce our emissions.

--- Later in debate ---

[Euan Stainbank]

We have talked about targeting. Would you support any further specific policy interventions to help to stimulate advanced 2G SAF technologies that might otherwise struggle to scale up?

[Luke Taylor]

I just have a pushback or challenge on the comments about SAF being popular. An earlier pushback, too, was on the £1.50 per passenger on top of tickets. Does that suggest that this might be easier to sell—easier to promote—to passengers than you might have suggested in the first place? I think the suggestion was that certain demographics and certain airline customer groups will be more or less in favour and able to pay it.

Lahiru Ranasinghe: To add to that, for us, the average leisure traveller would say—to put it in colloquial terms—“It’s your problem to solve. We want you to do it, but we’re not going to pay for it.” With corporates, they have their own corporate targets, so from a B2B—business to business—perspective, they want to hit those.

Jonathon Counsell: I will answer the risk question. Yes, without the policy, we have no 2G SAF, so we would be dependent on the 1G market, which will cap out in the early 2030s. We are not going to achieve our decarbonisation targets without 2G SAF. That is the biggest risk without the Bill.

The biggest risk with the Bill is buy-out. If the incentive does not produce enough SAF—we understand the buy-out is there to manage short-term supply shortages, but if we have long-term buy-out, which we have seen in the ground transport fuels market—that is policy failure. Essentially, that huge cost is £6,000 per tonne of SAF, and if that cost comes straight back to the airline, it will go on air fares, but you do not get any decarbonisation—you get huge cost and no decarbonisation. That is our biggest risk.

Luke Ervine: Some of the risks of the RCM that we need to be cognisant of include covering too much of the mandate with the RCM. We do not want to lock ourselves into high prices forever and a day. Obviously we want that to stimulate the part of the market that needs that support, so we want to leave enough room for competition.

The other thing we need to think about is how suppliers might bear some of the risk that is presented in the RCM—how some of the cost of capitalising the fund, or any cost of compliance failures that they may face, might be passed through to airlines and consumers. That key area of transparency is therefore important. This needs to be well thought through, but we also need to do it quickly because we are reaching a pivotal point in terms of buy-out where we will have to just pay for no decarb.

Lahiru Ranasinghe: Ultimately, the RCM is a derisking measure. It is a stepping stone towards what we want, which is a functioning SAF market. It is a complicated challenge. There is a lot of work to be done over the coming stages and throughout the process to make sure that we end up with a competitive UK SAF market so that producers can compete on a global scale, and, crucially, we as airlines can compete on a global and European scale by keeping flying affordable and continuing to grow in the UK. On an environmental level, if there is x amount of growth coming through the UK, which is supporting an environmentally robust SAF mandate, and production in the UK, as opposed to that going elsewhere in the world, that is driving sustainable growth on a global scale.

Jonathon Counsell: On the amendment question, I do not think we need to look at any amendments at this stage. On the targeting of the scheme, we should make it an opt-in scheme for the projects that need it. We do not want a blanket scheme to cover all 2G SAF because that is not needed, but we could have projects opt in with some qualifying criteria—for example, projects that are early stage, first of a kind or high risk, and that cannot get funding without the scheme.

I would not say SAF is popular—that is probably going a step too far. It is fair to say there is greater acceptance of SAF as a solution, but let us be clear: nobody wants to pay for it. However, we accept that there is a cost to the net zero transition, and our job is to minimise that cost as far as possible.

[The Chair]

Euan, do you want to follow up on that?

--- Later in debate ---

[Greg Smith]

Q This question is probably more for you, Ms Haywood, given the ethanol element of your product. Clearly, there has been some concern in the UK that the lower tariffs deal with the United States has quite a significant bioethanol element to it, which has made UK producers nervous, if I can put it that way. Given that what sits underneath a lot of the Bill is domestic fuel security and production here in the UK, how big a concern is it for you, producing SAF that is ethanol derived, that we might not have that UK security, because we will be dependent on imports—in this case, imports of the bioethanol feedstock?

