Opportunity Green
We close the gaps in global climate action using law, economics and policy.
ID: 861006553050-54
Lobbying Activity
Response to Sustainable transport investment plan
4 Sept 2025
2025 is an important year for aviation and maritime decarbonisation. Renewable hydrogen solutions offer the most effective pathway to decarbonising both of these sectors and reducing reliance on imported fossil fuels. If these projects are to be operating ahead of the 2030 target for ReFuelEU Aviation and 2030s targets for FuelEU Maritime, projects need to be reaching FID in the coming year. Financing and de-risking therefore needs to be accelerated now. The STIP is an opportune moment to address this and must be targeted towards renewable hydrogen projects. By introducing (1) a CfD financing mechanism for e-fuels (double-sided auctioning), (2) a time-bound book-and-claim flexibility mechanism for aviation e-fuels in the EEA, (3) support for the development and adoption of zero-carbon emission technologies via investment in hydrogen infrastructure in airports and use of green public service obligation (PSO) routes, and (4) encouraging the expansion of the EU ETS to maximise available funds, the STIP has the potential to transform the EUs e-fuel market, placing Europe at the forefront of a growing industry by driving decarbonisation, sustainable prosperity and competitiveness, and innovation. Please see attached for the SASHA Coalition's full feedback.
Read full responseResponse to EU Ports Strategy
24 Jul 2025
Please find enclosed Opportunity Green's response to the Call for Evidence.
Read full response7 Jul 2025
Opportunity Green welcomes the opportunity to provide input to the review of the emissions trading system and will focus on the revision of the aviation and maritime sectors in its submission. On aviation, Opportunity Green strongly supports the extension of the EU ETS to extra-EEA aviation, the inclusion of non-CO2 impacts, limiting zero-rating on all SAF and maintaining it exclusively for RFNBOs, and the allocation of ETS revenues to international climate finance and providing long term financial support to RFNBO development and deployment. Regarding maritime, this submission strongly supports the extension of the EU ETS to smaller ships, outlines the importance of transparent revenue allocation to international climate finance, and highlights that action taken on maritime under the ETS is complementary to the recently approved 'IMO Net-Zero Framework'.
Read full responseResponse to Amendment to Registry Regulation in response to the ETS revision/Fit For 55 (Batch 2)
9 Jan 2025
Please find attached feedback to the proposed amendments from Opportunity Green, on behalf of the SASHA Coalition.
Read full response2 Jan 2025
We welcome the planned introduction of 20 million allowances to be allocated to support the uptake of alternative fuels to drive aviation decarbonisation. The ReFuelEU Aviation regulation puts in place a clear framework that supports the vital role that alternative fuels will play in reaching EU decarbonisation goals for aviation. However, production of these fuels is falling behind where it needs to be to guarantee supply for the demand levels necessitated by ReFuelEU Aviation alternative fuel uptake targets. Indeed, recent analysis by Transport and Environment has found that no synthetic aviation fuel production facility in the EU has reached final investment decision (FID) - in part due to the significant cost premium that these fuels come at in comparison to fossil kerosene. We therefore agree that steps need to be taken to incentivise SAF uptake and agree with the approach proposed for calculating the price difference between eligible aviation fuels and fossil kerosene. However, we believe that measures should be put in place to ensure the allowances primarily drive the uptake of fuels with the greatest potential to lower emission and with the lowest impact on biodiversity - namely green hydrogen and fuels derived from green hydrogen (renewable fuels of a non-biological origin (RFNBOs)).
Read full response23 Dec 2024
We welcome the proposed introduction of common standards for refuelling infrastructure for maritime transport and inland navigation, and the inclusion of electricity supply, ammonia, hydrogen and methanol bunkering within the scope. Green hydrogen and its derivatives - e-methanol and e-ammonia - will play a crucial role in decarbonising the maritime sector, and it is important that across the supply chain barriers to uptake of these fuels are removed. Standardisation of refuelling infrastructure is therefore a crucial step that must be taken to support the uptake of such solutions for the shipping sector. Please see attached for more information.
