Public consultation on carbon and sustainability reporting under the RTFO

RTFO Stakeholders

Malcolm Fendick
Head of Cleaner Fuels and Vehicles Division
Department for Transport
Great Minster House
76 Marsham Street
London
Direct Line: 020 7944 2450

Web Site: http://www.dft.gov.uk/roads/rtfo

21st June 2007

 

Dear Stakeholder,

Public consultation on carbon and sustainability reporting under the renewable transport fuel obligation (RTFO)

As you will be aware the RTFO is due to start in April 2008.  The Government is committed to encouraging biofuels that deliver real carbon savings and do not cause environmental damage.  The Government believes this can be achieved by requiring transport fuel suppliers to report on the carbon saving and sustainability of the biofuels for which certificates are issued under the RTFO.  Douglas Alexander MP has today launched a public consultation on a draft Recommendation to the RTFO Administrator on how carbon and sustainability reporting should operate under the RTFO. Copies of the consultation are available at http://www.dft.gov.uk/roads/rtfo.

This consultation is the output of several months work by the department, the Low Carbon Vehicle Partnership, external consultants in consultation with industry and NGO stakeholders. It sets out the proposed methodology that transport fuel suppliers will have to follow to receive certificates under the RTFO and provides guidance on how they can report against this methodology.  Further it provides default carbon saving values for the majority of fuel chains that will exist for the UK market.  As such, this consultation is technical in nature and primarily aimed at the industry and other parties directly affected by the RTFO although any other interested parties are welcome to respond.

Whilst we would appreciate general comments on the proposed methodology and other requirements, we would particularly welcome comments on the questions listed overleaf.

To respond, please send comments by the 13th September 2007. For further information contact Rupert Furness on 020 7944 4899 or Rupert.furness@dft.gsi.gov.uk

The Government has today also announced a package of measures to ensure the sustainability of the biofuels supplied under the RTFO.  Details of this package are available in the press release available today via the DfT website.  In particular the Government has announced that it:

• aims to reward biofuels under the RTFO in accordance with the carbon savings that they offer from April 2010, provided that this is compatible with World Trade Organisation rules and EU Technical Standards requirements, and is consistent with the policy framework being developed by the European Commission as part of the review of the Biofuels Directive, and subject to consultation on its environmental and economic impacts
• aims to reward biofuels under the RTFO only if the feedstocks from which they are produced meet appropriate sustainability standards from April 2011, subject to the same provisos and consultation as above and subject to the development of such standards for the relevant feedstocks.
• will continue to work closely with out partners at a national, European and international level to develop robust standards for ensuring the sustainability of biofuels and to ensure that early consideration is given to the WTO implications of the UK’s policy intentions.
• will ask the RTFO Administrator to report to the Secretary of State every three months on the effectiveness of the RTFO's environmental reporting mechanisms, and on the carbon and sustainability effects of the RTFO.  The Government will keep the RTFO under review in the light of these reports.
• intends to set stretching indicative targets for the level of carbon and sustainability performance expected from all transport fuel suppliers claiming certificates for biofuels in the early years of the RTFO.  These targets, which are included in the consultation paper we are publishing today, cover:
  • the level of greenhouse gas savings that we expect to see from the biofuels used to meet the RTFO;
  • the proportion of those biofuels that we expect to come from feedstocks grown to recognised sustainability standards; and
  • the amount of specific information that we expect to be included in sustainability reports.
• has asked the Low Carbon Vehicle Partnership (LowCVP) to explore the feasibility of a voluntary labelling scheme to allow responsible retailers to show that their biofuels are genuinely sustainable.  Any scheme would need to be compatible with WTO rules.

Yours sincerely,

Malcolm Fendick

Questions

Is the general scope of the reporting requirement set out in chapter 2 appropriate?

Is the meta standard approach suggested in chapter 3 appropriate?

Are the Environmental and Social principles set out in chapter 3 the right ones?

Do the proposals for the content of monthly reports set out in chapter 3 provide enough detail - is there other information we should require?

Is there other information that should be required in the annual reporting requirements set out in chapter 4?

Are the targets for reporting in chapter 4 appropriate - should they be higher / lower?

Is our approach to the chain of custody set out in chapter 5 a sensible one?

Are we right not to allow C & S information to be transferred in an equivalence trade - chapter 5?

Is our approach to verification set out in chapter 6 appropriate?

Are there any other standards that should be benchmarked from the outset - Annex A?

Is excluding by product reporting as suggested in Annex A appropriate? - Are the by-products suggested in Annex A the right ones?

Is the exemption for mechanised farming suggested in Annex A appropriate?

Are the carbon intensity default values set out in Annex F correct?

Is the approach to assessing the impact of land use change set out in Annex G appropriate?

Are the costs of complying with the guidance as set out in the Partial Regulatory Impact Assessment for the draft Renewable Transport Fuel Obligations Order 2007 broadly correct?