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Green Fuels, Green Skies Competition

Stakeholder enquires and responses

Ref Question Response

1 What does the Government most want from the competition? The key objective for this competition is to Support the development of the UK SAF sector towards the deployment of innovative SAF production technologies at commercial scale that are capable of reducing emissions from the aviation sector in the UK within the near-term.

2 Is a fuel with waste plastic as a feedstock able to qualify for this competition?

Non-renewable feedstocks are only eligible for support under this competition where they align with the “recycled carbon fuel” proposals provided in the Targeting Net Zero Consultation available here. This means that Refuse-Derived Fuel (with a >25% biogenic content) or industrial waste CO gases are able to apply for GFGS support, but projects that plan on using waste fossil feedstocks that do not meet these Consultation definitions would not be eligible for support.

We would however encourage plastics to fuel developers to respond to the Consultation outlining the GHG savings you expect the fuel to meet, and the methodology you have used to calculate this. DfT will then be able to consider this evidence as part of the government response. The Consultation is now open and closes at 11.45pm on 23 April.

Please note that the use of provisions outlined in the Targeting Net Zero consultation as guidance for applicants for the GFGS competition does not indicate a fixed policy position under the RTFO. All outcomes of the consultation are subject to normal legislative procedures and as a result there is no guarantee fuels supported through this competition will be eligible for future RTFO support. However, given time frames for the Consultation we do not expect this position to be changed for the GFGS application process.

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3 In the guidance documentation there is mention that “Segregated waste fats/oils are not eligible” but under the feedstock status link UCO is listed in the table 3 as Double counting feedstock and eligible feedstock. Please could you confirm if UCO can be considered as a feedstock for GFGS competition?

Used Cooking Oil is a segregated oil, and is not eligible for development fuel RTFCs, and therefore is not an eligible feedstock for the GFGS competition. We note that Table 3 of the RTFO feedstock list (https://www.gov.uk/government/publications/renewable-transport-fuel-obligation-rtfo-guidance-2021/list-of-feedstocks-including-wastes-and-residues-year-2021--2) is a list of feedstocks that are eligible for double-counting under the RTFO – it is not a list of feedstocks eligible for development fuel RTFCs.

4 Is there a limit in terms of potential companies to be involved in a consortium? We are aware that there should be a company leading the consortium, but we wonder if there could be some other companies supporting other activities? Also, there is a limit in terms of academic institutions to be involved?

There are no limits to how many organisations (commercial or academic) may be involved in a consortium for the GFGS Competition. Please note, that the applications will be evaluated on the scoring criteria detailed on Page 12 of the guidance document which includes details of the skills and experience of the project team, plus appropriateness of project management and governance structure. The consortium should provide a robust justification for the role of each consortium member.

5a The guidance states that purchased goods and services to build and commission the proposed plant are ineligible. However, we believe this refers to a commercial plant that would be built after the competition period. In our case, our proposal would include the construction and operation of a pilot plant to demonstrate the technoeconomic viability of these technologies. We would like to know if this would be eligible from the feasibility stage funding pot.

The Competition aims to directly support activities that are crucial in the development of FOAK Commercial and Demonstration scale SAF plants in the UK. Funding is expected to provide support to progress projects to the point that they are both investment and construction ready as soon as possible after the end of the Funding Period. The competition will not provide funding for construction costs, however a range of plant design and modelling work, procurement activities, studies and assessments are eligible. Please see page 9 of the guidance document alongside Appendix D for further details on eligible and ineligible costs.

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Ref Question Response

5b As stated in Question 5a, we now intend to build and operate a pilot plant (TRL 5) to demonstrate the technoeconomic viability of these technologies. From the guidance provided, we understand this would be classified as a feasibility study.

Looking at Appendix D, “Technical reviews, in-depth research and feasibility studies” are eligible activities. Our view is that operation of the planned pilot plant constitutes in-depth research and would therefore be eligible.

Also in Appendix D, “Purchased goods and services to build and commission the proposed plant” are ineligible. However, we understand that “the proposed plant” would be a commercial plant based on the information included in the guidance document. In our case, we are talking about a pilot plant to carry out in-depth research.

Our question is: Can the construction of the pilot plant be eligible for GFGS funding given that its operation will constitute in-depth research to advance the technology?

Work eligible for funding under the GFGS will have to directly support the project development lifecycle stages (feasibility, pre-FEED and FEED) of the proposed plant, which in turn must be within the TRL 6-8 range.

While we welcome applicants applying for funding to develop feasibility studies for a TRL 6-8 plant in advance of completion of a plant at an earlier TRL; any work that is clearly designed to primarily support the development of the plant outside the GFGS TRL range as a priority should not be expected to be eligible for funding support. Unfortunately, this means that “technical reviews, in-depth research and feasibility studies” would not extend to allow funding of the construction of a pilot plant. Final decisions on a project’s eligible work, TRLs and project lifecycle status will be made during the assessment process.

6 We understand funding will be available from August 2021 (expected) to 31 March 2022. According to our current plans, the pilot plant would need to be operated for a period of time after the end of the GFGS grant. Because we and our partners would co-fund the project, this is not an issue for us. However, not all results from the pilot plant would be available within 15 days of the end of the grant as requested in the guidance. We would like to know if our feasibility project would be eligible in the understanding that results would be provided approximately 3 months after the end of the grant period. Of course, should the GFGS grant be awarded to us, we would have a contractual obligation to provide all agreed deliverables on completion of operation of the pilot plant.

The outcomes of the projects supported by the competition and findings of any studies undertaken are an important element in helping the government to understand the sector and whether the Competition objectives have been achieved. As per the competition guidance document it will be necessary for projects to provide a financial and narrative report of work undertaken within 15 days of the end of the project (i.e. by 15 April 2022). However, the Department for Transport understands that work on projects is likely to continue outside the competition timeframe and projects may also be required to participate in future benefit reviews at a later date.

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Ref Question Response

7 The guidance document shows these typical outputs and outcomes for the feasibility lifecycle stage (lifecycle stage table):

However, there is no information on the degree of attainment that a feasibility study must reach regarding the ASTM SAF pathway certifications listed in Appendix A of the guidance document. Can you please provide information on this topic?

There is no direct link between project lifecycle stage (e.g. feasibility, pre-FEED and FEED) and the ASTM certification status, nor an expected degree of attainment towards ASTM certification for any given project lifecycle stage. However, please consider the eligibility criteria for this competition, which states that projects should either

(i) involve fuels that are already ASTM certified, or (ii) (ii) show the relevant SAF pathway is currently engaged with the ASTM

certification process, or (iii) (iii) provide clear evidence of the fuel’s future potential to be blended with Jet

A-1.

Thus, as much as possible in the relevant questions in the application form, please explain how your feasibility study will aid in demonstrating (i), (ii) or (iii).

8 Regarding the lifecycle GHG savings, can you please provide further detail on the system boundary that should be considered for this lifecycle assessment? Is this to be based on the CORSIA methodology?

