By Paul Callister, Don’t Burn Our Future, 24 June 2023
The Climate Change Commission is calling for evidence as to whether emissions from international shipping and aviation should be included in the emissions reduction target (‘the 2050 target’). Given the need to dramatically and rapidly reduce all GHG emissions, it is vital all sectors must be accounted for. If a sector underperforms in this regard, it needs to be compensated for by deeper cuts in other sectors. Yet, we also recognise that both shipping and aviation are especially important to Aotearoa New Zealand given our geographic isolation.
Don’t Burn Our Future is a group of New Zealanders who came together to oppose the proposed biofuels obligation which the government planned to use to put biofuels in cars, trucks, trains and ships in Aotearoa New Zealand. In that campaign we made the following arguments:
- Similar biofuel directives around the world have caused massive net increases in greenhouse gas (GHG) emissions compared to using regular fuel,
- Growing the feedstocks for biofuel drives tropical deforestation, destroying biodiversity, depriving indigenous people of their land and livelihoods and increases net emissions.
- It drives up food prices, as biofuels are derived from food crops. Food price increases cause material hardship for the most vulnerable people around the world.
- Non-food ‘second generation’ biofuels, or those derived from waste are not available in the necessary volumes, or at all.
- Electrifying ground transport rather than using biofuels, or equally problematic hydrogen, is by far the best policy for energy use, emissions and for the wider environment.
The government dropped their planned obligation in February 2023, citing the rising cost of living.
While both shipping and aviation are important, aviation is seen as especially difficult to decarbonise. It is especially hard given planned growth. Judging by proposed airport expansions, Aotearoa New Zealand is on the verge of a major expansion of the industry.
Pre-Covid, total domestic and international aviation emissions were estimated to make up 12% of total CO2 emissions. Until Covid, growth of international emissions had been growing especially fast. And it seems international flights are now ramping up quickly again.
Traditionally, one way of reducing aviation emissions has been through efficiency gains such as improved engines, better aircraft design and better air traffic control. We expect these small gains to continue. But these depend heavily on rapid renewal of the fleet and, more importantly, have historically been swamped by growth in miles flown.
Batteries will not take planes on long flights across the oceans surrounding Aotearoa New Zealand any time soon. There are therefore only four ways of reducing emissions from international aviation in the short to medium term:
- Ongoing efficiency gains in areas such as air traffic control.
- Using biofuels either as a drop in or fully powering planes.
- Using Power to Fuel (PtF) either as a drop in or fully powering planes.
- Putting in place demand management strategies.
Biofuels feature strongly in decarbonisation announcements from the aviation industry. “Sustainable” Aviation Fuel (SAF) biofuels are made from the same set of feedstocks used for biodiesel. Therefore, for the same set of reasons we opposed the NZ and EU biofuel mandates for land transport, we oppose using first generation biofuels to power aircraft. The problems of creating enough biofuel from food crops are well set out in a range of reports. A recent one asks “Do we have enough crops? Yes — but mostly no.”
We do, however, support further research into second generation biofuels, particularly forestry-based fuels. We note the recent announcement by Air New Zealand/the government to fund research into this source of SAF. However, our research strongly suggests that such fuels are still many years away from being viable on a large scale and without increased net emissions, if ever. In a Listener article in 2023, Scion noted that domestic SAF from wood, “will take at least 7 years to get going.” There are many technical challenges to overcome in producing fuel from trees and local and international research is still in its infancy.
Furthermore, a conventional oil refinery is required to process forestry based biocrude into SAF, which New Zealand no longer has.
As was well established during the land transport biofuels discussions, New Zealand will need to import any SAFs.
For the foreseeable future SAFs will be expensive and the available supply of used cooking oil (UCO) and non-food biomass feedstocks will be less than just the European Union (EU) mandated volumes. New Zealand will compete with the EU and many other countries others inevitably resulting in fraudulent fuels, a problem the EU acknowledges exists now. There is a court case pending in New Zealand where biofuel feedstocks may have been deliberately mislabeled.
Palm oil and all its by-products are banned by the EU as contributing to deforestation, species decline and dramatically increasing greenhouse emissions. Approximately 5% of raw palm oil is a soapy byproduct called PFAD (Palm oil Fatty Acid Distillate) which has a number of industrial uses and usually commands a higher price than palm oil itself. In 2009 Finland reclassified PFAD as a waste product, allowing it to be used as a feedstock for biofuels. The Finnish National oil company Neste, which until then had been running conventional fossil fuel oil refineries, seized the marketing opportunity to process PAFD into Jet Fuel, which they have since marketed as Sustainable Aviation Fuel (SAF).
PFAD does not meet any reasonable definition of “waste”, so the PFAD based SAF Neste promotes in fact has the same disastrous environmental consequences the EU is trying to avoid with all non-waste-based biofuels. For this reason, Neste is opposed by European and international environmental groups such as Greenpeace and Friends of the Earth. Neste’s PFAD absolutely should not be accepted in New Zealand.
In the short to medium term, the only way to reduce New Zealand’s aviation emissions is to reduce the amount of flying. This could be achieved in a number of ways, including a moratorium on airport expansions, applying GST to international aviation as well as applying carbon taxes to international aviation.
A copy of our full submission is here. Submissions can be made up to 31 July 2023.