Aviation biofuels:How ICAO and industry plans for

'sustainable alternative aviation fuels'could lead to planes flying on palm oil

A report by BiofuelwatchOctober 2017

Report by Almuth ErnstingEdited by Rachel SmolkerDesign by Frances Howe

Produced with support from Heinrich Böll Foundatation

Published 6th October 201 7biofuelwatch.org.uk

biofuelwatch@gmail .com

Contents

1 . How do biofuels fit in with the aviation industry’s and ICAO’s growthstrategy?

2. Aviation biofuel: The state of play

3. Unlikely contenders: Aviation biofuels made from anything other thanvegetable oils and animals fats

4. Palm oil for planes – by far the most credible feedstock for aviationbiofuels

5. Why sustainabil ity and greenhouse gas standards for aviation biofuelsare not the answer

6. The dangers of hype about palm oil for planes

7. Conclusions

8. References

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1. How do biofuels fit in with the aviationindustry’s and ICAO’s growth strategy?

Greenhouse gas emissions from aviation arerising faster than those from almost any othersector. Between 1 990 and 201 4, emissionsfrom international aviation alone grew by87%1 . Growth in aviation emissions isincompatible with the goal of the UN ParisAgreement to keep global warming to within1 .5oC. Under the Kyoto Protocol, internationalaviation has been exempt from any curbs onits emissions. In the context of the ParisAgreement, the industry can no longer rely onsuch a blank cheque for aviation emissions infuture. At the same time, it wants to maintainits present high rates of growth to protectshareholder profits.

The aviation industry association IATA(International Air Transport Association)predicts that the number of air passengers wil ldouble over the next 20 years2. In addition,global air freight is rising at a rate of around4.3% a year3. There are no technical means ofal lowing air travel to expand at such a ratewithout CO2 emissions

4 also growing steeply.No alternatives to l iquid fuels exist in aviation:

passenger planes cannot fly with electricity,and hydrogen-fuel led planes are nowhereclose to being approved, due to technical andsafety problems5.

Aircraft efficiency has been improving at a rateof just 1 .1 % a year6, less than that of mostother industries. Airl ines have adoptedvoluntary efficiency goals7 and theInternational Civi l Aviation Organisation, ICAO,has adopted an efficiency “CO2 standard”

8.But even if those are implemented, efficiencygains wil l sti l l lag far behind the industry’sgrowth rate. Environmental NGOs haveargued that far more could be done to improvefuel efficiency of aircraft. According to theInternational Council on Clean Transportation,fuel consumption of new planes could be cutby 40% by 20349. Yet, even that would benowhere close to cancell ing out the increasein emissions from doubling air traffic over 20years.

In order to avoid growth-curbing regulations,the aviation industry has adopted the concept

transportenvironment.org/sites/te/fi les/publications/201 7_02_briefing_aviation_decarbonisation.pdf

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of “carbon neutral growth”. In 201 6, ICAO,which is a special ised UN agency which worksvery closely with the industry, endorsed a planfor “carbon neutral growth” from 2020 and fora reduction in ”net carbon emissions” by 2050,of 50% compared to a 2005 baseline. ICAOplans to meet those goals primari ly through acombination of carbon offsetting and biofuels.ICAO’s carbon offsetting scheme has alreadybeen denounced by more than 1 00 civi lsociety organisations1 0.

Ahead of its High-Level Conference onAlternative Aviation Fuels in Mexico City from11 th to 1 3th October, the ICAO Secretariathas published a proposal for very large-scalebiofuel use11 . The proposal would involve:

The Secretariat proposes call ing on memberstates to work with industry and to “set policiesthat strongly incentivise SAF [SustainableAviation Fuel] production”.

2. Aviation biofuels: The state of playOn 24th February 2008, Richard Branson wasfi lmed playing with a coconut next to a VirginAtlantic plane at Heathrow Airport as heannounced the world’s first commercial fl ightwith biofuels. This fl ight, he proclaimed, was “avital breakthrough” which “wil l enable those ofus who are serious about reducing our carbonemissions to go on developing the fuels of thefuture”. Virgin’s ‘biofuel ’ fl ight was widelydenounced and ridiculed as a mere publicitystunt1 2. In fact, it was neither the world’s firstbiofuel fl ight, nor a commercial one1 3, and itused a mere 5% biofuels mixed with fossilfuels.

I ronical ly, Virgin Group has never since usedbiofuels on any fl ight, although it continues toinvest in their research and development1 4. Yetgrowing numbers of other airl ines have usedbiofuel blends on thousands of passengerfl ights since 2011 , when such fuel blends werefirst cleared for commercial use1 5.

Nonetheless, overal l biofuel use in aviationremains minimal. According to Bloomberg NewEnergy Finance, existing refineries couldproduce as many as 1 00 mil l ion gallons ofbiofuels for aircraft – a fraction of the current83 bil l ion gallons per year of petroleum basedtotal aviation fuels in use today.

That 1 00 mil l ion gallons estimate far exceedswhat is being produced so far: there is just onecommercial-scale refinery in the world which

regularly produces small amounts of suchbiofuels, while focussing primari ly on biofuelsfor road transport.

What types of biofuels can be used inplanes?

Ethanol (made from starch or sugar crops)and biodiesel (made from vegetable oils andanimal fats) account for 95% of all biofuelsproduced worldwide1 6, but they cannot beused in aircraft. For safety reasons, any fuelused in aircraft has to meet jet fuelspecifications, which include high energydensity, low freezing point, and a specifictemperature at which fuels ignite or explode.Any new type of aviation fuel must beapproved by the international standardsorganisation ASTM. So far, five types ofbiofuels produced through four differentmethods have been approved for use inpassenger fl ights1 7. The four methodsproduce:

5 mil l ion tonnes of biofuels a year used byplanes by 2025, which is 2% of projectedaviation fuel use;

1 28 mil l ion tonnes a year used by 2040,which is 32% of projected aviation fuel;

285 mil l ion tonnes a year used by 2050,which is 50% of projected aviation.

1 ) A fuel made by putting plant oi ls oranimal fats through processes commonlyused in oil refining, including hydrotreating(which involves the use of hydrogen).Biofuels produced using this method arecalled Hydrotreated Vegetable Oil (HVO).A particular type of HVO, called HEFA, isneeded for aircraft1 8, produced undersl ightly different refining conditions thanHVO diesel, which is used in road

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Other methods for making aviation biofuelshave been proposed, but not yet approved.This includes an application to al low the useof 1 5% blends of Hydrotreated Vegetable Oil(HVO) diesel, currently produced for road andrail transport. I f approved by the ASTM, thiswould al low for far cheaper production ofbiofuels for aviation, as discussed in Chapter5.

In short, four very different methods formaking aviation biofuels have so far beenapproved. Between them, they could convertsugars and starch, sol id biomass such as

wood, switchgrass or straw, vegetable oils andanimal fats into biofuels suitable for planes.Furthermore, a US company, FulcrumBioEnergy, has announced plans for aFischer-Tropsch plant using Municipal SolidWaste which, though not a biofuel, would sti l lbe classed by ICAO and airl ines as a“sustainable alternative aviation fuel”23.

The fact that a particular aviation biofuel hasbeen approved and that companies haveproduced small quantities, does not prove thatit can be produced in commercial quantities –something Amyris has already conceded inthe case of its aviation biofuel based onfarnesene.

As il lustrated in Chapter 3, three of the fourapproved aviation biofuels do not appear to betechnical ly and economical ly viable based oncurrent knowledge and technologydevelopment.

On the other hand, HVO fuels – andspecifical ly HVO diesel – are already beingproduced on a significant and fast-growingscale. I f, as is widely expected, HVO dieselblends are permitted for aircraft, aviationbiofuel costs wil l fal l dramatical ly and may wellbecome affordable with l imited subsidies. Thiswould create a new market for vegetable oils,l ikely palm oil , as discussed in Chapter 4.

How much aviation biofuel is beingproduced so far?

The only refinery which regularly producesaviation biofuel is AltAir’s HVO refinery inParamount, California. Most of AltAir’s sharesare owned by the US oil company Alon. AltAirsold 1 .1 mil l ion gallons (just under 45,000tonnes) of biofuels for aircraft in 201 624. Jetbiofuels accounted for just 6.6% of itsproduction in 201 625. Most of its sales andprofits come from HVO diesel for roadtransport i .e. a biofuel with the sameproperties as conventional diesel for cars.

Otherwise, aviation biofuels have only beenproduced in small quantities and mostly insmall pi lot plants, general ly as part ofgovernment-funded research anddevelopment projects, such as the EU’s I takaprogramme, or the Defense AdvancedResearch Projects Agency’s (DARPA)BioFuels Program.

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transport. HVO is made in oil refineries –either on its own, in a converted refinery,or through co-production together withpetroleum in a conventional refinery. Theworld’s leading HVO producer is theFinnish oil company Neste, but severalother companies have invested in thetechnology (see Chapter 5);

2) A fuel made by fermenting sugars tofarnesene, which is a hydrocarbon thatcan be converted to jet fuel. Hydrocarbonsare chemical compounds that contain onlyhydrogen and carbon atoms. This processwas developed by a synthetic biologycompany, Amyris1 9, which has sinceadmitted that “sales of our fuels productshave not been cost-effective given thecurrent costs of producing farnesene andcurrent market prices for petroleum fuels”.Amyris now sells beauty productsinstead20;

3) A fuel made by gasifying solid biomasssuch as wood and then converting it tohydrocarbon fuels using a technologycalled Fischer-Tropsch reforming, after itsinventors. The process is discussed inmore detai l below. Two different types ofaviation biofuels made throughgasification and Fischer-Tropschreforming have been approved. Fischer-Tropsch reforming has been in theresearch and development stages sincethe 1 920s21 ;

4) A fuel made by fermenting sugars to anorganic compound called isobutanol,which is then upgraded to hydrocarbonscontained in jet fuel22. The companybehind this technology is Gevo.