The system boundary and GHG methodology that is to be used is set out in the UK’s RTFO Guidance documentation here, but applicants should also include the changes proposed in the March 2021 RTFO Consultation here (which include changes to GWPs, CHP allocations and inclusion of waste fossil feedstock counterfactual emissions). A summary of the key points will be available from 12th April, when a slide-deck will be distributed after a GHG workshop for applicants is hosted. Although very similar to the RTFO, the CORSIA methodology is not to be used.

9 Some of the evidence and information asked for in questions in the application form will be explored/developed by project work we are applying for support for under the competition. How should we structure our answers?

Projects should provide the best evidence they have available to answer questions in their application. The strength of evidence provided in applications will be a consideration in the scoring process and projects should strive to provide best available evidence across answers and avoid leaving blanks without strong justification.

However, DfT has an understanding that the type of evidence available to projects will be determined by a project’s current development stage. Due to this, the project’s current development stage will be considered as a factor when considering the type of evidence provided by a project, alongside the quality of the answer when marking certain assessment criteria.

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10 Some of our work will be carried out by an organisation outside of the UK, will this work be eligible for support?

For work that is supported by funding, winning projects will have to provide evidence of at least 1 bid by a UK company for all goods and services acquired above a certain value threshold. Where UK bids are not supplied there must be a strong justification for this reason. All work that has been agreed in advance of the project application will be considered as part of the application process in relation to its potential benefits to the UK economy.

11 What exactly does the GFGS mean by a FOAK? How is this related to the Lifecycle stages?

A project’s status as a First-Of-A-Kind commercial project is defined by the plant achieving Technology Readiness Level (TRL) 8 once operational. TRL definitions and a reference are provided in Appendix B of the guidance document. It should be noted that we consider TRLs to be based on global technology status. TRL 9 is only achieved with multiple full-scale commercial plants achieving proven operations and competitive manufacturing of key enabling technologies. Final decisions on each project’s lifecycle stage and plant TRL level will be made by the assessment panel. It is also expected that every plant between TRL 6-8 will undergo the same broad project lifecycle process. Therefore, lifecycle stages are considered independent of the TRL level.

12 Does DfT expect projects to progress through all or a single life cycle stage during the competition funding period?

Projects that can demonstrate a clear potential to meaningfully progress their projects during the funding period can be expected to perform well in the assessment process. Therefore, a project that is able to show how it would clear 1 or more lifecycle stages would likely be able to demonstrate this requirement effectively. However, DfT understands the development periods of projects may extend beyond the competition’s Funding Period so meaningful progress may not necessarily involve the completion of a full lifecycle stage. Due to this there is no absolute requirement to complete a lifecycle stage for winning projects, unless projects are awarded funding based on the claim that they will manage to do so.

13 Can DfT provide a list of companies that responded to the UK winter industry survey for this competition?

To ensure confidentially, DfT cannot provide a list of survey respondents, however a list of interested organisations in this competition that have agreed to share their public details will be made available via the competition website.

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Ref Question Response

14 I am aware the fund will support a feasibility study, does that mean the call will fund just a feasibility study or would additional work be required as part of the competition conditions, e.g. a pilot project? We are interested in using bio-H2 and bio-CO2 to produce jet fuel.

Typical outcomes expected of a Feasibility study have been outlined in Appendix C of the Competition guidance document. All work supported by the GFGS should be designed to primarily support the development of a plant within the TRL 6-8 range (please refer to question 5b for further details) and there is no expectation of pilot project activities for applicants who request support for a feasibility study. However, while applicants should note that the “credibility of the technological approach” is an important factor within the assessment process, we welcome applicants applying for funding to develop feasibility studies for a TRL 6-8 plant in advance of completion of a plant at an earlier TRL.

15 Our project, as part of the front end processing, generates a stream of reject plastic, that is non-recyclable but has an energy content that would be recovered in an EFW plant. At present we are counting the LCV based energy value and the associated CI for processing this stream within our boundary, and deducting this CI increment from our main product CI. Is this a valid approach? Would this also be acceptable for the non-biogenic calculation?

As per the GHG methodology guidance provided in the GFGS application form, Appendix H and Stakeholder Briefing pack (from 13.04.2021), the GHG calculations should use LHV energy allocation where there is a main output product and other co-products leaving your process system boundary over which the GHG emissions up to that point need to be split. If an output from your system boundary is a waste or residue (following the definitions of a waste as in the RTFO), no GHG emissions should be allocated to this output waste/residue stream. In either case, it is not appropriate to apply a CI deduction for the plastics from the main product emissions (this is would be a different GHG methodology to that used by the RTFO and GFGS). Please also be very clear where your system boundary is being drawn, and whether this stream processing lies within or outside of your system boundary. The same approach should be followed for the non-biogenic consignment calculation as for the biogenic consignment calculation.

16 what exactly is meant by MSW being ineligible prior to separation/recycling but RDF eligible? For example, if a plant takes in MSW but includes a front end facility to recover metals and other recyclables, how should that be treated?

Projects that plan to include MSW treatment into eligible RDF as part of their plant design will be eligible for support, providing the design plans to include MSW sorting/treatment are sufficiently evidenced during the assessment process.

17 Can you tell me when a successful grant is paid please? Is it pre expenditure or past? If the latter can you tell me when please?

The Green Fuels, Green Skies grant funding will be paid in arrears. Applicants can request payment in instalments between project start and end (March 2022). These instalments should be on completion of pre-agreed milestones. To submit claims associated with milestones, the grantee will provide their Monitoring Officer with evidence of the completed milestones. This is so that DfT can ensure funding provided is for eligible work completed.

18 Will applicants be allowed to have mainland European partners in their consortium?

The proposed plant must be located in the UK. Organisations based outside the UK may still be part of the project and project consortium.

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19 Can the final lifecycle emission figure (gCO2e/MJ) include carbon emissions avoided within the boundary, associated with the diversion of waste away from landfill or incineration for example?

The GHG methodology to be followed is as set out in the GFGS application form, Appendix H and Stakeholder Briefing pack from 13.04.2021.

• For biofuels or RFNBOs, there are no emissions arising or avoided emissions from diversion from counterfactual uses to be considered.

• For waste fossil feedstock consignments (meeting RTFO Consultation recycled carbon fuel definitions), the GHG methodology in the Targeting Net Zero Consultation is to be followed. For RDF feedstocks, EfW incineration to power at 26% efficiency is the only counterfactual to be used in the calculations. The Targeting Net Zero Consultation proposed methodology means that fuel processing + combustion emissions are assumed to cancel out the counterfactual emissions (from the EfW power plant), so applicants only need to account for the additional emissions from displaced grid electricity (using the 2028 grid factor). Landfill is not the specified counterfactual in the Targeting Net Zero Consultation, so should not be considered in the GHG methodology (even if in reality the counterfactual use is currently landfill).

