Summary of Responses to the Consultation on the draft Renewable Transport Fuel Obligations Order
Table of contents
- 1. Introduction
- 2. Public Response
- 3. Summary of Responses to Part 1 of the Consultation
- Q1: Is the definition of an obligated supplier appropriate? Are the compliance costs estimated in the attached partial Regulatory Impact Assessment broadly accurate?
- Q2: Is 450,000 litres an appropriate minimum threshold?
- Q3: Is it appropriate to calculate the level of obligation as a percentage of obligated suppliers’ fossil fuel sales in this way, despite the fact that this will make it a more stretching target?
- Q4: Will stretching the target [to 5% of total fuel sales] provide increased liquidity in the market for RTF certificates?
- Q5: Is it appropriate to exclude sales of road fuel gases from the calculation of suppliers’ obligations?
- Q6: Should the RTFO have an end date defined in the RTFO order, and if so what should it be?
- Q7: Does the suggested approach to eligible fuels provide a proper framework for identifying those fuels which should count as renewable fuels for the purposes of the RTFO?
- Q8: In advance of internationally agreed standards, is there more that can be done to help ensure that biofuels are sustainably sourced, for example through voluntary standards or agreements?
- Q9: Would obligated suppliers or others wishing to acquire certificates consider [the checks and balances described] to be sufficient to protect against any possible fraudulent claims of RTF certificates from the RTFO Administrator?
- Q10: Are the proposed arrangements for the recycling of the buy-out fund appropriate?
- Q11: What are likely to be the impacts of the RTFO on micro-scale biofuel producers, and how might adverse impacts be mitigated?
- Q12: Are the proposed arrangements for civil penalties and for revocations appropriate?
- 4. Wider Comments on Part 1
- 5. Summary of Responses to Part 2 of the Consultation
- Q13: Should the Government specify that, from a given date, credits under the RTFO should be linked to the GHG-saving of the fuel? If so, what arrangements should operate and how quickly should this requirement be introduced?
- Q14: Should the Government specify that, from a given date, only those biofuels meeting certain minimum environmental and social standards should qualify for credits under the RTFO? If so, what standards should be applied, and from what date?
- Q15: Is the Government right to await the review of the relevant fuel quality standards before setting targets higher than 5%?
- Q16: To what extent should Government support for biofuels be constrained by the impact on fuel prices at the pump?
- Q17: Will the RTFO have an adverse impact on other sectors? To what extent should this constrain future Government support for biofuels?
- Q18: Do you consider the above analysis of the options [for setting future RTFO targets] correct? Are there any other options that the Government should consider?
- Q19: What are your views on the relative merits of the different ways in which future RTFO levels might be expressed?
- Q20: Is the Government right to insist that robust carbon-saving and sustainability criteria are built into future EU-wide biofuel targets and support mechanisms?
- Q21: What should the level of the RTFO target be in future years (e.g. 2015 and 2020)? Should the level of ambition be maintained at the 2010/11 level, or increased?
- Q22: When should the Government set targets for years beyond 2010/11?
- Q23: Is our approach to setting the level of the buy-out price a reasonable one? Does the 30 pence per litre “package” strike the right balance between encouraging the use of renewable transport fuels and protecting consumers? For how many years into the future should it be guaranteed?
- Q24: Will rewarding different biofuels on the basis of their relative carbon saving performance be sufficient to bring these fuels onto the market? If not, in what other ways might the Government support the development and use of “advanced” renewable transport fuels?
- Q25: Should the Government consider providing additional support to encourage the use of high blend biofuels?
- Annex A: Organisations That Responded To The Consultation
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