SAF sustainability and pricing

This year, the EU mandated 2% Sustainable Aviation Fuel (SAF) blending in all airports feeding into aeroplanes. The definitions of SAF for EU is clear, mostly based on a whitelist of feedstocks that are proven to be ‘sustainable’ and achieves a high level of carbon emissions reduction on a lifecycle basis (70% or more compared to A1 Jet Fuels). Unlike CORSIA, which puts the onus on airlines to reduce their emissions from jet fuels, RefuelEU regulations put the responsibility on fuel suppliers that supply to the airports. These suppliers will need to quote their prices to airlines accounting for these regulations, and while airlines don’t have to deal with the hassle of making sure the blend is correct to meet compliance requirements, they will need to bear the increased costs.

Now, there are also similar SAF regulations in the US under Renewable Fuel Standards, but their requirements for feedstocks and lifecycle carbon emissions reductions are different. Just to caveat first that I’m way less familiar with the US standards and requirement but based off some work from my colleagues, I understand they are less stringent, defining SAF to require 50% reduction in lifecycle carbon emissions compared to conventional jet fuels. This allows feedstocks such as corn ethanol, or other dedicated energy crop-based feedstocks (including canola, other oilseed crops) to be used for their SAF.

And if you refer back to the ICAO standards set under CORSIA, they only require that there’s 10% reduction in carbon emissions. It is still unclear to me what would constitute ‘SAF’ to the countries in Asia Pacific that are all introducing some SAF volumetric blending mandate.

One of the key challenges with just defining a standard threshold for carbon reduction and then setting a volumetric SAF target is that you don’t incentivise SAF producers to reduce their lifecycle carbon emissions. It becomes a race to the bottom for the airlines or fuel suppliers to buy the cheapest SAF that meets the threshold for compliance. If instead, we set a carbon emission reduction target and require the blend to achieve that target, then we can benefit from a greater diversity of SAF feedstocks and pathways that meets the economics on the basis of a unit carbon abatement cost. After all, the carbon emission reduction is the piece of value we care about for SAF at the moment, won’t it be better to price that?

SAF Pathways and value pockets

Today’s conventional wisdom around the Sustainable Aviation Fuel (SAF) market is that it will start with the HEFA pathway which converts oily waste compounds into jet fuel. The process is well established and economical. The challenge is aggregation of the feedstocks which takes the form either of used cooking oil and oily waste streams coming out of some vegetable oil production streams. They could also take virgin vegetable oil and oil from oilseeds to produce (but these tend to have a higher lifecycle emission associated with them as they are cultivated and will require fertiliser inputs and other resources).

The regulators and market expect that these feedstocks will be insufficient as the virgin oils should be reserved for food use and the waste-based feedstocks are limited. So then when the HEFA feedstocks supply goes down, prices of these feedstocks would move up towards the next SAF pathway. The popular contender after HEFA is the alcohol-to-jet (ATJ) pathway. They take bioethanol or methanol and turn them into jet fuel. This process is a bit more expensive, but because bioethanol is already being produced by various plants worldwide to supply provide for gasoline blending in countries with ethanol-blending mandate, it has a much more stable and ready market than used cooking oil.

Further technology pathways are expected to involve gasification where biomass is subjected to thermal processes that breaks down the material into constituent carbon, oxygen, hydrogen and nitrogen compounds, then reformed to make liquid fuels including jet fuel. These pathways are even more expensive, but their feedstock, which is pretty much any biomass, would be much more abundant.

So, the supply curve is expected to notch upward in discrete steps; once prices hit the threshold to unlock the next technology pathway, more feedstock will enter the picture and hence increase the supply of SAF available. This doesn’t mean that the earlier pathways will earn more margin, because the bottlenecks are the feedstocks; typically, the feedstock owners or aggregators tend to extract more of that value.

But this would mean that the prices of SAF should and can only rise as the mandate for more SAF and aviation decarbonisation becomes stricter and emission reduction targets become more ambitious. Now there is another transition to consider. That is a scenario where the chief driver of SAF adoption, regulations and blending would be decided by the market – but the outcome they are targeting would be based on proportion reduction of carbon emissions relative to conventional jet fuels.

Now of course, some from Oil & Gas players might think they can use carbon capture and storage to lower the fossil jet fuel intensity to meet the criteria. Yes to a certain limit; because the carbon dioxide emitted during the aircrafts’ journeys from fossil jet fuels will always been counted while the biofuel or synthetic fuel’s emissions will be zero (because they are short-cycle or biogenic carbon dioxide).