20 Could you please confirm that plastic waste is an eligible feedstock? Non-renewable feedstocks are only eligible for support under this competition where they align with the “recycled carbon fuel” proposals provided in the DfT Targeting Net Zero Consultation. For plastic wastes, these would therefore only be eligible if they meet the definition of a Refuse Derived Fuel (EWC 19 12 10, or EWC 19 12 12 but non-hazardous), and the biogenic content is greater than 25% on a LHV energy basis.

21 Would joining the competition be possible if technology is licensed not developed inhouse?

This is allowable. DfT expects consortiums to enter the competition and for some projects identifying suitable technology providers may be a core focus of funded project work.

22 Being a UK call, are Mainland Europe Partners allowed/Will applicants be allowed to have mainland European partners in their consortium?

The lead applicant organisation must be registered in the UK, and the project itself must be located in the UK. But, organisations based outside the UK may still be part of the project and project consortium.

23 Does the demo plant have to be physically located in UK or it can be in other country under the consortium agreements?

The proposed plant must be located in the UK. Organisations based outside the UK may still be part of the project and project consortium.

24 For a feasibility project intending to carry out in-depth research, is the construction of a pilot plant eligible for funding?

Please refer to questions 5a & 5b of the FAQ on the competition website

25 How will feasibility study applications be scored - still 50% weighting on Project Implementation?

Yes. The initial weighting for each assessment criteria are set. However, projects currently at the FEED-FOAK stage of development will be marked preferentially for some scoring criteria during the scoring process.

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Ref Question Response

26 is the 2m for feasibility, part of the overall 15m pot? Yes, the £2m for feasibility studies is part of the £15m pot.

27 is the funding per project or is it the overall amount available? £15m is the overall amount available for all projects for this financial year and successful applicants will receive a share of this funding. While DfT expects to support more than one project there is no maximum or minimum funding restrictions per project.

28 What is the maximum amount of funding available to one project and is there a minimum private sector matching contribution (% of total cost)?

While there is no maximum award, the total grant funding available is £15m. There is also no minimum award threshold and no guarantee that the full £15m will be awarded.

The DfT has set the maximum aid intensity at 100% of total costs although proposals that include match funding will be scored preferentially, with increased match funding able to score higher marks. The competition board may rely on funding intensity to decide funding allocation in marginal cases. All applications for funding are subject to assessment and there is no guarantee that successful applicants will be offered the full amount they have applied for.

29 Given the fixed end date for projects, will costs incurred "at risk" during negotiations be eligible for reimbursement?

Project funding will be available for work completed during the competition “Funding Period”. The Funding Period for winning projects will begin after the finalisation of project specific grant conditions and all relevant grant agreement paperwork. Due to this the Funding Period start dates may vary between winning projects. However, for the purpose of their applications, projects may assume their Funding Period begins on 31 July 2021.

30 Are projects previously supported under the F4C/ABDC eligible for support under the GFGS? Should focus on new entrants not be a better approach to help companies that have not previously benefited?

The GFGS is an open and standalone competition so that it is possible to apply or to have applied for other grant scheme funding so long as Subsidy Control rules are not breached. This may mean a single eligible project applies for grants from two schemes up to the maximum subsidy control intensity, or that grants are applied to different elements of a project, so long as the base eligible costs do not overlap. In particular, projects previously or currently being supported under the Future Fuels for Flight and Freight Competition (F4C) or the Advanced Biofuels Demonstration Competition (ABDC) are required to demonstrate how funding through this competition will directly support different work even if for the same plant development project.

31 What is the minimum production p.a. of what you'd consider to be "commercial scale"

There are no specific minimum limits set, since what is commercial scale will vary by processing technology and by feedstock. Evidence should be provided as part of your application to support your stated scale and development status. Final decisions will be made during the assessment process based on evidence provided.

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32 Should the project be producing only SAF, what about other products in addition to SAP like Green Diesel or Naphtha?

There is an understanding that projects may coproduce other products such as energy or fuel for other transport modes and this is considered within the assessment process. However, projects should focus on the production of SAF, with a greater SAF focus expected to be able to perform well within the assessment process.

33 Cellulosic Sugar Starches to Jet Fuel is an eligible pathway? As with any route involving intermediate products, the original feedstocks from which the intermediate sugar/starch products have been derived must have the potential to qualify as a double-counting ‘development fuel’ under the RTFO. For example, if the original feedstock were forestry residues (that also meets other sustainability criteria) that are then hydrolysed into cellulosic sugars then this would be eligible. Whereas if the sugars are derived from a single counting feedstock, or derived from a double-counting feedstock that is not eligible for 'development fuels' support (e.g. derived from non-food energy crops or from segregated oils/fats), they will not be eligible for the GFGS. The current single/double-counting status of many feedstocks can be found here: https://www.gov.uk/government/publications/renewable-transport-fuel-obligation-rtfo-guidance-2021/list-of-feedstocks-including-wastes-and-residues-year-2021--2.

34 What about algae? or algae by-products?

There is no mention of algae-based waste lipids in the RTFO eligible feedstock... are we just not eligible? Or can we try to make a case that this feedstock could fit under one of the other classifications (IE food waste or salmon oil)?

As with any route involving intermediate products, the original feedstocks from which the intermediate algae product has been derived must have the potential to qualify as a double-counting ‘development fuel’ under the RTFO. For this competition therefore, Algae may be considered eligible where it has been grown using an eligible feedstock. For example, this may include if it had been grown using waste industrial gases meeting the new targeting Net Zero Consultation definition for development fuel support, or if it had been grown using atmospheric CO2.

We would encourage projects considering algae derived SAF to reach out to the RTFO unit (RTFO-compliance@dft.gov.uk) by 7 May for a review of their chosen pathway.

35 Please can you clarify the position on TPO, this is a qualifying dRFTO feed (where the consultation starting position is that the RCF would not count). We understand the DfT is keen to see applications for development fuel derived SAF including TPO. Thanks

In line with the proposals provided in the Targeting Net Zero Consultation, tyre pyrolysis oil (TPO) will not be considered eligible for this competition.

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36 Power to Liquid (CO2 + Hydrogen +FT). Is this pathway eligible for the competition? This is the technology mentioned in PM’s announcement.

Renewable Power to Liquids is an eligible pathway providing the process feedstocks and power input and other characteristics comply with the competition's eligibility criteria - so for Renewable Fuels of Non-Biological Origin, only eligible renewable power/heat sources must be used as per RTFO guidance. To this end projects should in particular note the renewable energy additionality requirements for the RFNBO pathway as set out in the Targeting Net Zero Consultation. Non-renewable power to liquids projects will not be eligible (i.e. those that use CO2 + fossil or nuclear power-derived hydrogen). Any use of biomass power derived hydrogen would count as a biofuel pathway, subject to the usual eligibility criteria for biofuel routes.

37 Can CO2 from air as a carbon source for SAF be allowed? Yes, CO2 from Direct Air Capture is an eligible feedstock for this competition. However, projects should note the renewable energy requirements for the RFNBO pathway as set out in RTFO Guidance, and the new additionality rules as per the Targeting Net Zero Consultation.

