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FiveBarGate RFA Consultation response

Please read our response to the Renewable Fuels Agency consultation, relating to the Renewable Transport Fuel Obligation. Should you wish to discuss this further, please contact us.

My key message is that the balance of value to industry of having new guidance seems limited. Given the UK will implement the RED in March 2011, there remains time for operators to develop their systems in a structured manner during 2010, based on guidance that will appear from the commission and be interpreted by the RFA during 2010.

Given this guidance will require further changes to systems, with some potential for amendments to these proposals, it seems more appropriate to make as few changes as possible, allowing analysis of 2010/11 data against 2008/9 and 2009/10 data. This 3 year database will be the best assessment of supply chain C&S performance in the world for at least 3 more years. Such a database can help inform further standards development, including iLUC, which is likely to develop post 2011.