Sophia Haywood: At the moment, we are not allowed to use the bioethanol produced in the UK, because the majority of it is technically first generation, whereby it is produced from crops. The bioethanol here is particularly produced from crops such as wheat. I am not sure about the exact proportion that is grown here and then converted into bioethanol here.

I think that SAF is a great opportunity for the challenge that the bioethanol sector is currently facing. If we were allowed to use in SAF the bioethanol that is currently allowed to be used in the road transportation sector, we would be able to take that and convert that into jet fuel at our facility Speedbird. I did some quick statistics—quick maths—looking at the total capacity that we have for bioethanol production in the UK today. If we took that additional capacity—not counting our current project, which is 2G or second generation—we would be able to build three and a half more Project Speedbirds in the UK, just taking that potential capacity, if that was all theoretically to come to us.

We see SAF as a great opportunity to fix the current issue that the bioethanol sector is facing. Certainly, we see it as complementary also to the scale-up of 2G, because for us it means that we can reduce the overall cost of project development and we could still transition to 2G over time, or indeed have blends of first generation and 2G together to increase roll-out. For our technology, as long as it is sustainable ethanol that is coming in, we are producing sustainable jet on the other side.

[Luke Taylor]

Q Thank you both. A lot of the criticism and cynicism over the value of SAF and its environmental benefits are around the fuel source or feedstuff—you have alluded to it. The Bill concentrates on second and third generation SAF. Do you see that as enabling a lot of the potential greenwashing of SAF that may have been behind all that cynicism? Does it address some of those challenges?

As a follow-up question, similar to one that I asked the previous panel, what do you see as some of the challenges across Government that will hold back your ability to produce more SAF? You referred to the ability to use some of the feedstuff to produce second generation SAF mixing, but I think planning and energy will be among the responses as well.

Sophia Haywood: On sustainability and fraud, I have been working on sustainability certification over a number of different fuel types. We have ISCC, which is like an auditing process that we generally have to go through—there are other providers out there—to be able to prove the sustainability of our fuel. This is a very complicated and rigorous process, and I have gone through it many times on different types of fuels.

On the sustainability piece, the guidance that has been put out already in the SAF mandate is very high, and we have to go through a lot of that auditing process. To your point about the risk of fraud and other challenges around greenwashing that potentially could have happened in the past, I think the UK has done a good thing there with how it has approached this, so I support the approach that we are taking. That is not necessarily in this Bill; I would say that that has more already been laid out in the mandate rules.

On what else we would like to see, potentially, through this, as I said before, there is a piece around the SAF allowances—this is a scheme currently in Europe that is funded through ETS revenues. Obviously, you are always taking from somewhere with funding, but you are trying to take at least from a funding source that is coming directly from industry, and using that to then fund the industry back with SAF. I think that has good bones and good structure, and I would love to see that being fleshed out.

On a more practical level, for sure, there is planning. We have just had a recent example that some of my engineers have told me about: waiting two months for an answer on a very small question. It is not because of the quality of the planning teams; they are fantastic. It is the fact that they are quite constrained and there are not enough of them. I suppose there is a potential short-to-medium-term fix there, but also a longer-term fix in terms of thinking of the skills that we need moving forward. We automatically think of more engineering and STEM roles, but we also need the rest of the value chain to be adequate in terms of workforce and other things.

I alluded earlier to the details of the mandate being really good on the sustainability piece, but there are some very complex rules that we are still consistently trying to navigate six months on. There are different interpretations to different questions—for example, in the nitty gritty of how hydrogen is treated or the rules around electricity and displacement. They are more in the detail, but we end up spending quite a lot of time on them as a company trying to break through into this market.

Equally, it is a learning experience for my colleagues doing these projects all across the world. We have other projects going on in India and Australia. As a Brit, I want the UK to be our flagship and our first, and I am working hard to make sure that it is, but as I always say to people, I am competing with my colleagues in Australia and all over because lots of people want SAF. It is about how we can make it as efficient and easy as possible, keeping in mind all the good sustainability criteria, to get steel in the ground here in the UK.