38 RDF has a wide-ranging specification. Can you be more specific? Any official standard?

The targeting Net Zero Consultation specified that RDF must have a biogenic content >25% on a LHV energy basis to be eligible, and that: "suppliers must demonstrate that the feedstocks are derived from facilities that have adequate separation processes to remove recyclable dense plastics, and that the resulting feedstock is categorised as refuse derived fuel (e.g. EWC 19 12 10)."

An additional RDF categorisation that would be permissible is meeting the specifications given under EWC 19 12 12, provided the material is non-hazardous.

39 How will Hydrogen be treated - process consumable or feedstock? Where the use of hydrogen contributes to the end energy content of the fuel it must be considered a feedstock. Please note that applications should consider how all feedstocks proposed for use meet GFGS eligibility criteria definitions.

If hydrogen is used in a manner (for example for de-sulphuring), such that the hydrogen does not end up in the finished fuel, then the hydrogen may be considered a process input and may be fossil derived. However, the GHG calculations will need to include the emissions associated with the production of the hydrogen used.

We would encourage projects uncertain about the categorisation of their Hydrogen input to reach out to the RTFO unit (RTFO-compliance@dft.gov.uk) by 7 May for a review of their chosen pathway. Final decisions will be made during the assessment process.

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Ref Question Response

40 What if hydrogen is a by-product from a refining process? Please see the answer to question 39 above. It is necessary to consider how this hydrogen is being used in the proposed jet fuel chain. If the hydrogen is only a process input for system heating or final fuel upgrading, then it should be considered as a process consumable (with a GHG intensity to include in your fuel GHG calculation when it crosses the system boundary), and the categorisation of the fuel as a biofuel, RFNBO or RCF will not change. However, if the hydrogen is a feedstock contributing to the fuel’s energy content, then the system boundary, GHG emissions calculation and competition eligibility criteria checks will need to go back up to the source of the hydrogen and its original feedstocks, and these original hydrogen feedstocks (along with any other feedstocks) will determine the categorisation of the fuel.

"By-product" is not a defined term under the RTFO. Either the hydrogen is a product or co-product from a process, or it is a waste/residue (i.e. user discards/intends to/required to discard, not purposely mixed to create a waste, nor processes modified to create more). However, fossil derived hydrogen from a refining process, even as an industrial waste gas, is not included within the "recycled carbon fuel" definition proposed in the Targeting Net Zero Consultation (only waste industrial gases containing CO are included). Therefore, if this hydrogen is used as a feedstock in the jet production process this route will not be eligible for the GFGS. If the hydrogen is only used as a process input, then the resulting jet fuel could still be eligible for the GFGS competition provided other criteria (including GHG emissions) are met.

The GHG emissions to be assigned to the hydrogen process input should be calculated based on LHV energy allocation across the relevant refinery and upstream fossil fuel chain emissions (for example, CertifHy produced an estimate of ~23gCO2e/MJLHV H2 for naphtha cracking - the result shown in Figure 5, based off input data in Table 11: https://www.certifhy.eu/images/project/reports/Certifhy_Deliverable_D2_4_green_hydrogen_definition_final.pdf).

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41 Can blue hydrogen be used as part of a process input and count toward the overall GHG calculation of end product fuels?

"Blue hydrogen" is understood to be reforming of fossil natural gas to hydrogen with carbon storage and sequestration (CCS). If your route is relying on hydrogen as a process input, you should take into account these additional GHG emissions associated with the hydrogen when it crosses the jet fuel chain system boundary (emissions from the hydrogen production, distribution and upstream gas sourcing).

However, if the hydrogen is a feedstock input contributing to the fuel’s energy content, the GFGS eligibility criteria decision has to go back to the original feedstocks that produced the hydrogen. If this hydrogen is derived from fossil natural gas, coal or oil, then this hydrogen is not an intermediate "recycled carbon fuel" as per the targeting Net Zero Consultation, so the resulting jet fuel will not be eligible for the GFGS.

We would encourage projects uncertain about the categorisation of their Hydrogen input to reach out to the RTFO unit (RTFO-compliance@dft.gov.uk) by 7 May for a review of their chosen pathway. Final decisions will be made during the assessment process.

42 What would be the CI baseline for manure? Would it be for example biogas production or would be de direct emissions without composting?

There are technically feasible routes that could go from animal manure into AD biogas, upgrade into biomethane, and then convert the biomethane into jet fuel (e.g. via syngas then FT synthesis). We would ask you to follow the RTFO guidance in terms of drawing the system boundary around the whole supply chain from the original manure feedstock to aircraft refuelling. There are also default values available in the RTFO Carbon Calculator and in recent JRC reports (referenced in Appendix H and the Targeting Net Zero Consultation) for the GHG emissions associated with various biomethane pathways, including from wet and dry animal manures, that may assist.

Note that GHG methodology rule changes proposed in the Targeting Net Zero Consultation ought to be followed (these proposals include removing the CHP export credit by reverting to energy allocation for electricity; allowing the use of a GHG emissions credit equivalent to the emissions avoided as a result of improved manure management, i.e. 45gCO2e/MJ of manure used in AD; and retaining the requirement to report separate biomethane consignments separately even when co-digesting).

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43 It is my understanding that combustion emissions of RCF are not accounted for. Is this correct?

Under the Targeting Net Zero Consultation, a simplified GHG methodology has been proposed for eligible RCFs. The proposed methodology means that feedstock carbon emissions released during transport fuel processing plus during transport fuel combustion in use are assumed to cancel out the carbon emissions in the counterfactual use (from a Energy-from-Waste power plant), so applicants only need to account for the additional emissions from displaced grid electricity (using the 2028 grid factor), and they do not need to account for the RCF combustion emissions. This simplified GHG methodology only holds where the counterfactual does not include CCS.

44 Can you clarify how you will account for the carbon intensity of flue gas emissions? In 2030 will you assume 4 CCS clusters exist in the UK and therefore the baseline use of the flue gas is storage?

By flue gas emissions, this is assumed to mean waste CO2 (along with N2 and other impurities) being emitted from either biomass or fossil-fuelled industry or power plants. This CO2 can be used as a feedstock in some eligible fuel chains, e.g. if combined with renewable H2 to create syngas for FT synthesis to RFNBO jet. The emissions associated with the extraction and collection of the CO2 (including the additional energy and chemicals used in CO2 capture) are to be included at the start of the RNBO fuel chain calculation (Section 7.71 of RTFO Process Guidance).

However, if the question had meant waste CO streams as a flue gas before flaring, please see the Targeting Net Zero Consultation regarding the accounting of waste fossil industrial CO gases under the proposed RCF GHG methodology, as this requires applicants to provide evidence regarding the appropriate counterfactual to use for this CO gas (a flaring counterfactual would avoid the need to include any grid displaced emissions in the GHG calculation, but a heating counterfactual would incur significant emissions).

The UK-wide counterfactual use of RCF feedstocks in 2030 is assumed to remain EfW without CCS, despite the reality that the counterfactual use of some RCF feedstocks may start to be with CCS in certain clusters by 2030.