3. Unlikely contenders: Aviation biofuels made fromanything other than vegetable oils and animals fats

Airl ines have signed 1 2 sourcing agreementswith a total of 8 biofuel companies26. Thoseinclude AltAir Fuels (see above) and Neste,who produce 60% of the world’s HVO, albeitnot routinely for aviation so far. A thirdcompany, SG Preston, has agreed to supplyHVO biofuels to Jet Blue – but seems to benowhere close to building or converting arefinery.

This leaves five companies promising toproduce substantial amounts of biofuels foraircraft using a technology other than HVO.How credible are those promises?

Fulcrum Bioenergy: Turning waste intofuels for planes?

At an ICAO Seminar about aviation biofuels inFebruary 201 727, Fulcrum BioEnergy gave avery upbeat presentation to delegates:Fulcrum had developed a “proven” technologyto turn Municipal Solid Waste into aircraft fuel,which guaranteed “low-cost production” withan “attractive environmental and sustainabil ityprofi le”. Municipal sol id waste is certainlymuch cheaper than vegetable oils – andcompared to palm oil , it would be a far lesscontroversial feedstock. But by any definition,Fulcrum BioEnergy’s technology is neither“proven” nor “low cost”.

Fulcrum BioEnergy, founded in 2007, spent itsfirst 6-7 years struggl ing to interest any privateinvestors in its plans, and it had to abandon anattempt to float the company on the stockexchange in 201 228. In 201 4, the company’sfortunes changed: it was awarded a $70mgrant under the US government’s DefenseProcurement Act to build a first commercial-scale refinery in Nevada29. On top of this, theUS Department of Agriculture awarded it a$1 05 mil l ion public loan guarantee. That sameyear, Cathay Pacific Airways decided to investin the company and to enter into a supplyagreement for 1 0 mil l ion gallons a year over adecade30. Commercial production was to startin 201 6/1 731 . Since then, Fulcrum has alsosigned an investment and supply agreementwith BP and a supply agreement with UnitedAirl ines32, and it has partnered with the oil

company Andeavor (formerly Tesoro). Yet sofar, Fulcrum Bioenergy has not evenannounced a start date for construction. I tclaims to have “proven” its technology in ademonstration plant in North Carolina. This isa small pi lot plant on the premises of theSouthern Research Institute, which has beenused to test biomass and waste gasificationand reforming to l iquid biofuels. In the sameyear that the US government promisedFulcrum up to $1 75m in subsidies, SouthernResearch Institute was advising theDepartment of Energy that tests at the plantshowed that “large scale systems havesignificant technical, logistics, and economicchallenges”33.

Fulcrum’s technology involves three differentprocesses, and there is no evidence that eitherof the first two has ever worked with mixedwaste: the first is gasification, which involvesexposing fuel to high temperatures withcontrol led oxygen in order to produce syngas.The syngas is then cooled down and cleanedunti l i t contains only carbon monoxide andhydrogen. Syngas can then be burned togenerate heat and/or electricity or, in theory atleast, it can be converted to l iquid fuels.Gasification is highly challenging even for“clean” virgin wood. There is no rel iableevidence of any successful gasification plantsanywhere in the world that use mixed waste34.The second stage, Fischer-Tropsch reforming,involves a series of catalytic reactions duringwhich the syngas is transformed into l iquidhydrocarbons. During the final stage, thehydrocarbons would be separated intodifferent useful hydrocarbon products, using aprocess widely used in oil refineries. Fischer-Tropsch reforming syngas to l iquid fuels hasnever been successful ly achieved at scale withany feedstock other than coal or natural gas,as wil l be discussed below in relation to aproposal by Red Rock Biofuels. Two of thethree technologies in Fulcrum’s process arethus entirely unproven. There seems to belittle to distinguish Fulcrum’s promises fromones made by the now bankrupt aviationbiofuels company Solena35.

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Solena Fuels

For several years, US company Solena Fuels captured headlines around the world about itsaviation fuels-from-waste plans. In 201 0, Solena entered into a partnership with BritishAirways to build a large refinery in the south-east of England. I t teamed up with Quantas tobuild a similar plant in Sydney, and negotiated with Easy Jet, Ryanair and Aer Lingus aboutbuilding one in Dublin, and with city authorities in Chennai India, about yet another suchplant.

Like Fulcrum BioEnergy, Solena Fuels wanted to combine waste gasification with Fischer-Tropsch reforming. Neither Solena nor any of its partner companies had ever proven such atechnology at any scale – not even in a small pi lot plant. In October 201 5, Solena Fuels fi ledfor bankruptcy in Maryland, without ever having built or produced anything.

Remarkably, British Airways has just announced a new “partnership” with Solena’s supposedtechnology supplier Velocys (discussed in the section about Red Rock Biofuels), for whatseems to be exactly the same proposal.

Red Rock Biofuels: Turning trees intobiofuels for planes?

Red Rock Biofuels (RRB) also procured a$70m grant under the US DefenseProcurement Act. Furthermore, it obtained a$4.1 m Department of Defense grant and$2.1 m in tax credits from the OregonDepartment of Energy. I t has signed supplyagreements with Southwest Airl ines, andFedEx.

The technology RRB wants to use is verysimilar to Fulcrum BioEnergy’s, except that itwould use trees rather than waste as afeedstock. RRB has never built any type ofplant, however small . The gasifier that thedevelopers say they wil l use is to be suppliedby a company called TCG, who received a$20 mil l ion grant from the US Department ofEnergy for a demonstration gasifier. TCG’sfinal project report, in 201 0, showed thatproblems initial ly prevented any syngas frombeing collected whatsoever. After the plantwas taken down and reassembled, TCGmanaged to produce some syngas, but it wastoo contaminated to be converted to biofuels.Eventual ly, after major investments, TCGsucceeded in obtaining clean syngas for atotal of four days36. According to publiclyavailable evidence, this appears to be the totalof RRB’s gasification technology supplier’sexperience with the technology, and the basisfor the company’s claim that it can gasify1 75,000 tonne of wood a year. The Fischer-Tropsch technology is to be supplied byVelocys, one of the companies involved in the

failed Solena venture. Velocys’s experiencewith biomass Fischer-Tropsch reformingseems to also be limited to some test runs atthe same Southern Research Institute plantpreviously used by Fulcrum – the one whoseresearchers concluded in 201 4 that thetechnology does not so far work at scale.

RRB sti l l needs more funding before it canstart building its refinery, and there are seriousconcerns about the location of the plant, notleast because the vil lage where it is to be builtsuffers from pollution levels so high thatresidents have been fined for using woodstoves37.

I t seems highly unl ikely that RRB's orFulcrum’s plans can possibly succeed. Therehave been other more credible efforts todevelop biomass gasification and Fischer-Tropsch refining, projects that involved yearsof research and development. The companywhich got furthest with the technology wasChoren Tech GmBH. Choren first trial led thetechnology to produce diesel from wood in apilot plant, which opened in 1 998. In 2003,Choren then embarked on scaling up the pilotplant and attracted investment from Shell ,Daimler and Volkswagen. I t succeeded inproducing small amounts of Fischer-Tropschbiofuels over a total period of thousands ofhours, albeit with many shutdowns, repairsand modifications along the way. After years ofsuch experimental production, Chorenremained unable to achieve commercial-scaleproduction, causing investors to pull out38.Choren fi led for bankruptcy in 2011 and its

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technology has been sold to Linde, which nowpromotes its use to turn coal into l iquid fuels.

In Europe, just one biomass Fischer-Tropschproject is now underway, supported by €33.2mil l ion in subsidies. Unlike RRB, its operatorshave not promised that they wil l produce anyfuel, let alone 1 9 mil l ion gallons a year – allthey have committed to are four years ofresearch fol lowed by a “validation” reportabout the feasibi l ity of the technology39.

In the US, Fischer-Tropsch fuel research hasbeen largely driven by the mil itary. During the2000s, when oil prices and energy securityconcerns were high, the US Air Force set itselfa goal of using 50% Fischer-Tropsch “synfuel”by 201 640. The Air Force was most interestedin coal-to-l iquids synfuels, a far more maturetechnology. US legislation, passed in 2007,prevented any government agency, includingthe Air Force, from buying fuels with higheremissions than petroleum. The governmenttherefore funded research into co-gasifyingbiomass with coal to produce liquid fuels, onthe basis that biomass is classified as “zerocarbon” (contrary to scientific evidence).Those efforts, too, proved futi le and the AirForce’s synfuel goal has been quietlyabandoned. The Department of Energy’sFischer-Tropsch research programme nowfocuses entirely on coal and natural gas-to-l iquids41 , a development that precedes theTrump administration.

Technical problems with biomass Fischer-Tropsch technology include:

Challenges posed by biomassgasification: Although some biomassgasifiers which use homogenous

feedstock have been made to work, this isnot an off-the-shelf technology.Successful gasifiers are general ly oneswhich operators have spent yearsadjusting and repairing, while the vastmajority of biomass gasification projectsworldwide fail . Problems includeexplosions, tars clogging up theequipment, chemicals in the gas causingcorrosion, and problems with gaspurification. Solving those problems canpush up operating costs and reduceenergy gains42;

Coal-to-l iquids technology has beendeveloped over many decades, butbiomass has very different chemicalproperties from coal – and there aresignificant differences in the properties ofdifferent types of biomass, so coal cannotjust be replaced with biomass. Eachfeedstock requires specific catalysts andtechnology adjustments. The US alonespent $3.6 bil l ion on coal Fischer Tropschconversion research & development43.The South African Apartheid regimeheavily subsidised coal-to-l iquidstechnology and the company they had setup in 1 950 to deploy the technology,Sasol. In 2005, Sasol stated that itsupplied 28% of South Africa’s l iquid fuelsfrom coal44. Yet even coal-to-l iquidstechnology remains expensive andcannot compete with petroleum withouthigh subsidies to cover the capital costs.