Noaman Al Adhami: From our perspective, the route we are using—the Fischer-Tropsch synthetic paraffinic kerosene route—is an American Society for Testing and Materials route that is approved already. On sustainability, the feedstock criteria are well defined in the SAF mandate. All the types of feedstock that are eligible to produce SAF are well defined. We are complying with that. The greenhouse gas and carbon intensity are other factors for measuring sustainability. For our project, without carbon capture, we are at minus 80% or minus 85% from the fossil equivalent. With carbon capture, we will go negative—we will go to even more than minus 200%. That is key for us.

On what could be done better, planning is always an area where we need improvement in terms of time. There is also connection to the grid, for example—grid connections take a very long time. We decided to produce our own power on site using a biomass boiler rather than waiting for a grid connection because the answer we got was that we will get it by the end of the 2030s—2039—and we cannot wait until then.

Another requirement, which is very specific to us, is to get connected as early as possible to the carbon network once we start producing SAF by the end of 2029, especially when there is a unique benefit for the UK. By the way, that is very unique to the UK. No other country has a SAF mandate that is about carbon scaling and at the same time has the capability to capture CO₂. That is also unique in Europe because the UK and Norway together have 75% of the carbon capture capacity in Europe. It is really very unique to the UK. Our ask is to get connected to reduce carbon intensity, provide a better price per certificate, and also pay, because we do not need subsidy for carbon capture. We are ready to pay the transport and storage costs to the Government for carbon capture. Those are the three main points.

[Euan Stainbank]

Q What effect has anticipation of the RCM and the corresponding timetable, which I imagine your companies are now working to, had on your ability to make a final investment decision? Can you give us as much detail as possible about your current plans, spades in the ground and such?

Noaman Al Adhami: Our project is a £2 billion investment. We need the RCM to be able to reach FID. We already have lenders on board, and that is the requirement they have asked us to secure before reaching FID. Our project was part of the windows of the advanced fuels fund. The original plan was to start construction by 2025—this year. We were planning all our development activities to be ready to start construction this year. Unfortunately, that is now not possible, because the RCM is now pushed to the end of 2026.

Yes, immediately after I sign the contract—the day after—I will start constructing the site and reach FID. I will technically be ready by the end of this year. I am finishing FEED. We have invested more than £70 million in this project so far and we will finish FEED by the end of this year, so technically I am ready to start construction after the end of this year.

If there are delays, we are worried. We are broadly very supportive of the Bill; our issue is timing. If I do not get the RCM by the end of 2026, then the project will be delayed, and then I will not be able to produce SAF as planned starting from the end of 2029, and then provide the market with the SAF quantities by 2030, when it is required, as per the mandate. The second-generation SAF is required in 2030. I will not be able to do that if there are delays.

Sophia Haywood: We are currently in the FEED phase, which is front-end engineering and design—we are really good at acronyms in this space. Basically, what that means is that we are looking at the facility specific to the site and designing everything up with the site. It is a really important stage, before we then go to a final investment decision. We are expected to go to a final investment decision next year. That is what we came out publicly and said. Any policy uncertainty in this space, even if it is for a good thing, creates questions, but at the moment we are still working towards that timeframe.

One of the things we are hearing at the moment on access to finance is a lot of positivity towards when you get to that final investment decision space. But again, who knows the full impact that this will have on the broader markets in the financial space as well? All eyes are on the UK; they have been, first with the SAF mandate, and now with the RCM. Also in Europe, there is a lot of looking to what the UK is doing.

This is undoubtedly going to have an impact, but in all honesty it is very difficult to say right now what that impact could be until more details are available. From our perspective, the development of the scheme as swiftly as possible and, as Jonathon Counsell said, the competitivity within that, is important. It is about as much swiftness as possible. We are very supportive at the moment of what is happening.