We would encourage projects uncertain about their input CO2 or CO gases to reach out to the RTFO unit (RTFO-compliance@dft.gov.uk) by 7 May for a review of their chosen pathway.

Please note that the rules as set out for the purposes of this competition do not in themselves determine the direction of future RCF or RTFO policy. A future position will be set out in the upcoming Government response to the Targeting Net Zero Consultation and beyond.

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45 Just to double check that avoided/displaced emissions from incineration or landfill for example can be included in the emission boundary (counterfactual), enhancing the potential emission savings?

No, there will be no enhancement of GHG savings, only a potential worsening for some waste fossil fractions.

For biofuel consignments, the GHG methodology in the RTFO guidance should be followed. This does not have any avoided or displaced emissions from incineration or landfill.

For eligible "recycled carbon fuels" (RCF) consignments as defined in the Targeting Net Zero Consultation, although there are zero emissions up to the point of collection of the waste feedstock (where the system boundary starts), the waste fossil feedstocks are also given the displaced emissions from being diverted to fuels from a counterfactual use. The counterfactual to use for the fossil fraction of Refuse Derived Fuel (RDF) is Energy-from-Waste power generation at 26% efficiency (no CHP or CCS), so the emissions from additional grid electricity generation (in 2028) is given to the starting feedstock fraction for the 2030 jet fuel GHG emission calculation. Landfill is not proposed as the counterfactual in the Targeting Net Zero Consultation counterfactual, so should not be used.

There are some additional evidence requirements and possible alternative counterfactuals allowed for waste fossil industrial gases containing carbon monoxide. Note the new methodology in the Targeting Net Zero Consultation is not confirmed in legislation, so meeting GFGS entrance rules is no guarantee of meeting the finalised RTFO rules.

Note that for any applicants familiar with previous DfT sustainable fuel competitions, the Future Fuels for Freight and Flight Competition (F4C) only reported waste fossil feedstock counterfactual emissions alongside the assessed direct fuel supply chain emissions. In contrast, the GFGS requires the inclusion of these counterfactual emissions within the fuel GHG calculations, to check eligibility for GFGS funding and for assessment scoring purposes.

46 Does the weighted average need to meet the 70%? Yes, First-Of-A-Kind (FOAK) commercial scale plants (TRL 8) must have the potential to deliver a jet fuel output with a minimum 70% saving in the weighted average lifecycle GHG emissions compared to a fossil fuel comparator of 94gCO2e/MJ in 2030. Demonstration scale plants (TRL 6-7) do not have to meet this requirement, but must report their expected GHG emissions from the demonstration plant, and demonstrate how a future commercial FOAK plant operating in 2030 using their technology would be able to meet this 70% GHG saving threshold. Projects that cannot demonstrate that 70% GHG savings can be met by a FOAK commercial plant in 2030 will not be eligible.

The correct method of calculating a weighted average of the fuel consignments is to multiply each consignment's emissions intensity gCO2e/MJ LHV jet by the consignment jet fuel MJ LHV, sum these values, then divide by the total MJ LHV of all jet fuel consignments.

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47 It appears that the GHG emissions calculations may favour early stage pathways that claim use of options like CCS that may or may not be available at time of implementation. Is there a risk that this will bias the scoring away from pathways that are more likely to contribute to SAF production in a relevant timeframe?

The assessment process has to consider a wide number of potentially balancing factors relating to a project's suitability for support. Within this, it is unavoidable that certain characteristics may favour certain projects, however DfT has strived to ensure the assessment process is as balanced and as fair as possible within the competition framework. In relation to the GHG assessment process for instance, all projects have been asked to calculate their GHG emissions calculations against a standard reference year (2030) - this avoids disadvantaging plants that may start operations earlier in the mid-2020s before CCS is available. It should be noted that 2030 is sufficiently far in the future where CCS could reasonably be expected to have been installed at major project sites were they to choose to do so.

If a project is relying on the use of CCS for GHG compliance, robust evidence will need to be provided that this additional equipment has been factored into the technical design work, costings and business case, downstream contracting and project management risks.

48 You mentioned 'industry experts' on the assessor panel. What confidence do we have that detailed technical information shared on IP and processes will not leak into industries that may have a competitive element? Exactly what industries are these experts in?

As is standard practice with competitions of this nature, all expert panel members will be asked to sign a conflict of interest and terms of confidentiality agreement before provision of application material.

49 Concerns over confidentiality. What assurances does an applicant have over security of data shared?

IP developed within the project remains the property of the applicant/consortium. Any information provided to the DfT may be subject to the Freedom of Information Act 2000, the Environmental Information Regulations 2004 or other legislation. The DfT will work with applicants to ensure that no commercially sensitive information is disclosed as far as possible under the law.

50 When will Appendix E (projected cash flow) be available? We expect the final templates to be made available via the competition website imminently.

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51 At least one of the links in appendix H (Ecoinvent ISCC database) does not take you to the document. Can you resend the links?

The Appendix H Excel workbook has been updated on the GFGS website. We have also updated the CO global warming potential (GWP) IPCC link, and included a GWP for hydrogen, and a further useful JRC reference.

Please forward any similar issues to GFGS@ricardo.com so that these may be addressed.

As stated in the Stakeholder Briefing pack (from 13.04.2021), we would recommend use of updated JEC WTT v5 datasets in the first instance, as these align to REDII default values and the latest GWPs matching those in the targeting Net Zero Consultation. Applicants could also look at the Biograce calculator, provided the correct set of GWPs are selected. The Ecoinvent ISCC database is to be used as a last resort, as this is based on older GWPs and GHG methodologies that do not necessarily align with those now required for the GFGS - calculations of material/chemicals/energy GHG emissions bottom-up may be preferable to using this 2015 ISCC database.

52 Will these slides be shared afterwards? Can I record or will there be a post version?

We have made FAQs from this session available alongside the full guidance and existing FAQs at ricardo.com/GFGS. This will be constantly updated as new questions come through, however no recording of the stakeholder session is available.

53 I can't see the FAQs / slides on ricardo.com/GFGS yet. Please could they be made available today?

N/A

54 Can you please clarify the rationale behind requesting [recycled carbon fuel] feedstock [contains] bio-content?

The GFGS eligibility criteria are aligned to the proposed RTFO “development fuels” definitions in the Targeting Net Zero Consultation, and therefore wholly fossil non-recyclable plastics are not eligible for the GFGS. As stated in page 32 of the Consultation, regarding the definition of which recycled carbon fuels are proposed for support under the RTFO development fuels sub-mandate “it is the intention that support will only be provided where solid wastes are mixed with organic waste to help unlock more biomass for transport use. It is proposed that solid feedstocks should have at least a 25% content, by energy, of biogenic waste.”

We would encourage plastics to fuel developers to respond to the Consultation outlining the GHG savings you expect the fuel to meet, and full details of the methodology you have used to calculate this. DfT will then be able to consider this evidence as part of the government response. The Consultation is now open and closes at 11.45pm on 23 April. However, given time frames for the Consultation, we do not expect the position on GFGS feedstock eligibility to be changed for the GFGS application process. Please also see the answer to question 2 of the Stakeholder enquiries document.