So I urge regulators and policy-makers; focus on the carbon intensity reduction targets, rather than volumetric blending targets.

Land resources

I don’t think we’re being imaginative or aggressive enough with tackling climate issues. Nor are we thinking about how to sync-up our efforts to grow our economies, improve lives together with environmental conservation efforts. There are plenty of false dichotomies that result from how we’ve developed our economies. It’s haunting us and discouraging us from thinking in worthy directions for problem-solving.

One example of a dichotomy that may turn out to be false in the long run is the issue of food versus fuel. The food shortage problems today is driven by logistics and localised disaster more than aggregate unavailability or insufficiency. If anything, instead of trying to outright ban dedicated energy crops or crop-based feedstocks for biofuel production, it would be wiser to encourage a programme of reducing desertification and farming of marginal land with resilient crops that can be used as feedstocks for biofuels.

Another involves questioning of thermodynamically-unappealing solutions. Direct air capture (DAC) requires that energy is so cheap that you should mechanically capture the carbon dioxide from the air with machines. And yes, it doesn’t take as much land per unit of carbon captured. It could even compete with vegetation/forests. One could consider through the lens of this competition with nature: Forests takes about 860 square km of land to absorb 1 million tonnes of carbon dioxide whereas if you were to build a DAC plant plus a solar farm powering it which can capture 1 million tonnes of carbon dioxide a year would only take about 30 square km, which is ~3.4% of the land area. [my calculations are back-of-envelope and derived from unit figures here and here].

Yes, but then what about the limited lifespan and all the value chain emissions from making solar panels and DAC systems? Indeed, those trade-offs are worth thinking about, which is why we probably won’t advocate replacing natural habitats and forests with DAC. A forest is more than just sequestering carbon, but also provides other ecosystem services such as enhancing biodiversity, increasing groundwater supply, and even helping to clean the water and reducing the risks of desertification.

At some level, biofuels compete with synthetic or e-fuels; and biomethane perhaps is imagined to compete with hydrogen. But all of these are false dichotomies. The world needs us to keep working on different solutions and coordinate our efforts to scale them where they make sense. One can be purist about different things and get nowhere. Let’s try to lay out the trade-offs and work through those in specific contexts rather than seek to rule out solutions on the whole.

When oil saved the environment

In Seth Godin’s new book, This is Strategy for, he had a chapter (the book has over 200 chapters, all of them short and highly readable) on killing whales.

He documented the rise of the whale-hunting industry in the 1800s where sperm whales were hunted down for their blubber. The activity was both dangerous and lucrative because a single sperm whale’s blubber could yield many barrels of lamp oil. The demand for lighting onshore and offshore fueled the whaling activity.

For a time to the mid 1850s, it seemed like they could just go on and hunt sperm whales to their extinction. Yet the earth today still has sperm whales. Thanks to the discover of petroleum and hence the advent of keroscene used in oil lamps. The cost of keroscene was much more competitive than lamp oil made from whale blubber and the petroleum industry was also costing less human lives.

Climate solutions that displace fossil fuels would need to achieve cost reductions to scale. But we could all inprove their chances by removing fossil fuel subsidies and pricing carbon. Of course, that will “hurt” the cost of living for many people. But if we think about it at system level, it is more about a sort of attachment to the current status quo of how we value different things, and refusing to change that.

I don’t think we could derive any sort of moral authority from the market to say we’re producing something that destroys our future because it is cheaper. We may not have a future to spend that surplus savings on. At the system level, we will have to help one another cope with changes.

Learning to struggle

If there’s one big thing we need in society that the education system is not properly teaching us, that is the need to struggle. There’s this sentiment in the education system that struggling suggests something is wrong, that is a state to transit away from, and to be avoided if possible. But what if struggling through difficulties, challenges is actually an important aspect of life? What if it takes struggling in order to truly learn something? Not just to acquire head knowledge but also to have a practical sense of how to use that knowledge?

How do we teach people to be resilient otherwise? How do we cultivate a generation of people who can actually deal with those problematic issues confronting mankind (eg. climate change, sharp inequalities, cracks in market capitalism, etc)?