The development of biomass Fischer-Tropschtechnology thus lags decades and manybil l ions of dol lars behind that of coal Fischer-Tropsch fuels, which have only been viablewith a combination of generous subsidies andlow coal prices. Any technical breakthroughwould l ikely apply to one single type ofbiomass given the varying characteristics ofdifferent feedstocks. There is l ittle genuineresearch and development into biomassFischer-Tropsch at present and it seemshighly unl ikely that such fuels wil l be availablefor airl ines in the next few decades.

Planes flying with fuels made from sugar?

Two technologies for turning sugar intoaviation fuel have been developed, one byAmyris, the other by Gevo. Both are biotechcompanies using synthetic biology, i .e.

Choren’s biomass-to-l iquids demonstration plant in

Freiberg, Germany, 201 1 . Photo: Choren/Detlev Mul ler

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extreme geoengineering, to genetical ly modifymicroorganisms.

Amyris, as mentioned above, has given up ontrying to produce biofuels. I t had been sell ingbiofuels at a cost of $7.80 per l itre, which is$1 ,240 per barrel, but was making a loss evenat such exorbitant prices45. Nobody else hascome forward to invest in this technology.

This leaves Gevo as the only contender, usingdifferent technology.

Gevo made headlines in November 201 6,when it supplied the first ever aviation biofuelsmade from wood to Air Alaska. Breaking downcellulose contained in wood into sugars whichcan then be fermented has been possible forover a century46, but the costs and energybalances have been prohibitive. Gevo did notin fact process any wood. Instead, sugarsobtained from wood were delivered by a nowdefunct public private research initiative47.Gevo has built a commercial-scale refinery inMinnesota. That refinery contains fourfermenters, al l of which use corn starch. Threeproduce ordinary corn ethanol, a fourth hasbeen designated to produce isobutanol whichis then upgraded to useful hydrocarbons,including jet fuel, in Texas. Gevo’s isobutanolproduction has been so expensive, and sobeset with problems, that the whole businesscontinues to operate at a loss. In its 201 6

Annual Report to the financial regulators inthe US, Gevo admitted: “We have producedonly l imited quantities of isobutanol atcommercial scale and we may not besuccessful at increasing our production”48.The company conceded it has had problemswith contamination – i.e. the wrong type ofyeast getting into the isobutanol fermenters –and with achieving the yields it had hoped for,by which it must mean the yields which it hasbeen tel l ing airl ines and government agenciesit could achieve. Gevo’s losses and debtscontinue to mount, and the company’s futureseems in serious doubt.

Creating a new demand for sugar cane orcereals would mean more industrialmonocultures for biofuels, grown at theexpense of food and at the expense ofgrasslands and other biodiverse habitats. I twould also mean more agrochemical use,more water and soil pol lution and depletion.However, this does not appear to be arealistic threat posed by aviation biofuels.

Air Alaska’s fl ight with isobutanol from sugarsin wood appears to have been nothing but aPR stunt: there has not been a singlesuccessful ethanol refinery that uses wood inthe world, despite many attempts – whereasethanol production from sugar crops andcereals is commonplace. Given that nobodyhas succeeded in commercial ly successful

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U.S. Air Force photo/Staff Sgt. Oely Santiago: First aircraft flown with Alcohol-to-Jet fuel by

the US Air Force, fuel suppl ied by Gevo, June 201 2

isobutanol production from any type of sugar,the idea that this could be done from wood inthe foreseeable future seems far-fetched.

LanzaTech: Aviation biofuels withoutbiomass?

In 201 6, VirginAtlantic announced apartnership with the New Zealand/UScompany LanzaTech, with whom it had beencollaborating since 2011 . I t announced thatLanzaTech had produced 1 ,500 gallons ofaviation biofuels at a demonstration plant in

Shougang, China49. The fuel is yet to beapproved for use for passenger fl ights.LanzaTech’s fuel, despite being certified bythe Roundtable on Sustainable Biomass50, isnot in fact made from biomass. The companyhas genetical ly engineered gas-fermentingClostridium bacteria, commonly found inhydrothermal vents, in order to ferment carbonmonoxide from flue gases to ethanol andanother chemical, butanediol51 which can beconverted to hydrocarbons, including aviationfuel.

LanzaTech’s concept is attractive: Planeswould eventual ly fly without fossil fuels orbiofuels from crops or trees, which requirelarge areas of land. Instead, smokestackgases coming out of steel mil ls or oil refinerieswould be captured and fermented to fuels. Bythe end of 201 4, LanzaTech had attractedinvestment from Mitsui, Siemens, KhoslaVentures, and New Zealand SuperannuationFund, amongst others, and it had entered intoJoint Ventures with two large Chinese steel

Microorganisms play a vital role inregulating the carbon cycle and all

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Shougang J ingtang Iron and Steel Plant – at which

LanzaTech’s demonstration plant is situated; photo:

wikimapia.org

producers52. Yet there is l ittle evidence thatLanzaTech is anywhere close to a commercialbreakthrough. Between 201 4 and 201 5, itsannual losses grew while its revenuesdropped53. LanzaTech’s website l ists four pilotand demonstration plants it has built – three ofwhich have been closed54.

According to Robert Rapier (author a blog onenergy issues), the key problem withLanzaTech’s technology is energy balance55.Even a conventional corn ethanol refineryrequires high energy inputs, much of it fordisti l l ing the ethanol, which is recovered fromfermentation tanks in 1 2-1 5% solutions. Theless concentrated the solution, the moreenergy is needed to boil off the water56. InMarch 201 7, LanzaTech revealed that it hadachieved less than 2% concentrations ofethanol, and less than 4% concentrations ofbutanediol (i .e. of the chemical which can beupgraded to aviation fuels – requiring furtherenergy inputs)57. This means that LanzaTechwil l need at least six times more energy than acorn ethanol refinery for disti l lation. LanzaTechclaims that it wil l use “low-value waste heat”from steel mil ls or a refinery, but, as Rapierhas pointed out, waste heat is only “low-value”because it is not hot enough to boil water. Withsuch high energy requirements for disti l lation,LanzaTech is clearly a very long way frombeing able to fuel planes.

Genetically engineered microbes for biofuelsmay not be commercially successful, but poseserious dangers

Amyris, Gevo and LanzaTech have al l been usingsynthetic biology, i .e. extreme geneticengineering, to develop microorganisms whichcan help convert biomass into biofuels,including for planes. Amyris and Gevo havebeen engineering baker’s yeast to fermentsugars to two different precursors ofhydrocarbon fuels. LanzaTech has beenengineering gas fermenting Clostridiumbacteria, which metabol ise carbon-rich fluegases to biofuels.

The ecological and health impl ications ofgenetical ly engineered microorganisms escapingor being del iberately released into theenvironment remain unknown and largelyunassessed, but of most serious concern:

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In 201 2, LanzaTech obtained permission forthe environmental release of GE bacteria inNew Zealand59. Gevo and Amyris claim thattheir use of GE yeast in refineries is

‘contained’. However, Gevo has admitted tostruggl ing with contamination of its isobutanolfermenter, i .e. with keeping other strains ofyeast out of it. I f it cannot prevent undesiredyeast from entering that fermenter than it isdifficult to imagine that the company cancontain the GE yeast inside it. In 201 2, theindustry magazine Biofuel Digest reportedabout Amyris:

A friend of the Digest writes: “I was inBrazil last month and got an earful aboutthat from a very high up there on [Amyris].If their shiny high grade fermenter wasnot up to snuff they are really introuble…having worked in nice universitylabs and clean room pharmaceuticalsthey did not know what was awaitingthem in the down market dirty world ofbiofuel. You can’t make biofuels withanything you got to keep that clean.”60

4. Palm oil for planes – by far the most crediblefeedstock for aviation biofuels

Hydrotreated vegetable oils: the world’s fastestgrowing type of biofuel

In 2007, the Finnish oil company Nesteinaugurated a completely new type of biofuelproduction into its oi l refinery in Porvoo, nearHelsinki. This biofuel – made fromHydrotreated Vegetable Oil (HVO) - waschemical ly identical to petroleum-deriveddiesel, which made it technical ly superior tobiodiesel or ethanol.

Three years later, Neste went on to open theworld’s two largest biofuel refineries, inSingapore and in Rotterdam. Each producesalmost 1 mil l ion tonnes of HVO fuels per year.Several, mostly oi l companies, have fol lowedsuit, although Neste sti l l accounts for 60% ofglobal HVO production61 .

The Ital ian oil company Eni has converted anoil refinery near Venice to 1 00% HVOproduction and is in the process of converting

Synthetic biology research, NASA Ames, Photo: Alexandervan Di jck

planetary nutrient cycles, including soilnutrient cycl ing. Yet their ecology is poorlyunderstood and it is estimated that onlyaround 1% of al l yeast and bacteriaspecies have ever been isolated andidentified;

Once a GE microorganism enters theenvironment, it wil l be difficult to detect andimpossible to isolate. Even if it was toprol iferate to form large populations andcause harm, l imited knowledge of theworld’s microbial diversity would make itvery difficult to trace back to its source.Reversing any harm done would bevirtual ly impossible;

Microorganisms are capable of transferringgenetic materials to other species, even toplants and animals. Such “horizontal genetransfer” has been observed in Clostrodiumbacteria and in yeasts. This means thataltered gene sequence may not remainl imited to the intended species;

Microorganisms have a particularly largepotential for population growth andevolutionary change. Even GEmicroorganisms thought to be unable tosurvive in the natural environment couldacquire the abil ity to do so through genetransfer and mutations58.