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55 We currently gasify the non-recyclable fraction of municipal solid waste and municipal sewage sludge into syngas, before syngas combustion in an engine for power generation. We plan to install a small test FT reactor onsite to use a slip-stream of the syngas to produce SAF, to validate previous experiments. We require investment to build the test plant, but it would be operational by March 2022, as we have already completed detail design. Would this be eligible for the GFGS?

Unfortunately, due to resourcing constraints we are unable to provide detailed support to all projects in advance of application. However, we fully encourage any applicant seriously considering developing plans for commercial scale SAF production in the UK to review the GFGS and consider how and where it can support its aims within the eligibility criteria.

On the above we would highlight that it is up to projects to ensure that their proposed project aligns with the competition's eligibility criteria on TRL levels and available work. To this end we would reiterate that the GFGS cannot support installation or construction activities or any work that is clearly designed to primarily support the development of a plant outside the GFGS TRL range. However, we do welcome applicants applying for funding to develop feasibility studies for a TRL 6-8 plant in advance of completion of a plant at an earlier TRL, noting that final decisions on eligible work and project statuses will be made in the assessment stage. Please consider responses to questions 5a & 5b of the FAQ for further details.

56 We would like to submit a proposal focused on developing and demonstrating (TRL6) a SAF pilot-scale plant based on gas fermentation process combined with chemocatalytic conversion. The project will transition the technology from TRL4 to TRL6, with most of the funds spent on CAPEX for the development of the pilot facility. The pilot demonstration will generate data that will feed into the FEED of a larger-scale demonstration plant that will subsequently be constructed, commissioned and validated, ahead of the design and construction of the commercial scale plant. Can you please confirm if the proposed project is in scope for the GFGS competition?

Please refer to questions 5a & 5b of the FAQ above.

57 Is CAPEX for the pilot plant development an eligible project cost? Please refer to questions 5a & 5b of the FAQ above.

Capital costs relating to installation/construction and earlier-stage development costs relating to a pilot plant (TRL 5 facility) are not eligible uses of GFGS competition funds.

58 Are Catapults/RTOs eligible to lead projects for the Green Fuels, Green Skies Competition?

To be eligible for the GFGS competition, the project lead must be a UK registered company.

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59 What is the match funding required for each type of partner? (i.e. RTO, SME, Large company)

As outlined in Question 14. DfT has set the maximum aid intensity at 100% of total costs although proposals that include match funding will be scored preferentially, with increased match funding able to score higher marks. The competition board may rely on funding intensity to decide funding allocation in marginal cases. All applications for funding are subject to assessment and there is no guarantee that successful applicants will be offered the full amount they have applied for.

60 What are the eligible overheads? The GFGS funding will cover up to 20% of administrative overheads.

61 We would like to use capture CO2 as feedstock, could you please advise if we should list the electricity used for H2 production or CO2 capture? Also, we have assumed that we just need to list how much CO2 and H2 to be used for our project, can you confirm whether this is correct?

For the purposes of this answer, we assume the route in question is electrolytic H2 + captured CO2 being converted to jet, rather than another H2 production route with minor electricity process inputs.

The electricity used for electrolysis must be quantified and described clearly, as this determines the fuel renewability, fuel categorisation and GHG emissions calculations, and therefore GFGS eligibility. Renewable electricity additionality rules for RFNBO routes in the recent Targeting Net Zero Consultation should be followed.

The electricity used for CO2 capture should also be quantified and included as part of the GHG emissions calculations, as per RTFO guidance for RFNBO routes. The source of the CO2 should be made clear, as should the capture process.

Mass and energy balances in Appendix B should be supplied, which cover all inputs and outputs to the project. GHG emissions calculations in Appendix H will need to be filled using this same project data, but also extending upstream to the generation or collection of the original feedstocks, and downstream to the aircraft fuel tank. More information is therefore required than just how much CO2 and H2 is used.

62 Can companies be part of more than one application? Yes, organisations can participate in more than one application, provided evidence is supplied regarding staff availability in the case of multiple successful applications.

63 Can companies put forward more than one proposal? Yes, organisations can provide more than one proposal for funding to the GFGS. However, applications should be standalone. Final decisions on whether a proposal is standalone shall be made during the assessment process. Projects that are not considered standalone may be grouped at the discretion of the assessors.

64 Please explain the underlying reasons behind the 25% bio-content requirement from system thinking perspective.

Please refer to question 54 on the competition FAQ for further details, and please approach the DfT’s RTFO unit if you have questions regarding the Targeting Net Zero Consultation.

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65 Appendix E: In the “Guidance on cash flow” tab, we are told that “assessors will pay particular attention to the net cash flow for saving/dividends and equity repayment, and bidders should use the figures in this line to explain why a GFGS grant is required.”

Since the GFGS grant is required to be spent before March 2022 and is only for pre-construction expenses, the need for such a grant is driven not by this line but by the challenge of funding the development to reach Final Investment Decision.

Please could you explain what assessors would expect to see in this line and in our commentary on it, given the parameters of the competition?

The commercial potential of projects is an important aspect of the GFGS assessment and the cash flow model and the results presented in this line should be used by applicants to underpin their commercial claims within their wider application.

Acknowledging that for most projects these results will carry uncertainty in advance of any Financial Investment Decision, projects should strive to provide as accurate and justified inputs as possible within the model.

In short, projects may consider "why a GFGS grant is required" to relate to the future economic potential that the applicant expects the GFGS grant can help them unlock.

66 Appendix E: The capital investment rows 75-80 stop after 31st March 2024. Our capital investment will continue after this date.

Can we extend these rows to fit our requirements?

Yes. Projects are welcome to adjust the template to suit your specific requirements without significantly adjusting the structure, but please check calculations in the new rows/columns are correct, and any sums over these new rows/columns are also correct.

67 Appendix E: Our project model has 7 revenue and 16 expense line items on the P&L; with only a single line in the template for “other revenue” and three for “other costs”, there will be a loss of detail.

Can we insert additional rows?

Please do add rows/ adjust the template to suit your specific requirements without significantly adjusting the structure. Additional rows/columns are acceptable – provided the information is set out in the order as requested by the overall template. This is to assist the evaluation process. 7 revenue and 16 expense lines is an acceptable level of detail.

68 Application form: Please could you clarify two of the questions on the GFGS application form?

Questions 2.2.9 and 2.2.10 are both phrased in the negative and require yes/no answers. That’s potentially confusing.

Respondents should tick ‘Yes’ to confirm that planned activities have not been previously funded by the DfT (or other public-sector funding) (Q 2.2.9) and ‘Yes’ to confirm that it has not been possible to fund proposed project activities solely from private sector investment on reasonable commercial terms (Q 2.2.10).