Read full responseResponse to Greenhouse gas emissions savings methodology for low-carbon fuels
24 Oct 2024
The SASHA Coalition, facilitated by Opportunity Green, brings together leading companies from the shipping and aviation sectors who are committed to decarbonising their industries using green hydrogen. The SASHA Coalition takes an evidence-based approach to call for more ambitious policy and regulation to drive the development and deployment of green hydrogen fuels for shipping and aviation. In order to provide a holistic and effective approach to maximising the benefits of a transition to low-carbon fuels the methodology should recognise and capture all climate forcing emissions (including non-CO2) as well as other environmental impacts such as biodiversity impacts, nitrogen leakage etc. This would avoid maladaptation (i.e. investing in fuels that do not ultimately realise the anticipated benefits and therefore are technological dead ends) or investing in fuels that could be more detrimental in the longer term because their potential for CO2 emissions savings is outweighed by the other negative impacts that they generate.
Read full responseResponse to ReFuelEU Aviation environmental labelling scheme
22 Oct 2024
The SASHA Coalition - facilitated by Opportunity Green - welcomes the publication of, and opportunity to respond to, the draft Implementing Act for the Flight Emission Label. Providing a framework for the consistent labelling of flight emissions is important for consumers to make well-informed decisions and for providing increased transparency on aviation emissions. In order to most effectively deliver on its aims, we have highlighted two areas where further clarification can be provided: the inclusion of non-CO2 impacts of aviation and the need for further clarity on the impacts of sustainable aviation fuels. The climate impacts of aviation are not limited to the CO2 emissions it produces. While we welcome the inclusion of methane and nitrous oxide alongside CO2 in the scope of gases considered in the aviation fuels life cycle emissions estimation, we believe that this can go further to reflect other non-CO2 impacts such as those caused by contrails. We support the suggestions made by Transport & Environment to raise awareness of the non-CO2 effects from the Flight Emissions Label's launch through the inclusion of information on their impacts, leading to the inclusion of quantitative data on the non-CO2 impacts of flying from 2026. We also join both the International Council on Clean Transportation and Transport & Environment in supporting the use of RED II and CORSIA accounting frameworks to calculate the life cycle emissions of aviation fuels, including sustainable aviation fuels (SAFs). However, we further share the concerns raised by Transport & Environment that not all impacts associated with alternative fuels can be captured by a life cycle analysis. For example, biodiversity risks associated with the production of biofuels and associated risks of land use change and lack of clarity on feedstock origins. As such, we support their recommendation that the Label includes space for airlines to provide additional information on SAF feedstock and associated, non-climate risks.
Read full responseResponse to Environmental Implementation Review 2025
5 Jul 2024
Opportunity Green and the SASHA Coalition welcome the Commission's initiative and call for evidence in the 2025 implementation review. Achieving a just transition to a net zero future in the aviation and shipping sectors is an ambitious goal, but it is one that is achievable with a properly supportive policy framework, resources, and collaboration between industry and decision makers. Action needs to be taken now, however, if we are to meet 2050 net zero goals, given that it will take time to develop and scale the technologies and supporting infrastructure needed to transition to these sustainable fuels. With political attention increasingly being turned towards hydrogen, and the many opportunities its development provides, the SASHA Coalition is being formed to ensure that the aviation and shipping sectors are present in policy conversations and that their voice is heard at this important time. The attached briefing reveals that there is a lack of policy supporting the production of green hydrogen, which is slowing down demand and discouraging investment, creating a Green Hydrogen Gap. It demonstrates the clear role that green hydrogen and direct air capture (DAC) must play in decarbonising the shipping and aviation industries, and the associated risk of not putting in place the policies and regulations needed to ensure a secure supply of both for decarbonising those sectors. The report also outlines how the EU should prioritise the use of hydrogen and DAC in the aviation and shipping sectors because they lack decent alternatives, and highlights the need for EU policy to ensure that these solutions can be rolled out at scale. While we welcome efforts made to date at EU level, legislation must go further to incentivise the production of green hydrogen and DAC-derived fuels for shipping and aviation. Additionally, to overcome shipping and aviation's Green Hydrogen Gap, there is a clear role for both stronger regulation and ambitious voluntary action from first-mover companies to ramp up demand for these fuels.
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