What exactly is HVO?

HVO is made from the same feedstocks asbiodiesel: vegetable oils (including rapeseed,palm and soybean oil) and animal fats (mainlytal low, a residue from slaughterhouses). I tconsists entirely of hydrocarbons, i .e.compounds of hydrogen and carbon.

Hydrotreating, used to produce HVO, is aprocess widely used in fossil fuel oi l refining,which oil companies have adapted tovegetable oils and animal fats. I t involvesreacting oils and fats with hydrogen, which isusually produced from natural gas65.Reactions take place under high pressure andat temperatures of 300- 400oC.

HVO fuels can be produced in existing,possibly retrofitted oil refineries, or in purpose-built ones. They can also be processedtogether with fossil fuels in a refinery.Biodiesel refineries, on the other hand, cannotbe converted to HVO fuels.

There are two important differences betweenHVO and biodiesel:

Firstly, HVO products are chemical ly identicalor near identical to petroleum-derivedproducts. This means that there is no limit onthe amount of HVO that can be blended withdiesel. On the other hand, most dieselengines can only burn l imited amounts ofbiodiesel. The EU’s legal standard for dieselpermits a maximum of 7% biodiesel blends66.HVO is thus essential to meeting biofueltargets of more than 7%. And, because HVOproducts can be used in aircraft in up to 50%blends, whereas biodiesel is unsuitable foraviation67.

Secondly, the properties of biodiesel varydepending on the feedstock, but those of HVOvary only according to the refiningconditions68. Biodiesel made from some typesof vegetable oil – most importantly palm oil –sol idifies during normal winter temperatures intemperature cl imates, which strictly l imits theamount of palm oil that can be used forbiodiesel.

HVO fuels for planes: Still an expensiveniche market

At present, the vast majority of HVO fuels are1 2

Eni ’s Porto Marghera refinery near Venice which has beenconverted to HVO production from palm oi l , Source:

panoramio.com/photo/40482299

a second, in Sici ly. Total is converting its LaMède refinery in France. Repsol and Cepsa inSpain and Galp in Portugal are co-processingvegetable oils and animal fats with fossil fueloi l . Preem in Sweden and the paper companyUPM in Finland have built HVO refinerieswhich use a byproduct from pulp and paperproduction (tal l oi l) as a feedstock.

In the US, AltAir, Diamond Green Diesel andREG are operating HVO biofuel refineries,and Emerald Biofuels and SG Preston haveplans for future ones.

Three Chinese refiners, Yangzhou JianyuanBiotechnology Co Ltd, ECO BiochemicalTechnology Co Ltd and Hainan Huanyu NewEnergy Co Ltd have been certified asproducing HVO diesel which meets the EUbiofuel standards set out in the RenewableEnergy Directive62. Furthermore, ChinaPetrochemical Corporation (Sinopec) hasannounced plans to build an HVO refinerywith the stated aim of producing fuel foraircraft63.

HVO refineries have also been announced inUnited Arab Emirates, Indonesia and Mexico,although the status of those plans isuncertain.

Altogether, 5.2 mil l ion tonnes of HVO wereproduced in 201 6. HVO accounts for 4% ofbiofuels worldwide, but is growing at over tentimes the rate of biofuels overal l64. With twonew HVO refineries due to open in 201 7/1 8,and with Neste expanding its capacity, HVOproduction wil l continue to grow steeply.

HVO diesel, used in road transport. The factthat HVO diesel can be used in higher blendsmakes it competitive with biodiesel, eventhough it is more expensive to produce. Likemost biofuels, it depends on subsidies,including blending mandates and quotas inorder to compete with fossil fuels69.

HVO diesel is cheaper to produce than HVOfuel for aircraft, cal led HEFA. This is becauseHEFA refining requires more severeprocessing, which reduces biofuel yields pertonne of feedstock by 5-1 0%.

AltAir, the world’s only regular producer ofHEFA, appears to be sell ing it as a “lossleader”, one which has gained them a lot ofinterest and publicity, while making most of itsincome from sell ing HVO diesel and gettingfederal and state subsidies70 for that.

According to several estimates, the productioncost of HVO aviation fuel is above $1 ,000 pertonne71 . By comparison, the highest monthlyglobal jet fuel price during the year ending31 .8.1 7 was around $426 per tonne72. Jet fuelprices are on average only sl ightly abovethose of diesel. This means that evenextending the subsidies available for roadtransport biofuels to aviation biofuels wouldnot make HEFA competitive with HVO used incars.

Far cheaper HVO for airplanes on thehorizon

Aviation biofuels wil l have to becomesignificantly cheaper to produce beforeairl ines can use them on a large scale. Thiscould happen very soon if an applicationmade by Neste and Boeing to the standardsagency ASTM is approved.

In 201 4, the two companies tested a blendwith 1 5% HVO diesel (i .e. the HVO fuelnormally only used for road transport) in a jetengine73. They argue that the overal l blendmet al l of the technical specifications for jetfuel and should therefore be approved.Approval of this application would immediatelylower the production cost of aviation biofuelsto that of HVO diesel. Except where subsidiesfavour biofuels for cars, HVO could becomeeven more profitable when sold to airl inesrather than for road transport, because jet fuelprices are sl ightly higher than those for diesel.

1 5% of current global jet fuel use translates to43.3 mil l ion tonnes. This is equivalent to 3times the volume of the EU’s entire biofuelmarket - or 1 .6 times the world’s entirebiodiesel production74.

In 2011 , a High-Level Panel of Expertswarned75: “Biofuel support policies in theUnited States and the European Union havecreated a demand shock that is widelyconsidered to be one of the major causes ofthe international food price rise of 2007/08.” I tpointed out that the growth in global vegetableoil markets would have slowed down had it notbeen for the major growth in European biofueluse between 2000 and 201 0. This washappening at a time when global and EUvegetable oil use for biofuels was significantlysmaller than today. Creating a new biofuelmarket for vegetable oils 1 .6 times as big asthe one that exists today would have verydramatic effects indeed.

Can we really expect 43 million tonnes ofHVO diesel burned in planes in the nearfuture?

There can be no doubt that approval for 1 5%blends of HVO diesel in commercial aircraftwould be a very significant breakthrough.

However, HVO diesel is more expensive thanbiodiesel and far more expensive than fossilfuel diesel76. HVO “cost parity” with petroleum-based jet fuel would thus require newsubsidies to bridge the remaining gap.

At present, far more generous subsidies areavailable for road transport biofuels than foraviation biofuels:

In the EU, subsidies mainly take the form ofblending mandates. Such mandates havebeen introduced by Member States seeking tomeet a 1 0% renewable energy target for roadand rail transport by 2020, set by the EURenewable Energy Directive, as well as arelated target contained in the Fuel QualityDirective. Aviation biofuels can be countedtowards meeting Renewable Energy DirectiveTargets, but no EU member state requiresairl ines to use any biofuels.

The only country in the world with a biofuelmandate for aviation is Indonesia, which has

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mandated 2% from 201 8, 3% from 2020, and5% from 2025. However, the 2% mandate wasto original ly have started in 201 6, and thereare doubts as to whether it wil l be enforced infuture77.

The question of whether aviation fuel madefrom HVO diesel wil l be adopted on a largescale thus comes down to policy decisions:wil l ICAO members decide to make fundsraised from aviation carbon offsets available tohelp airl ines bridge the price gap betweenpetroleum-based jet fuel and biofuels, as theBrazil ian Biojetfuel Platform proposes78? Wil lthe EU and governments around the worldextend existing biofuel subsidies to aviationand perhaps introduce new ones?

EU support for aviation biofuels

The European Commission has endorsed aviation biofuels for many years. In 2011 , itpubl ished a White Paper call ing for 50% “sustainable low carbon aviation fuel” use by 2050. Inthe same year, it partnered with industry to set up the European Advanced Biofuels Flight PathInitiative, which aims for 2 mil l ion tonnes of aviation biofuels to be produced annually by 2020.There has been significant EU funding for research and development into aviation biofuelsbiofuelstp.eu/aviation-biofuels.html. Aviation biofuels which meet the - albeit very weak – EUbiofuels standards are classified as “zero carbon” under the European Emissions TradingScheme (ETS). In practice, this has not yet made a difference because the ETS carbon pricehas been far too low to compensate airl ines for the higher cost of such fuels.

The European Commission’s proposal for a new, post-2020 Renewable Energy Directiveincludes a progressively tightening cap on food-based biofuels, including ones from virginvegetable oil , the abolition of a separate renewable energy target for transport, but a newmandatory target for “advanced biofuels”.

As the new legislation is debated, crucial decisions wil l be made about incentivising aviationbiofuels in general (by counting them higher towards renewable energy targets, and aboutdeciding which types of biofuels (regardless of where they are used) are defined andincentivised as “advanced biofuels”. Companies such as Neste want to get HVO classified as“advanced”.

The outcome wil l largely depend on whethergovernments and ICAO are prepared tocreate and subsidise a new market for palmoil .

Why palm oil is essential for large­scaleHVO use

So far, airl ines have been careful to avoidbiofuels made from palm oil . The high level ofpublic awareness about rainforest andpeatland destruction and landgrabbingassociated with oil palm plantations wouldmake it a PR disaster for companiespromising “greener” aviation. I t looks far betterfor airl ines to source the sti l l tiny amounts ofbiofuels used so far from wastes andresidues. Yet it is difficult to see how biofueluse for fl ights could be scaled up withoutresorting to palm oil .