69 We add a liquid waste fossil feedstock as part of our process to convert waste biomass into fuels, and some of this fossil feedstock ends up in the final fuels. Our jet fuel is therefore partially renewable. Our pathway has already had a positive indication from DfT that the renewable fraction of our fuel is potential eligible for development fuel RTFCs, based on the waste biomass used.

Please confirm if our pathway and feedstocks are eligible under the GFGS as a partially renewable fuel?

Please see the responses to questions 2, 39 and 40 above.

Liquid waste fossil feedstocks are not included within the "recycled carbon fuel" definition

proposed in the Targeting Net Zero Consultation (only the fossil fraction of RDF and waste

industrial gases containing CO are included). Therefore, given this waste fossil liquid is used

as a feedstock in the jet production process, this route will not be eligible for the GFGS.

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70 Please would you confirm that this waste (sewage sludge) RTFO double counting feedstock is a qualifying feedstock for the competition?

Yes, sewage sludge, as per RTFO definitions is a double-counting biogenic waste, and the resulting jet fuel would therefore have the potential to be eligible for development fuel RTFCs, and hence is eligible for the GFGS.

We note however that sewage sludge FOG (fats, oils and grease) feedstocks, whilst they are also double-counting biogenic wastes under the RTFO, are likely to be classified as a segregated fat/oil, and therefore will not be eligible for development fuel RTFCs, nor the GFGS.

We would encourage projects uncertain about the categorisation of their feedstock to reach out to the RTFO unit (RTFO-compliance@dft.gov.uk) by 14 May for a review of their chosen pathway. Final decisions will be made during the assessment process.

71 Is the GFGS tied to the F4C? The GFGS is a standalone competition. Please refer to question 30 on the competition FAQ for further details.

72 is it possible to apply for another grant at the same time as the GFGS to “hedge bets”?

It is possible to apply or to have applied for other grant scheme funding so long as Subsidy Control rules are not breached. This may mean a single eligible project applies for grants from two schemes up to the maximum subsidy control intensity, or that grants are applied to different elements of a project, so long as the base eligible costs do not overlap. If projects receive a separate funding bid during the application period or while they have a grant offer in place under the GFGS period they should disclose this immediately to the GFGS competition team. They will be required to demonstrate how this alternative source of funding impacts their bid or project and how funding supplied through this competition will directly support different work even if for the same plant development project.

73 Is it correct that the project budget sheet only contains the overall costs per Deliverable/Task, but there is no necessity to split the budget further down into e.g. budgets per consortium partners or specific budget categories, such as staff costs, subcontracting, etc.?

The lead project organisation will be responsible for claiming and then disbursing funds to consortium partners. However, details of eligible spend per project partner and budget categories is helpful to identify appropriate evidence for the tasks/ deliverables within each milestone and strengthens the project case. Please do provide as much detail as possible in the project budget by adding as many rows as necessary linked under claim/ milestone number.

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74 Please provide some additional detail about the eligibility of foreign legal entities in the bid. Could you advise.

• if we (non-UK) might be able to participate (and receive funding) with another non-UK based legal entity,

• if participation and funding is only allowed for UK based legal entities.

• or if a non-UK legal entity could be part of the consortium without being eligible for the UK funds?

The proposed plant must be located in the UK and the project lead must be a UK organisation. Organisations based outside the UK may still be part of the project and project consortium and accordingly are able to claim grant against eligible spend.

75 Do matching funds have to be used for the specific scope of the proposed project or can it be matching funds that contribute broadly to the proposed technology? For example, if we were to propose a feasibility study, does the matching fund have to be used only for the 8-month feasibility study?

All match funding must be used for eligible spend (as defined in the GFGS guidance) for the

proposed project itself and by 31st March 2022. The funding organisation must also pass

due diligence.

Please note that wider funding commitments may still be considered as part of the application, in particular in relation to a project’s future commercial viability. However, they will not be considered as part of the project’s match funding assessment. Final decisions on qualifying match funding will be made during the assessment stage.

76 We have a number of questions on the GHG modelling and associated mandatory spreadsheet. Would you be available for a meeting to discuss?

Unfortunately, while we would like to offer further support to prospective applicants, due to resourcing constraints we are unable to provide detailed support to all projects in advance of their application. In addition, the GFGS is an open competition and in the interests of fairness, we have to ensure all potential applicants must receive the same information. Please make sure to review the resources available on the GFGS webpage. Specifically;

• GFGS Briefing pack

• Stakeholder enquiries (FAQ’s) document available on the GFGS webpage (last updated 10 May 2021 - this document is updated regularly and will continue to be updated for the duration of the application window).

• GFGS Stakeholder session slide pack If you have a question that you are certain has not been addressed within the resources available, in particular the updated FAQ, please send written questions to GFGS@ricardo.com and the delivery partners will aim to respond promptly. Please note that all questions and responses will be included within the competition FAQ’s.

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77 We are preparing to bid for a Feasibility study within the £2m feasibility point. It struck us that appendix E (cash flow model) and appendix H (detailed LCA) are really outputs of a feasibility study. As such, is it more appropriate to provide a high-level assessment of each within a bid, or is the expectation that the full detail would be estimated for the proposal?

Please refer to Question 9 in the FAQ for a general approach to this issue. As further guidance we would highlight that for projects at the earliest stage of development we would still expect to see:

− In their Cash Flow model, projects demonstrate a clear understanding for the factors that impact economic viability, and how their plant could be economically viable. For example, this would include estimates of CAPEX, OPEX and revenues, complete with assumptions.

− In their Green House Gas estimates, projects demonstrate a clear understanding of how the plant could meet the required GHG threshold. For example, this would include explaining the key assumptions, or technological options that allow them to meet the criteria.

78 Why is the formula for the counterfactual emissions from appendix H different than the formula from the regulation document named “Targeting net zero - Next steps for the Renewable Transport Fuels Obligation”?

The 26% LHV efficiency for power generation is the same as in the RTFO Consultation.The grid emissions intensity is a set value for 2028 to be used for the GFGS calculations, but this value is not specified in the RTFO Consultation.The fossil feedstock counterfactual emissions are therefore following the Consultation proposed approach, and have to be factored by the supply chain efficiency, and allocated between jet and co-products, as with any other emissions associated with a feedstock. We cannot therefore see any difference to the RTFO Consultation formula.

79 How will the counterfactual work if applied to imported RCF SAF from other markets? Would the UK counterfactual still apply or a counterfactual local to place of production? If counterfactuals will differ, it will be important from a commercial perspective to evaluate how competitive UK-based RCF SAF production would be with production in other countries (and then export to the UK).

Imports of jet fuel into the UK, i.e. jet fuel production abroad, is not eligible for the GFGS. Imports of RDF feedstock for jet fuel production in UK should, for simplicity and assessment comparability purposes within the GFGS, assume the same counterfactual as for UK RDF, as given in the Targeting Net Zero Consultation. This is not a RTFO policy position.

80 Could you please send the “EcoInvent/ISCC database of GHG emissions” link in appendix H?

Please see uploaded revised version of Appendix H.

