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Analysis of SAF allowances (FEETS) – 2024-price update

February 2025, the European Commission adopted a new support mechanism on ‘SAF allowances’: used to bridge the price gap for the use of alternative fuels to accelerate the roll out of SAF.
We reviewed this mechanism in order to assess its expected impact on supporting the development of SAF market. We conclude that the policy design would require additional policy instruments to support the broader development of the SAF market.

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SAF allowances may not be the best instrument to ramp up SAF production

Sustainable Aviation Fuels (SAF) are renewable fuels that replace fossil based kerosine in aircrafts and are seen as an important option to mitigate climate emissions in the aviation sector. Generally, these alternative fuels are more expensive than their fossil counterpart, kerosene. In order to support the uptake of SAF, the European Commission has introduced several policy instruments.

SAF allowances may not be the best instrument to ramp up SAF production Read More

How to understand the dynamics of ETS for renewable fuels in the maritime sector

The maritime sector faces a fast-changing policy landscape. With the maritime sector now included in the scope of the EU emissions trading system and FuelEU Maritime fully applied from this year, fast action will be required by those across the industry to reduce emissions in shipping. This requires investment in

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Understanding the EU and NL carbon emission obligation schemes for SAF production

A Sustainable Aviation Fuel (SAF) producer asked us to assist them in identifying their obligations under the EU Emissions Trading System (ETS) and the Dutch national CO2 taxation scheme. 

For this analysis, we assessed the (future) participation requirements of the SAF producer under EU ETS based on their production set-up.

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Evaluation of bioenergy feedstock opportunities for the production of biofuels

For: Multinational energy company [December 2022 – December 2023] Our client, a market player within the Dutch oil and energy industry, sought clarity on the EU regulatory landscape for feedstock for biofuels. With a vision of producing advanced biofuels with low well-to-wheel carbon intensity, they required insights into how certain

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Strategic support on understanding of the renewable energy and fuel regulatory and market landscape

For: A downstream oil and gas company [January – December 2023] Our client sought our assistance in navigating the complexities of the transition of the transport fuel sector towards higher shares of renewable energy. Specifically, they required insights how the national implementation of the EU Renewable Energy Directive (REDII) impacts

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Compliance risk for obligated parties due to lack of (planned) eSAF production volumes 

ReFuelEU Aviation has set first mandates for the blending of Sustainable Aviation Fuels (SAF, and eSAF when produced from renewable electricity). Some production plants are already in operation and many more have been announced. From 2030 onwards production volumes, in particular for eSAF, need to ramp up following the set

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Understanding Fit-for-55

For: Various Netherlands companies active in transport fuels market [July 2021 – date] Summer 2021, the European Commission published the Green Deal Fit for 55 package: a legislative package full of proposals for new Directives and Regulations that collectively should lead to 55% lower greenhouse gas emissions in europe, compared

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