Technical ly, HVO can be made from anyvegetable oil as well as from animal fats.Feedstock accounts for 60-80% of productioncosts79. The second biggest cost is forhydrogen. Hydrogen requirements and thuscosts can be reduced by choosing feedstockswhich are rich in saturated fats, such as palmoil or tal low, as opposed to soybean, rapeseedor camelina oil .

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Fel led rainforest on a Korindo oi l palm concession inPapua, Photo: Mighty Earth,

farmlandgrab.org/post/view/27387-samsung-get-out-of-confl ict-palm-oi l

Even jet fuel from tallow could be bad news for forests and climate

Tallow is a residue from slaughter houses. I t comprises animal fats which can be used infood, and ones which are not safe for human consumption. In the EU, tal low which is notedible for humans is divided into three categories, only one of which (category 3) can beused for soap, cosmetics and industrial products. In 201 6, the European Commissionpublished a commissioned study about indirect impacts associated with biofuels made fromtal low(ec.europa.eu/energy/sites/ener/fi les/documents/Annex%20I I%20Case%20study%202.pdf). I t concluded that “an increased used of animal fats by the biodiesel industry would lead toindirect effects through ILUC [indirect land use change] and fossil fuel combustion”. Thelivestock industry itself was responding to the new tal low demand for biofuels by sell ingtal low which it would otherwise have burned for on-site heat and power and switching tofossil fuels instead. The oleochemical industry (soap, cosmetics and various industrialproducts) was particularly dependent on tal low, but the competition for tal low from thebiofuels sector helped producers that could most easily and cheaply switch to palm oil bypartnering with Southeast Asian plantation companies. Those companies could easilyswitch from tal low to palm oil . The animal feed industry, on the other hand, could replacetal low with palm or rapeseed oil . A new tal low market for HVO for aircraft would alsocompete with biodiesel producers, who might have to switch to palm oil or other virginvegetable oils. Flying aircraft on blends with biofuels made from tal low could thus havemuch the same overal l impacts as flying them with HVO from palm oil .

Bridging the price gap between jet fuels madefrom fossil fuels and those made from biofuelsrequires keeping feedstock and otheroperating costs as low as possible. This wouldsti l l be the case even if existing subsidies forbiofuels for road transport were extended toaviation.

According to a 2011 report by one of theleading technology developers for HVObiofuels, Honeywell-UOP80, tal low was thecheapest HVO feedstock at the time. Buttal low and other suitable wastes and residues,namely Used Cooking Oil , are in l imitedsupply. Tallow and Used Cooking Oil arepopular biodiesel feedstocks, and some typesof tal low are in high demand for animal feed,soap, cosmetics, rubber and plasticproduction.

For example, Total is converting an oil refineryin La Mède, France to HVO and wil l require650,000 tonnes of vegetable oils and animalfats per year in order to operate the plant atful l capacity. Total claims that it wil l use1 00,000 tonnes of Used Cooking Oil , but hasonly succeeded in signing a sourcing contractfor one-fifth of that amount. A special ist traderin waste vegetable oils and fats, Greenea,estimates that Used Cooking Oil col lectionscould at most be increased by 50,000 tonnesa year across France. All of Total ’s other

Finnish oil company Neste, the world’sleading HVO producer, states that its useof crude Palm Oil dropped from 31% in201 5 to 1 9% in 201 6, and that wastesand residues accounted for 78% of itsfeedstock that year82. 1 9% of palm oiltranslates into half a mil l ion tonnes, sti l l avery substantial amount. However,Neste’s so-cal led residues include anundisclosed proportion of a constituent ofCrude Palm Oil cal led PFAD83, whichmany believe should not be classified asa residue at al l (see below);

I tal ian oil company ENI runs its HVOrefinery near Venice, I taly, entirely onpalm oil84, which is also the expectedfeedstock for the HVO refinery it iscurrently converting in Sici ly;

Portuguese oil company Galp started co-processing 3% of palm oil in its Sines oilrefinery in Portugal in September 201 785.Galp has set up its own oil palmplantations in Brazil86;

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feedstock – ranging from 550,000 to 630,000tonnes a year - is expected to be palm oil81 .

Not surprisingly, given the cost considerationsdiscussed above, the vast majority of HVOproduced worldwide is made – completely orpartly – from palm oil :

In Spain, Cepsa (owned by InternationalPetroleum Investment Company) andRepsol jointly produced 1 40,000 tonnes ofHVO in the first half of 201 6 (i.e. 280,000tonnes throughout 201 6, assuming thatthe rate of production remained the sameall year). Together, they are co-processingpalm oil with fossil fuels in 7 or 8refineries87;

BP produces HVO from palm oil in itsRotterdam refineries and in two refineriesin Spain;

Chinese HVO producers Hainan HuanyuNew Energy Co Ltd and ECO BiochemicalTechnology Co Ltd use PFAD (see below)in their mix;

In Indonesia, an HVO refinery has beenproposed by the state-owned oil and gascompany Pertamina in collaboration with apalm oil company, PT PerkebunamNusantara.

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Hiding palm oil amongst residues: WhyPalm Fatty Acid Distillate (a PFAD) mattersin the debate about aviation biofuels

Companies hoping to become aviation biofuelproducers face an obvious dilemma: on theone hand, the economics of HVO productionstrongly favour palm oil . On the other hand,palm oil fuels would pose a reputational risk toairl ines and undermine efforts too “green” theindustry’s image.

HVO refiners have found a partial answer tothis di lemma: Palm Fatty Acid Disti l lates(PFAD), which companies l ike Nestecontroversial ly class as a ‘residue’. Whencrude palm oil is refined, free fatty acids areremoved because they turn palm oil rancidand thus unsuitable for food. PFAD, whichcontains those concentrated fatty acids, isused by the oleochemical industry in soap,cosmetics, candles, rubber and plastic, foranimal feed, and to extract compounds fornutraceuticals88.The UK Government advises:

“The treatment of PFAD in the RED[Renewable Energy Directive] GHG[greenhouse gas] calculations indicatesthat it is to be treated as a product. PFADhas a significant economic value inrelation to the main product (palm oil) anda variety of productive uses.”89

This seems sensible, given the high demandfor PFAD and the fact that none would bewasted in the absence of a demand forbiofuels. Biofuel guidance in Sweden, Finlandand Norway also states that PFAD should notbe classified as a “waste or residue”90. I taly onthe other hand classifies PFAD as a residueand counts it double towards its biofuelstargets.

Such a debate about classifications maysound academic, but it has major implicationsfor palm oil use in biofuels:

In the EU, biofuels made from residues areexempt from most sustainabil ity standards,and count double towards renewable energytargets, which gives them a significant pricepremium. Furthermore, from the beginning of201 8, palm oil processed in mil ls withoutmethane capture wil l no longer meet the EU’sgreenhouse gas standards for biofuels91 , yetthis wil l not affect any palm oil “residues”. Andthe European Commission’s proposal for apost-2020 Renewable Energy Directive wouldprovide yet more incentives to biofuels madefrom residues and wastes as opposed to virginvegetable oil , sugar crops and cereals. Inshort, classifying PFAD as a residue allowscompanies such as Neste to make more profit(through double-counting of its biofuels), andto protect itself against any future regulationsthat may limit palm oil use.

Getting PFAD classed as a residue by ICAOwould al low airl ines to source HVO made frompalm oil , without having to declare it as such.The same could happen if ICAO was toclassify PFAD as a by-product whilst treatingthose in a similarly favourable way as the EUtreats wastes and residues for biofuel.

That could contribute significantly towardsmaking HVO use in aircraft commercial lyviable, albeit not at the scale proposed by theICAO Secretariat. Right now, PFAD productionworldwide is just 2.5 – 3 mil l ion tonnes a year.A multi-mil l ion tonne demand for aviationbiofuels would have dramatic, though difficultto predict, impacts on palm oil markets.

There are two main ways in which PFAD usein aviation biofuels could lead to new andlarger oil palm plantations:

1 6

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The most obvious one wil l be for animal feedproducers and oleochemical companies toreplace PFAD with crude or refined palm oil ,particularly since the other attractivealternative, tal low, is also increasingly used forbiofuels.

Another possibi l ity is that a spiral l ing demandfor PFAD could push up its price to match or

move beyond that of refined, edible palm oil . I fthat were to happen, palm oil processors andgrowers might start producing crude palm oilwith a greater fatty acid content, i .e.del iberately increasing the proportion of PFADcompared to refined palm oil . This istechnical ly possible and would directly couplePFAD demand to oil palm expansion92..

5. Why sustainability and greenhouse gas standardsfor aviation biofuels are not the answer

Whether or not sustainabil ity (includinggreenhouse gas) standards can guaranteethat biofuels and other forms of bioenergy aresustainable and low-carbon has been debatedfor many years. Biofuelwatch has long arguedthat they are inherently ineffective as a tool foraddressing negative impacts of bioenergy93

because:

standards cannot address “sustainabil ityof demand”: for example, excessivedemand for agricultural products andwood has long been the primaryunderlying driver of deforestation andforest degradation. Driving this demandup further can only make the situationworse;

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Diagram of a Crude Palm Oi l refinery (Note: Recovered Disti l late is PFAD), Source: Abd Karim Al ias, vimeo.com/34329405

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6. The dangers of hype about palm oil for planes

Even if large-scale aviation biofuels do notbecome a reality – perhaps because palm oiluse is political ly too sensitive – there is aserious risk that plantation companies wil lprofit from mere expectations generated by anICAO “vision” such as that proposed by theSecretariat.