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81 We are uncertain about the categorization of Hydrogen (feedstock or process consumable). Could you please review.

1) If the hydrogen is a feedstock, how do we proceed when some of the power used to generate hydrogen via electrolysis may come from the (partially) renewable grid? This could happen when green power supplied under a PPA does not meet the temporal requirement set out in the draft RCF legislation and we need to assume supply of grid power instead. Do we need to complete additional sheets based on hydrogen as a feedstock?

2) If the source of the hydrogen is steam methane reforming, is the emission factor from Ecoinvent (3.7.1 (2020), Market for hydrogen, liquid, ReR) of 2.116 kg CO2eq/kg acceptable?

1) Efforts must be made to ensure that the proposed project will use 100% eligible feedstocks. Where grid power will be used for feedstock hydrogen production, then by financial close, the project would be expected to have secured an appropriate volume of Power Purchase Agreements (with sufficient evidence of additionality) to supply the necessary volume of renewable energy production for this process. Please note that where Hydrogen from renewable power is a feedstock, projects should submit an additional GHG workbook for this RFNBO consignment. We would also highlight that these GHG emissions workbooks should be provided for fuel production in the year 2030. We appreciate that the intermittency of some renewables may create some uncertainty in regards to the future reliability of these PPAs to provide the sufficient volume of energy production required across a whole year. However, we would reassure projects that, for the purposes of the GFGS competition, DfT would expect to take a pragmatic approach to this issue based on a reasonable expectation of the future performance of renewable sources and storage options on the grid under real world conditions, and the understanding that plant proposals provided for the GFGS may undergo reasonable changes in the process of completion and subsequent operations. GFGS applicants will also be at different stages in their project lifecycle, and some projects may not have started considering the source of their renewable power or PPA negotiations. Where applicants in their proposal have incorrectly included a small amount (in total energy terms) of fossil hydrogen feedstock that contributes to the final fuel energy’s content (see questions 39-41), the GFGS team may offer applicants an opportunity to provide (within 5 working days on request): 1. a proposal as to how they would ensure this hydrogen feedstock would be obtained from eligible sources to maintain compliance with the competition’s eligibility criteria; 2. an additional GHG Excel template that covers this new fuel consignment (e.g. renewable power to RFNBO hydrogen to jet fuel). This opportunity will only be offered where this is viewed as proportionate and will be provided at the GFGS team’s discretion. Please note that the use of provisions outlined in the Targeting Net Zero consultation as guidance for applicants for the GFGS competition does not indicate

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a fixed policy position under the RTFO or "draft RCF legislation". In addition, we would highlight that in proposals provided under the consultation, PPAs being used for renewability are only suitable for the support of RFNBO fuels, and not RCF or biofuel consignments that involve input of grid power. All outcomes of the consultation are subject to normal legislative procedures and as a result there is no guarantee fuels supported through this competition will be eligible for future RTFO support.

2) As stated in the guidance notes/stakeholder presentation, we would strongly

encourage applicants to first use the JEC WTT v5 dataset for sourcing emissions factors. https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-reports/jec-well-tank-report-v5. Hydrogen produced from SMR without CCS is likely to have a much higher emissions factor than the unspecified source given in Ecoinvent.

82 For feedstock transport, I calculated the emissions per kg of dry mass (the methodology used by ISCC) and not per kg of wet mass. Is this acceptable?

Yes, provided the overall MJ (LHV) flow through the analysis correctly, the mass units can be altered from the template

83 For the separate consignment Excel workbooks (biogenic jet and waste fossil jet), should we include both of the biogenic and non-biogenic feedstock consignments in both of the Excel workbooks, and use module efficiencies to split these out?

A biogenic consignment Excel workbook should only contain biogenic material throughout the whole supply chain/whole workbook (and module efficiencies are to be based on the common module efficiency across the total of any mixed consignments). The same logic applies to RFNBO consignment or waste fossil consignment Excel workbooks. Using mixed consignments and then splitting out the biogenic from non-biogenic consignments should not be done within the workbook supply chains, e.g. the biogenic fraction of mixed wastes should not be misinterpreted as a module efficiency.

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84 We are involved in a joint bid where one entity is in the process of setting up a UK base but the lead applicant is already established as a British company. Are there are any restrictions on dispersing grant funds to non-UK entities?

Funding will be provided to the lead organisation in arrears following the completion of project milestones and on the provision of evidence of the completion of eligible work during the Funding Period. Lead organisations will be able to distribute this funding at their discretion following its release. However, we would also highlight that clause 5.4 of the draft grant agreement requires that: “Payment of the Grant by the Authority is conditional upon the Grant Recipient providing the Authority with evidence in a form reasonably satisfactory to the Authority that the Grant Recipient has obtained at least three (3) competitive quotes for the provision of all goods and services with a cost of £5,000 or more, with at least one (1) of those quotes being sourced from a UK-based supplier where reasonably practicable. In cases where this is not possible, if the Grant Recipient follows a single tender procedure for example, where the value of a contract is very low or where there is only one supplier capable of providing the goods or services concerned, the Grant Recipient must keep a record of the reasons why that procedure was thought to be appropriate.”

85 Would funding or payment in kind support from a member of the project consortium for eligible project work not be eligible as ‘match funding’?

Material support provided by a member of the project consortium or project lead can still

be considered as match funding under the GFGS, provided the support complies with all

other match funding requirements (please see question 75 of the competition FAQ for

further guidance on this issue). Final decisions on qualifying match funding will be made

during the assessment stage.

In addition, we would highlight that the grant agreements provided on the competition

website are boilerplate and may be subject to change at the discretion of DfT. This includes

the introduction of project-specific “Special Conditions” which may outline requirements on

proposed match funding offers.

86 Are you happy to receive documents (especially appendices) via WeTransfer?

Yes

87 If we submit before 1600 on Friday 28th May, would be possible to receive an acknowledgement before the competition deadline? We would like to ensure that our application, including the appendices which are large files, has been safely received.

We will endeavour to provide a confirmation of receipt for all applications received by

1600, Thursday 27th May 2021. Applicants should note that submissions received after this

date may not receive responses from the GFGS team, until Tuesday 1 June onwards,

following the May bank holiday.

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88 Question 2.1.1 asks for the aims and vision of “the project”. We have interpreted this as “the overall project” – i.e. the eventual construction of a commercial SAF plant, of which the proposed funded activity is only one stage. The objectives of the GFGS-funded stage of the project are summarised in our answer to 2.3.1, not in 2.1.1. Please confirm that this is what is intended.

Yes, this is the correct interpretation for 2.1.1 and 2.3.1. However, projects should note that 2.1.1 is not scored, but is used for public information

purposes, and to provide an initial starting context for assessors when reading bids.

89 We have not seen anything that says how many claims there should be. We assume this is at the discretion of the applicant – is that correct?

Projects are welcome to indicated preferred claim frequency as part of their detailed

project budget (Appendix D). However, projects should provide a compelling case for why

funds would need to be provided more frequently than every two months. Final structure

of support will ultimately be at DfT’s discretion.