The RTFA submitted a brief (3 page) response to this consultation.
Our members primarily concern themselves with the RTFO and SAF mandate which already have the most rigorous sustainability criteria of all the current biomass incentive schemes, with strict land-use change prohibitions (aligned closely with EU RED II), lifecycle GHG savings thresholds (e.g., ≥65% for most biofuels, ≥40% for SAF, with tightening obligations), ILUC reporting, waste/residue prioritisation via double counting incentives, and consignment-level mass-balance traceability verified by independent auditors, (often via schemes like ISCC or RSB). This positions the transport sector as a leader in sustainable biomass use, with the vast majority of supplied volumes from wastes and residues.
The document sets out that many existing schemes that encourage the use of biomass will be unaffected by the proposals in the consultation, due to either being locked into existing criteria; or the proposals taking so long to be rolled out that the schemes will have closed.
RTFA response to the Common Biomass Sustainability Framework consultation