In 201 3, ActionAid reported that 98 Europeaninvestors had taken control over 6 mil l ionhectares of land in Sub-Saharan Africabetween 2009 and May 201 3 with the statedaim of producing biofuels, especial ly for theEU market94. Yet figures published in the sameyear showed that virtual ly no African feedstockhad been used for EU biofuels by 201 395. Themere expectation of a major new demand forvegetable oils and other agricultural productsfrom Africa was enough to facil itate one of thebiggest land-grabs in history. I t helpedpersuade state authorities to lease or sel l landto investors, and to attract finance – even if thereal intention behind many of thoseacquisitions may have been to acquire land fordifferent purposes, or to simply profiteer fromland speculation.

There is a risk that an ICAO “vision” for large-scale aviation biofuels could fuel land-grabs ina similar manner, regardless of whether it isever realised.

1 8

2006 landgrab by UK company Sun Biofuels in Tanzania,2008 Photo: Tom Pietrazik, ActionAid – 1 1 vi l lages lost20,000 acres of land, no biofuels were ever produced,

Sun Biofuels went bankrupt but the land went to a cattleranching company, rather than being returned to the

communities

there are no credible ways of addressingthe major indirect impacts of bioenergythrough standards;

there is no regulatory mechanism formonitoring and enforcing compliance withstandards;

the World Trade Organisation and bi- andmulti lateral trade agreements exertstrong pressures against genuinelymeaningful standards.

Standards cannot make the ICAOSecretariat’s aviation biofuels “Vision”sustainable. Firstly, the scale of the additionalbiofuel demand would be highlyunsustainable. Secondly, there is no realalternative to using palm oil for large-scaleaviation biofuels no matter what standardsmight say. Suitable wastes and genuineresidues are in l imited supply. And there is nogood argument for taking scarce wastes and

residues away from road transport biofuels aslong as mandates for those remain in place –doing so would simply lead to more palm andsoybean oil being used for cars.

Final ly, ICAO itself is drawing up standardsthrough its Committee on AviationEnvironmental Protection, yet it is heavilydominated by the aviation industry and notknown for its expertise in protecting forests orcommunity rights.

Nonetheless, if standards were to explicitlyprohibit the use of palm oil – including PFAD –this would go a very long way towardspreventing serious harm from aviationbiofuels. I t would almost certainly preventlarge-scale uptake of biofuels for planesaltogether. Whether such standards would bepermissible under World Trade Organisationregulation is highly questionable. I t would befar safer for governments to refuse tosubsidise aviation biofuels altogether.

7. ConclusionsICAO’s support for large-scale biofuels stemsfrom the aviation industry’s quest to protect itshigh growth rates, something which would beimpossible if it was forced to genuinely reduceits greenhouse gas emissions.

The only mature technology for producingaviation biofuels is hydrotreating of vegetableoils and animal fats (HVO). Even HVOaviation fuels are currently so expensive thatthey can only be produced in small quantities.However, Neste and Boeing have applied tothe international standards agency ASTM topermit up to 1 5% blends of HVO diesel inplanes. HVO diesel – currently used for roadand rail transport only - is the fastest growingtype of biofuel worldwide. Approval of HVOdiesel blends with jet fuel would dramatical lylower the price of aviation biofuels.

Nonetheless, HVO diesel costs significantlymore than petroleum-based jet fuels. Evenwith subsidies, there would be pressure onproducers to keep costs down. The cheapestfeedstock by far which is available on a largescale is palm oil . HVO production for roadtransport is already heavily dependent onpalm oil , and it is difficult to see how the samecould be avoided for aviation biofuels.

Whether planes wil l in future fly with fuels frompalm oil in their tanks wil l largely depend onpolitical decisions, made by ICAO and bygovernments. Awareness of the seriousnegative impacts of palm oil has grown overthe past decade. In Apri l , the EuropeanParl iament adopted a resolution which callson the European Commission to “takemeasures to phase out the use of vegetableoils that drive deforestation, including palm oil ,as a component of biofuels, preferably by

2020”96. In the US, the EnvironmentalProtection Agency has so far refused toaccredit palm oil as a biofuel feedstock eligiblefor federal subsidies (i .e. for the RenewableFuel Standard). I t wil l be vital for civi l societygroups to oppose subsidies for aviationbiofuels, which would translate into newsubsidies for palm oil .

1 9

At the same time, it is important to debateabout aviation biofuels in the wider context ofaviation. Greenhouse gas emissions fromaircraft today – let alone in future, at theprojected growth rates – are incompatible withstabil ising global warming at 1 .5oC or even2oC. The only credible way of tackling thoseemissions is through policies which stem andreverse the growth in aviation – includingbetter investment in and support for rai l andbus services and abolishing subsidies foraircraft, including tax exemptions.

Plane Stupid Scotland scale the Scottish Parl iamentbui lding in protest against plans for airport expansion.

Photo by Al ice Myers

References1 . National greenhouse gas inventory datafor the period 1 990–201 4, Report by theSecretariat, UNFCCC, 2nd November 201 6,unfccc. int/resource/docs/201 6/sbi/eng/1 9.pdf

2. IATA Forecasts Passenger Demand toDouble Over 20 Years, 1 8th October 201 6,iata.org/pressroom/pr/Pages/201 6-1 0-1 8-02.aspx

3. Airfreight demand on the increase but sti l loutpaced by capacity rise, Air Cargo News,3rd August 201 6,www.aircargonews.net/news/airl ines/single-view/news/airfreight-demand-on-the-increase-but-sti l l-outpaced-by-capacity-rise.html

4. Per unit of energy, tai lpipe CO2 emissionsfrom aviation biofuel use are more or lessidentical to those from fossil fuels. Theclassification of biofuels as “low carbon” or“carbon neutral” is based on a politicaldecision which does not reflect actualemissions from burning fuel, and which hasbeen heavily criticised by many scientists.

5. Hydrogen unlikely to become fuel foraircraft – it is no magic bul let solution foraviation CO2, Airport Watch, 4th March 201 7,airportwatch.org.uk/201 7/03/hydrogen-unl ikely-to-become-fuel-for-aircraft-it-is-no-magic-bul let-solution-for-aviation-co2/

6. Fuel Efficiency Trends for New CommercialJet Aircraft, 1 960-201 4, Anastasia Kharinaand Daniel Rutherford, International Councilon Clean Transportation, August 201 5,theicct.org/sites/default/fi les/publications/ICCT_Aircraft-FE-Trends_201 50902.pdf

7. Operation Fuel Efficiency, IATA,iata.org/whatwedo/ops-infra/Pages/fuel-efficiency.aspx

8. ICAO Council adopts new CO2 standard foraircraft, 6th March 201 7,icao. int/Newsroom/Pages/ICAO-Council-adopts-new-CO2-emissions-standard-for-aircraft.aspx

9. Cost assessment of near- and mid-termtechnologies to improve new aircraft fuelefficiency, International Council on Clean

Transportation, 27th September 201 6,theicct.org/aircraft-fuel-efficiency-cost-assessment

1 0. International Civi l Society Statement:Aviation industry plan to offset emissions wil lpush global warming beyond 1 .5° Celsius,September 201 6,fern.org/sites/fern.org/fi les/Final_September.pdf

11 . Conference on Aviation and AlternativeFuels, October 201 7, Proposed ICAO Visionon Aviation Alternative Fuels,icao. int/Meetings/CAAF2/Documents/CAAF.2.WP.01 3.4.en.pdf

1 2. Airl ine in first biofuel fl ight, BBC, 24thFebruary 2008,news.bbc.co.uk/1 /hi/7261 21 4.stm, andBranson's coconut airways - but jet is on afl ight to nowhere, say critics , Sam Jones andDan Milmo, 25th February 2008,theguardian.com/environment/2008/feb/25/biofuels. theairl ineindustry

1 3. The first biofuel demonstration fl ights wereconducted by Green Flight International in2007. Virgin’s demonstration fl ight was not apassenger fl ights.

1 4. See for exampleblog.virginatlantic.com/quest-biofuel-sustainable-aviation/

1 5. fl ightglobal.com/news/articles/astm-certifies-aviation-biofuels-from-plant-oi ls-animal-359086/ Any new type of aviation fuelhas to be certified by ASTM as meeting thetechnical and safety standards for use inaircraft.

1 6. Renewables 201 7 Global Status Report,REN21 , ren21 .net/wp-content/uploads/201 7/06/1 70607_GSR_201 7_Full_Report.pdf

1 7. New Alternative Jet Fuel Approved,Federal Aviation Administration, 22.04.1 6,faa.gov/news/updates/?newsId=85425 – Notethat two types of Fischer-Tropsch biofuelshave been approved, which are discussedtogether in this report.

20

1 8. This fuel is cal led Hydro-processed Estersand Fatty Acids Synthetic Paraffinic Kerosene(HEFA-SPK), usually referred to as HEFA.

1 9. This is fuel is cal led Synthesised Iso-Paraffins (SIP).

20. Amyris Inc. , US Securities and ExchangeCommission, Form 1 0-K, 1 7th Apri l 201 7,seekingalpha.com/fi l ing/35061 56

21 . Those fuels are called Fischer-TropschSynthetic Paraffinic Kerosene (FT-SPK) andFischer-Tropsch Synthetic Kerosene withAromatics (FT-SKA) respectively.

22. This fuel is cal led Alcohol-to-Jet SyntheticParaffinic Kerosene (ATJ-SPK).

23. Fischer-Tropsch fuels can also be madefrom natural gas and coal. In fact, the onlylarger-scale Fischer-Tropsch fuel productionworldwide rel ies on coal. However, Fischer-Tropsch fuels from natural gas or coal wouldnot fal l within the remit of the aviationindustry’s or ICAO’s “Sustainable AlternativeAviation Fuel” programmes.