Carbon pricing

I’ve written about carbon credits (here and here); but I never really quite considered them from the perspective of carbon tax, because I generally thought of it as just another instrument that is used to price carbon. In reality, the different mechanisms actually work differently. And even for ‘carbon markets’, where you allow trading (which can take the form of credits or allowances, again slightly different conceptually), the carbon price can take on different meanings depending on the underlying instrument in question.

Singapore’s carbon tax system introduced the idea of allowing carbon credits to ‘offset’ these taxes. And the carbon credits are essentially international carbon credits generated from projects that removes or mitigates emissions in one way or another. This is not new as some other markets have allowed the use of offsets to reduce ETS liabilities (eg. Korea). In Singapore, companies who wish to do so can only have 5% of their carbon tax exposure offset using eligible carbon credits; and there are clear specifications of what works and what doesn’t.

This marriage of carbon taxes and pricing with the generation of quality international carbon credits is something critical to bring the next step of carbon pricing to maturity. Global ‘carbon resources’ in the form of means of removal and sequestration is not uniform, even when we are all sharing the same atmosphere. It is therefore necessary to be able to trade carbon. Technically, because there is negligible transport cost when you ‘trade’ carbon, global pricing of carbon should eventually converge to the same levels. It is potentially as close as it gets to a good that can be pure commodity. Yet because of the whole issue around measurement integrity and the lack of consensus around some of the dodgier types of carbon credit methods, it is going to be very difficult for pricing to converge any time soon. The variations globally in regulating carbon emissions and putting a price on carbon emissions would also serve to slow down global carbon trade.

At the end of the day, there are wider geopolitical and economic considerations blocking stronger climate action. Working along these forces will be necessary since fighting them is rarely an option.

Gas Transition

Natural gas seem to be the fossil fuel which was supposed to be a transition fuel that overstayed its welcome. In fact, it seem to have failed at its job at properly displacing coal and yet today, it is seen as a dirty fuel to be transited away from rather than towards.

That is actually a very anglo-saxon view of the energy transition and if you go around Asia, to some of the fast growing economies you’d realise that notion is somewhat deluded. Natural gas is still growing and providing more energy to more businesses, households and people not because of the gas lobby or some kind of oil & gas conspiracy but that plans laid down in the past to move towards gas are just cranking on and moving forward. Sure, things are not moving as fast as we would like them to, but it is incredibly challenging to keep trying to drive people off gas towards renewable electricity when we have not properly dealt with or created a realistic pathway out of coal power.

A premature transition out of gas, especially for currently non-electrified uses, could be expensive. And electrifying heavy industrial loads when a power system is still dominated by coal, is certainly emissions-blind.

SAF and fuel mandates

I wrote about the trickiness of cutting subsidies which raises the cost to various groups in the society. This is effectively changing the underlying dynamics of wealth transfer in the society. Another thing that could alter the dynamics is putting some kind of regulation into the system. This tends to be less controversial when people are in agreement that the regulation is necessary. For example, getting companies to increase climate disclosure or just improve packaging labels etc would raise prices for customers as companies need to bear these costs in order to comply.

One could argue the consumers benefit from those regulations so it is fair for them to pay the price. What about when passing environmental regulations? Essentially when you first pass them, it creates benefits for parties going beyond the consumers themselves. Take the case of putting pollution control regulations on a manufacturing plant; eventually the consumers of the product of that plant is paying the cost but the ones who benefit from the regulation are the ones living near the manufacturing plant. That is when you evoke the ‘polluter pays’ principle because in this case, you are regulating away a ‘cost’ that existed in the system rather than creating a new benefit.

That brings us to the issue of climate change and greenhouse gas emissions. I work in the field of energy transition and this is intimate linked to those problems. For one, my day job is focused on solving these issues. What I’m wondering, as the CORSIA regulations kick in to push aviation industry to decarbonise, is whether national governments will choose to spend time going out to set up agreement to enable carbon credit trade which involves corresponding adjustments, or put in fuel blending mandates for Sustainable Aviation Fuel (SAF) which can play a role in airlines meeting CORSIA obligations.

Setting up fuel blending mandates will cost the airlines, who will then pass on the cost to the passengers. And perhaps that will reduce the tourism to the country, or perhaps it could increase the cost of doing business and hence make it less attractive for inbound investments. All of that factor causes it to be unclear who is paying the cost for the environmentalism and whether it ends up hurting the country more. Fuel blending mandate could nevertheless bring about new manufacturing jobs and opportunities that offset the job losses. And at the same time, you might attract relevant, future ready technologies to be based in your country.

