Just in case anyone missed it, the DfT is delivering on a number of issues, some of which we’ve been taking them to task on for some time. A number of very helpful RTFO Account Holder Communications came out at the end of 2023.  The 8th December Communication (No 14), cleared up the question of whether RTFCs are eligible for fuel used on vessels on inland waterways which use the same fuel for heating and propulsion. They are, regardless of whether the fuel is used for heating or propulsion. That’s a pragmatic solution to an odd situation not impacting many players, nor significant volumes of fuel, but where the answer differed depending on where in the supply chain the fuel supplier was, or which part of DfT they were asking. It was also very good to read DfT’s words regarding mobile generators.  The RTFA has been campaigning for many months about biofuel used for power generation, in situations where grid electricity is available. It makes no environmental sense and seemed to be gaining momentum.

Those members who read Tom’s commentaries on the RTFO statistics reports may have picked up some subtle signalling, but DfT came right out and said that it’s important not to take what it says on a proof of sustainability (PoS) at face value – but instead to apply some common sense checks, and it provided some examples.

We’re often asked is HVO is actually 100% biogenic, and can this be proven? Communication 15 (19th December) provides advice to RTFC claimants that where co-processing has occurred, that the fuel needs to be reported as a different fuel type. This leaves the possibility open for the RTFO Administrator to ask for proof of renewability for fuel reported as HVO.  The 19th December communication also covered development fuels. RTFA members will know we’ve long been trying to get the guidance to follow suit with the policy intent; i.e., genuine investments made to produce valuable drop-in fuel from previously unused feedstocks. The first attempt at this (proposed in Communication No. 11, 17th Oct) wouldn’t have had the desired effect, so thank you to DfT for pulling back from implementing it. It’s good to see the resolve to sort this out, and we’ll continue to work with DfT colleagues to resolve it.