24. Alternative Jet Fuels: Factors that haveenabled success, Jim Hileman, US FederalAviation Administration, 8-9th February 201 7,https://www.icao. int/Meetings/altfuels1 7/Documents/Jim%20Hileman%20-%20FAA.pdf

25. ALON USA SEC Fil ings,ir.alonusa.com/all-sec-fi l ings?form_type=1 0-K#document-45496-0001 325955-1 7-00001 6,Annual Report 27th February 201 7, page 40.

26. See Reference 24.

27. Converting MSW into Low-Cost,Renewable Jet Fuel, Bruno Mil ler, FulcrumBioenergy, 8th February 201 7,https://www.icao. int/Meetings/altfuels1 7/Documents/Bruno%20Mil ler%20-%20Fulcrum%20BioEnergy%20.pdf

28. Fulcrum Bioenergy withdraws $11 5 mil l ionIPO, Renaissance Capital, 30th November201 2, nasdaq.com/article/fulcrum-bioenergy-withdraws-11 5-mil l ion-ipo-cm1 94790

29. Congratulations to cl ients FulcrumBioEnergy and Red Rock Biofuels, Westar

Trade Resources Blog,westartrade.com/blog/bid/72808/Congratulations-to-Clients-Fulcrum-BioEnergy-and-Red-Rock-Biofuels

30. Mitigating International Aviation Emissions:Risks and Opportunities for Alternative JetFuels, Sammy El Takriti , Nikita Pavlenko, andStephanie Searle, White Paper, InternationalCouncil on Clean Transportation, March 201 7,theicct.org/sites/default/fi les/publications/Aviation-Alt-Jet-Fuels_ICCT_White-Paper_2203201 7_vF.pdf

31 . Biofuels in Defense, Aviation and Marine,Bioenergy Technologies Peer Review, ZiaHaq, US Department of Energy, 24th March201 5,energy.gov/sites/prod/fi les/201 5/04/f21 /day_2_plenary_haq_aviation.pdf

32. Thermal Gasification of Biomass UnitedStates Update, Kevin Whitty, IEA BioenergyTask 33, 2nd May 201 7,ieatask33.org/app/webroot/fi les/fi le/201 7/Innsbruck/CR/USA.pdf

33. Enabling Small-Scale BiomassGasification for Liquid Fuel Production,Santosh Gangwal, Southern ResearchInstitute, 29th-30th July 201 4,https://www.energy.gov/sites/prod/fi les/201 4/11 /f1 9/gangwal_biomass_201 4.pdf

34. Waste Gasification and Pyrolysis: HighRisk, Low Yield Processes for WasteManagement, Global All iance for IncineratorAlternatives, March 201 7,no-burn.org/gasification-pyrolysis-risk-analysis/

35. Open Letter: Call on UNCTAD to withdrawmisleading report about Second GenerationBiofuelMarkets, 7th Apri l 201 6,biofuelwatch.org.uk/wp-content/uploads/UNCTAD-2G-biofuels-report-critique-FINAL.pdf

36. Gridley Biofuels Project Final Report,Desert Research Institute, 21 st July 201 0,www.dri.edu/images/stories/editors/eafeditor/Hoekmanetal201 0DRIReportGridleyBiofuelsDilutionSample.pdf

37. Scorched Earth: Mil itary Forest to Fuels inOregon, Chris Zinda, 1 2th January 201 6,

21

counterpunch.org/201 6/01 /1 2/scorched-earth-mil itary-forest-to-fuels-in-oregon/

38. What happened at Choren?, RobertRapier, 8th July 2011 ,energytrendsinsider.com/2011 /07/08/what-happened-at-choren/

39. Inauguration of the BioTfueL projectdemonstrator in Dunkirk: 2nd generationbiodiesel and biokerosene production up andrunning, Energies Nouvelles, 9th December201 6 ifpenergiesnouvelles.com/News/Press-releases/Inauguration-of-the-BioTfueL-project-demonstrator-in-Dunkirk-2nd-generation-biodiesel-and-biokerosene-production-up-and-running

40. Coal-to-Liquids Technology and itsImportance to the Air Force and Civi l Aviation,Roger H. Bezdek, Management InformationServices Inc. , 27th February 2007,https://www.energy.vt.edu/vactl/BEZDEK.CTL.Briefing.HILL.2-07.pdf

41 . Fischer-Tropsch Synthesis, NationalEnergy Technology Laboratory,netl .doe.gov/research/coal/energy-systems/gasification/gasifipedia/ftsynthesis

42. Biomass Gasification and Pyrolysis,Biofuelwatch, June 2021 5,biofuelwatch.org.uk/wp-content/uploads/Biomass-gasification-and-pyrolysis-formatted-ful l-report.pdf

43. Overview of Coal and Coal-Biomass toLiquids (C&CBTL) Program, Jenny B.Tennant, US DOE, December 201 4,netl .doe.gov/File%20Library/Research/Coal/ccbtl/21 04-1 2-C-CBTL-Slide-Library.pdf

44. Sasol produces 1 .5 bil l ion barrels ofsynthetic fuel from coal in fifty years, Sasol,24th August 2005, sasol.com/media-centre/media-releases/sasol-produces-1 5-bi l l ion-barrels-synthetic-fuel-coal-fifty-years

45. The Rise And Fall Of The Company ThatWas Going To Have Us All Using Biofuels ,Daniel Grushkin, 8th August 201 2,fastcompany.com/3000040/rise-and-fal l-company-was-going-have-us-al l-using-biofuels

46. The first commercial cel lulosic ethanolplant in the US, Robert Rapier, 1 0thSeptember 2009,http: //www.energytrendsinsider.com/2009/09/10/the-first-commercial-cel lulosic-ethanol-plant-in-the-u-s/

47. Gevo Produces First CellulosicRenewable Jet Fuel Specified for Use onCommercial Airl ine Flights, Gevo, 11 thOctober 201 6,ir.gevo.com/phoenix.zhtml?c=23861 8&p=irol-newsArticle&ID=221 0799

48. SEC Fil ings, 1 0-K Annual Report, Gevo,31 st March 201 7,ir.gevo.com/phoenix.zhtml?c=23861 8&p=irol-sec

49. Virgin unveils aviation 'game-changer' withalcohol-to-jet fuel, Edie, 1 4th September201 6, edie.net/news/8/Virgin-unveils-aviation--game-changer--with-alcohol-to-jet-fuel/

50. Certification Evaluation Report: Beij ingShougang LanzaTech New Energy ScienceandTechnology Co. , Ltd. , Roundtable onSustainable Biomaterials, 22nd October 201 5,rsb.org/wp-content/uploads/201 7/03/RSB_RPT_SGLTNE_11 091 5_ForRSB-1 .pdf

51 . The GE Clostridium bacteria ferment amixture of carbon monoxide, carbon dioxideand hydrogen to ethanol and 2,3 butanediol.See Circular economy through C1fermentation, LanzaTech, 201 4,https://www.bio.org/sites/default/fi les/WorldCongress/Sean%20Simpson.pdf. Butanediolcan be converted to hydrocarbon fuels,including for aircraft.

52. LanzaTech, a Waste-Gas-to-Fuel Startup,Tops Off a $11 2M Funding Round, EricWesoff, 8th December 201 4,greentechmedia.com/articles/read/can-lanza-khosla-solve-the-biofuels-conversion-riddle

53. Carbon recycler LanzaTech widens annualloss to US$38 mln , Scoop Business Desk,1 3th July 201 6,scoop.co.nz/stories/BU1 607/S00378/carbon-recycler-lanzatech-widens-annual-loss-to-us38-mln.htm

54. lanzatech.com/facil ities/22

55. LanzaTech’s Vulnerabil ity, Robert Rapier,1 6th October 201 4,energytrendsinsider.com/201 4/1 0/1 6/lanzatechs-vulnerabil ity/

56. Alternative Fuels from Biomass Sources,Penn State College of Earth and MineralSciences, e-education.psu.edu/egee439/node/673

57. A Hybrid Catalytic Route to Fuels fromBiomass Syngas, Sean Simpson, LanzaTechInc. , 9th March 2001 7,https://energy.gov/sites/prod/fi les/201 7/05/f34/thermochem_simpson_2.3.1 .403.pdf

58. CBD Technical Series 82, SyntheticBiology, Secretariat of the Convention onBiological Diversity, March, 201 5,https://www.cbd. int/ts/cbd-ts-82-en.pdf

59. Decision notice by the EnvironmentalProtection Agency, New Zealand, 26th Apri l201 2, epa.govt.nz/Publications/ERMA200833-decision.pdf

60. Playing Defense: Contamination and thejitter effect in advanced biofuels, J im Lane,27th May 201 2,biofuelsdigest.com/bdigest/201 2/05/07/playing-defense-contamination-and-the-j itter-effect-in-advanced-biofuels/

61 . Neste Annual Report 201 6, 8th March201 7, neste.com/en/corporate-info/news-media/material-uploads/annual-reports-0

62. Valid Certificates, InternationalSustainabil ity & Carbon Certification,iscc-system.org/certificates/val id-certificates/

63. Finding new sources of biofuel to powerthe world’s aeroplanes, Gary Peters, 1 8th July201 7, airport-technology.com/features/featurefinding-new-sources-of-biofuel-to-power-the-worlds-aeroplanes-5870860/

64. In 201 6, HVO production grew by 22%,compared to a 2% growth in biofuels overal l ;see Reference 1 6.

65. I t is possible to make the hydrogen fromone of the byproducts of HVO production,propane, but the propane is commonly sold as

“renewable” LPG instead.