Looking at the situation now, it is unlikely for SAF or other green fuels to get into the market through a supply push. The fact is that without a proper, transparent and accepted carbon price, there is no incentive to use a greener fuel that would cost more expensive. And this are green fuel that still ends up emitting carbon dioxide albeit in the short-cycle and hence considered to have zero greenhouse warming potential. Government should take the stance that they will have to mandate the blending and then manage the impact of the costs later. In this case, the ‘polluter pays’ principle could be evoked as a foundation but then various other instruments and tools can be used to cushion the impact for various groups to continue achieving economic objectives.

Energy subsidies

I don’t really remember the last time I dealt with the topic of subsidies. There are huge transfers that takes place in the economy as a result of government interventions through a combination of taxes and subsidies. It is hard to see what the real effects are because the result is always nett of a combination of different forces and programmes. As a result, it is hard to see whether the end result was intentional or not. Often, the end result can be intentional but brought about through a combination of transfers or policies with differing stated intents.

Take for example the whole issue of fuel and energy subsidies. There are explicit and implicit subsidies and they are applied at different levels, to different parts of the value chain, captured by different parties. Of course, the result is to some extent lower cost of energy, but it is also more energy used than otherwise would be. Well, why would you favour wasting energy? Often, it’s because it can help to divert perhaps certain industrial activities that could have downstream impacts such as helping to alleviate poverty, create employment, strengthen social cohesiveness and the list goes on.

After a while, you realised that in the sphere of politics and governance, economics only holds to a certain extent. And competition often can be defined within a single dimension but actually practised over that. What this means is that if you think you’re working hard for school grades, you’d be outcompeted by someone who recognizes that his grades mean little if it is not directed towards getting to a good school or a good job. There is always a greater arena that you are actually competing within.

What this means for renewable energy is that they are not just competing with fossil fuel in terms of adoption and capital for deployment but also consumption and subsidies. Of course there is lots of subsidies going around – for example, for hydrogen. The question is whether it is worthwhile pouring subsidy into that or a more mature energy vector that has the potential to decarbonise (for example, biomethane). However, there are limitations to biomethane or bioenergy because of feedstock limitations, because of the dispersed nature of the feedstock, and the difficulties associated with deployment.

Well, there are also budget limits and land limits. It is strange how people prefer to invest in areas that have more unknowns and uncertainties rather than areas where limits are more ‘known’, but the market could still be sizable. In Australia especially, I think there is incredible upside to taking the long-term view in things because it is a market where sensibilities do tend to eventually prevail.

Originally the intent was to rant about fossil energy subsidies but look where that got me.

Single pivot point

To make a change, we need a single pivot point each time. The pivot point is where things are fixed in place and do not change, and all the other changes hinge on it. And then when we make the next change, we can have another pivot point. But with any one change, we need to select a point of invariance to ensure some kind of order for the change.

In our climate transition today, too many people are trying to change things without a pivot point, thinking that the whole world has to transform. Determining what can be kept constant first is probably a good way to use consensus to drive actions. Then you’ll begin to realise what you are trying to keep the same can have far reaching consequences. For example, if you want to keep energy demand constant and start switching out existing demand into renewables, then you’re making it difficult for economic activities to expand. If you want to keep energy cost constant, then you risk keeping things to status quo and banishing adoption of costlier but greener technologies.

Laying out the trade-offs matter but one can consider how we fix certain parameters and move others first before coming back to revisit these. Take energy costs for example; given the cost of living issues and challenges, governments might want to focus on expanding proven, existing low cost green energy sources and pushing through all manner of regulations, and coordination necessary. Capture of landfill gas to be upgraded into biomethane and upgrading the biogas produced in wastewater treatment plants are low-cost sources of renewable gas that can be plugged into the existing system to displace fossil fuels. Malabar’s biomethane injection plant has just received the Greenpower certification and is the first biomethane plant in Australia to do so, ushering in what we hope to see as an era of using market mechanisms to drive renewable gas and fuel growth as it had done so for renewable electricity in the past decade in Australia.

Some may argue that prolongs the life of fossil infrastructure but we are calling them fossil infrastructure only because they are majority driven by fossil fuels as a result of legacy. One day, those infrastructure could be 100% driving renewable fuels.