66. BS EN590 Standard for Diesel Fuel, IPUGroup, ipu.co.uk/en590/

67. The reason why HVO-based jet fuels mustbe blended with 50% fossil-fuels is that theydo not contain as many aromatichydrocarbons as conventional jet fuel. Jetfuels have to contain a wide range ofhydrocarbon molecules, including aromaticones because plane engines have to operatein a wide range of often extreme conditions.

68. However, very impure waste feedstockscan cause damage to the hydrotreatingequipment, and some feedstocks are easier torefine than others.

69. There is no consensus as to whetherconsumption mandates, such as those forbiofuels, should be defined as a subsidy. TheInternational Energy Agency and the GlobalSubsidies Initiatives regard them as subsidies,because they drive up market prices, set ademand floor and thus make biofuelproduction more competitive. We use thisdefinition (see Biofuels — At What Cost? Areview of costs and benefits of EU biofuelpol icies, Global Subsidies Initiative, Apri l 201 3,i isd.org/gsi/sites/default/fi les/biofuels_subsidies_eu_review.pdf)

70. AltAir’s HVO diesel is subsidised throughthe California Low Carbon Fuel Standard, andfederal Renewable Fuel Standard, and unti lDecember 201 6, it also benefited fromblenders’ tax credit (which has expired butcould sti l l be reinstated retroactively).

71 . Building up the future cost of biofuel,Sustainable Transport Forum, Sub Group onAdvanced Biofuels, European Commission,1 2th February 291 7,platformduurzamebiobrandstoffen.nl/wp-content/uploads/201 7/07/201 7_SGAB_Cost-of-Biofuels.pdf, and Reference 30, andReview of Biojet FuelConversionTechnologies, Wei-Cheng Wang et.al. , NREL,July 201 6, nrel.gov/docs/fy1 6osti/66291 .pdf

72. Jet Fuel Daily Price, Index Mundi,accessed 2nd October 201 7,indexmundi.com/commodities/?commodity=jet-fuel&months=1 2

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73. The HEFA type Renewable Jet Fuel -Views from the refiner, Henrik Erämetsä,Neste, 21 st March 201 7,ies.be/fi les/Erametsa_H.-Neste-HEFA-Views_from_the_refiner.pdf

74. Global jet fuel use in 201 6 was 85 bil l iongallons, which is 288.69 mil l ion tonnes(caafi.org/resources/faq.html). 1 5% of this is43.3 mil l ion tonnes. EU biofuel use in 201 6was estimated as 1 4.4 mil l ion tonnes(bioenergyinternational.com/biofuels-oi ls/eu-biofuel-consumption-201 6-increased-marginal ly-1 4-4-mtoe). Global biodieselproduction was 30.8 bil l ion l itres (en21 .net/wp-content/uploads/201 7/06/1 70607_GSR_201 7_Full_Report.pdf , i .e. 26.94 mil l ion tonnes in201 6.

75. Price volati l i ty and food security, The HighLevel Panel of Experts on Food Security andNutrition, July 2011 ,fao.org/fi leadmin/user_upload/hlpe/hlpe_documents/HLPE-price-volati l i ty-and-food-security-report-July-2011 .pdf

76. Fuel costs – Production, distribution andInfrastructure costs used in the EconomicAnalysis in Grøn Roadmap 2030, EA EnergyAnalyses, 1 9th November 201 5, ea-energianalyse.dk/reports/1 459_fuel_costs_production_distribution_infrastructure.pdf

77. Developing the Potential of Indonesia’sAviation Sector, IATA, 1 2th March 201 5,iata.org/pressroom/pr/Pages/201 5-03-1 2-01 .aspx and Indonesia Aviation BiofuelsPolicy, Saptandri Widiyanto, AlternateRepresentative of Indonesia to ICAO, 25th-27th October 201 6,caafi.org/resources/pdf/Biennial_Meeting_Oct25201 6_Special_Guest_Comment1 .pdf

78. Brazil ian Biojetfuel Platform: Meeting theCORSIA Challenge, 8th-9th February 201 7,https://www.icao. int/Meetings/altfuels1 7/Documents/3-MLu-BBP.07Feb.pdf

79. Reference 1 7, Table 7, and Fuel costs –Production, distribution and Infrastructurecosts used in the Economic Analysis in GrønRoadmap 2030, EA Energy Analyses, 1 9thNovember 201 5, ea-energianalyse.dk/reports/1 459_fuel_costs_production_distribution_infrastructure.pdfpage 1 0.

80. Green diesel production by hydrorefiningrenewable feedstocks, Tom N. Kalnes et.al . ,Biofuels Technology, January 2011 ,https://www.honeywell-uop.cn/wp-content/uploads/2011 /01 /UOP-Hydrorefining-Green-Diesel-Tech-Paper.pdf

81 . Reconvertir la raffinerie de La Mède pourune transition juste socialement et soutenableécologiquement, Les Amis de la Terre France,Apri l 201 7,amisdelaterre.org/IMG/pdf/reconvertir_la_raffinerie_de_la_mede_avri l_201 7.pdf andbiofuels, waste based biofuels, waste basedfeedstock, Greenea, 23rd March 201 7,greenea.com/publication/and-do-you-recycle-your-used-cooking-oi l-at-home/

82. See Reference 61 .

83. In an email to Biofuelwatch dated 31 stAugust 201 7, Johann Lunabba of Nestereplied to a query about the proportion ofPFAD in “residues and wastes”, saying: “Forcompetitive reasons Neste has decided not todisclose the proportions of specific waste andresidue feedstocks and therefore unfortunatelywe cannot give clarifications to those specificrequests.“

84. Green Refinery, Eni,eni.com/en_IT/innovation/technological-platforms/green-refinery.page

85. Sines produz biocombustível de 2ªgeração , Galp, 1 4th September 201 7,arge.pt/wp-content/uploads/201 7/09/Actual idades-Galp-Setembro-276.pdf

86. Biofuels, Galp,www.galpenergia.com/EN/AGALPENERGIA/OS-NOSSOS-NEGOCIOS/REFINACAO-DISTRIBUICAO/Paginas/Biofuels.aspx

87. Spain – HVO Production up 85% in 1 H-1 6,Square Commodities, 21 st December 201 6,squarecommodities.com/content/spain-hvo-production-85-1 h-1 6 and InternationalSustainabil ity & Carbon Certification, iscc-system.org/certificates/al l-certificates/ - HVOco-produced in Cepsa’s Tenerife refinery hasnot been ISCC certified, hence the feedstockused there cannot be corroborated.

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88. Production and uti l isation of palm fattyacid disti l late (PFAD), Ab Gapor Md Top(MBOP), Lipid Technology, January 201 0,ocl-journal.org/articles/ocl/pdf/2006/01 /ocl20061 31 p9.pdf

89. Renewable Transport Fuel Obligation(RTFO) guidance: year 1 0 , IL Department forTransport, 5th Apri l 201 7,www.gov.uk/government/publications/renewable-transport-fuel-obl igation-rtfo-guidance-year-1 0

90. Palm Fatty Acid Disti l late (PFAD) inbiofuels, ZERO and Rainforest FoundationNorway, 1 6th February 201 6,blogg.zero.no/wp-content/uploads/201 6/03/Palm-Fatty-Acid-Disti l late-in-biofuels.-ZERO-and-Rainforest-Foundation-Norway.pdf and Norway tightensregulations on use of PFAD for biodiesel,Platts, 26th Apri l 201 6, platts.com/latest-news/agriculture/london/norway-tightens-regulations-on-use-of-pfad-for-26427825

91 . From 1 .1 .201 8, al l biofuels need to beclassified as achieving at least 50%greenhouse gas savings compared to fossilfuels (Directive (EU) 201 5/1 51 3 of 9thSeptember, eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:3201 5L1 513&from=EN) - although the methodology usedto calculate greenhouse gas savings frombiofuels is highly controversial. The defaultand typical greenhouse gas savings l isted forHVO and biodiesel made from palm oilwithout methane capture are below 50%(Directive 2009/28/EC of 23 Apri l 2009, eur-lex.europa.eu/legalcontent/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN).

92. The fatty acid content of crude palm oildepends on how quickly palm fruits are

harvested and processed. At present, withedible refined palm oil attracting the highestprice, the industry requires a fatty acid contentof no more than 3-4%. However, palm oilproduced by smallholders in Africa has beenfound to frequently contain far more fattyacids, sometimes more than 1 5%: Processingpractices of small-scale palm oil producers inthe Kwaebibirem District, Ghana: A diagnosticstudy, C. Osei-Amponsaha et.al. NJASWageningen Journal of Lice Sciences, July201 2, core.ac.uk/download/pdf/82465469.pdf.Refining palm oil with a high fatty acid contentwould result in a smaller proportion of ediblepalm oil and a greater proportion of PFAD.

93. Biomass Sustainabil ity Standards – aCredible Tool for Avoiding Negative Impactsfrom Large-scale Bioenergy?, Biofuelwatch,Global Forest Coalition and Econexus,January201 4,biofuelwatch.org.uk/201 4/biomass-sustainabil ity-standards-briefing/

94. Adding Fuel to the Flame: The real impactof EU biofuels policy on developing countries,ActionAid, 27th March 201 3,actionaid.org/sites/fi les/actionaid/adding_fuel_to_the_flame_actionaid_201 3_final.pdf

95. Land grabs for biofuelsdriven by EUbiofuels policies, Carlo Hamelinck , Ecofys,commissioned by e-Pure, July 201 3,https://www.ecofys.com/fi les/fi les/ecofys-201 3-report-on-land-grabbing-for-biofuels.pdf

96. European Parl iament resolution of 4 Apri l201 7 on palm oil and deforestation ofrainforests (201 6/2222(INI)),europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P8-TA-201 7-0098+0+DOC+XML+V0//EN

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