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SkyNRG B.V.

SkyNRG

Developing capacity for sustainable aviation fuel - bio-based and e-SAF

Lobbying Activity

Meeting with Radan Kanev (Member of the European Parliament) and Norsk e-Fuel AS

2 Dec 2025 · Synthetic aviation fuels

Response to Sustainable transport investment plan

4 Sept 2025

We wish to deeply express our appreciation to the European Commission for the opportunity to contribute to this call for evidence. In summary, we believe that the Sustainable Transport Investment Platform (STIP) should incorporate the following interventions to accelerate the deployment of e-SAF and advanced biofuel SAF in the European Union: - The establishment of an EU market intermediary dedicated to e-SAF and advanced biofuel SAF. - The encouragement of Member States to allocate national funding to a double-sided auction by mid-2026, in order to bridge the financing gap until an EU-level intermediary becomes operational. - The reinforcement of the mandate of EU public financial institutions such as the EIB to provide concessional debt and equity instruments to first-of-a-kind projects. We remain at the Commissions disposal to provide further input and stand ready to support the development of a robust and competitive European SAF sector.
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Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Implementation Dialogue on ramping up renewable and low-carbon maritime and aviation fuels production in the EU

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

4 Jul 2025

Dear DG CLIMA team, SkyNRG appreciates the opportunity to contribute to the consultation on the revision of the EU ETS for aviation. As a leading developer of Sustainable Aviation Fuel (SAF) projects in Europe, we see the ETS as a vital tool to unlock investment in SAF, particularly e-SAF, and accelerate the sectors decarbonisation. Our response outlines six targeted recommendations to strengthen the ETS framework and support the delivery of ReFuelEU Aviation targets. In particular, we call for: - Extending ETS coverage to all departing flights where global ambition falls short; - Prioritising in-sector emission reductions over offsets; - Amending the proportionality rule to improve SAF uptake at EU airports; - Scaling and extending the SAF allowance mechanism through 2040; - Creating a market intermediary to de-risk e-SAF offtake agreements; and - Allowing flexible allocation of biogenic CO from mixed-source emitters to CCU applications, to ensure access to biogenic CO for e-SAF projects. These changes would ensure that the EU ETS fully supports the scale-up of SAF, sends the right investment signals, and reinforces the EUs climate and industrial goals. We thank DG CLIMA for its continued leadership and look forward to engaging further. Kind regards, The SkyNRG Team
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

7 May 2025 · Exchange of views on sustainable aviation fuels

Response to Rules for reporting CORSIA eligible fuels and CORSIA units cancellation reports under the ETS Directive

29 Apr 2025

We welcome the opportunity to provide input on the future design of the EU ETS and its interaction with CORSIA. We believe that strengthening the EU ETS and extending the scope to cover 3rd country departing flights is crucial for the decarbonization of aviation, as CORSIA alone will not do enough to drive in-sector mitigation of air transport emissions and stimulate the uptake of SAF. In addition, an extension of the scope has the benefit of enabling the funding of an extension of the SAF allowances mechanism (FEETS) and could bring in additional revenues to provide long term revenue certainty to eSAF facilities through a double-sided auction mechanism or similar mechanisms that are under discussion for the EUs Sustainable Transport Investment Plan (STIP). We encourage the Commission to prioritize policy frameworks that both price carbon effectively and recycle revenues into high-impact climate investments. Extending the EU ETS for aviation offers an opportunity to achieve both, while harmonizing the level playing field for aviation in Europe and ensuring consistency with the EUs broader Green Deal and Fit for 55 objectives.
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Meeting with Nikolina Brnjac (Member of the European Parliament)

25 Apr 2025 · Contribution of SkyNRG to the Sustainable Aviation Fuel (SAF) industry in the EU and the EU’s climate ambitions

Meeting with Moumen Hamdouch (Head of Unit Mobility and Transport)

8 Apr 2025 · Presentation of specific case of building an eSAF plant, funding mechanisms and policy intervention for ramp-up of SAF production and de-risking for investments.

Meeting with Moumen Hamdouch (Head of Unit Mobility and Transport)

23 Jan 2025 · Exchange of views in the area of: SAF, eSAF, funding mechanisms for SAF, de-risking for investments

Response to Rules for calculating price difference to kerosene and for EU ETS allocation of allowances for the use of eligible fuels

6 Jan 2025

SkyNRG welcomes the draft proposal on the delegated act to supplement the Directive 2003/87/EC (EU ETS), laying down detailed rules for the yearly calculation of price differences between eligible aviation fuels and fossil kerosene, and for the EU ETS allocation of allowances for the use of eligible aviation fuels. Next to feedback on the price difference calculation, we would also like to stress the importance of coming forward with measures to ensure that SAF production facilities are further derisked and the uptake of advanced SAF (advanced biofuels for aviation and eSAF) is accelerated, which SAF allowances currently do not do. Please find attached our detailed feedback.
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Meeting with Magda Kopczynska (Director-General Mobility and Transport) and TotalEnergies SE and

6 Dec 2024 · Investments in sustainable liquid fuels production in the EU

Meeting with Sunčana Glavak (Member of the European Parliament) and Rud Pedersen Public Affairs Brussels

2 Dec 2024 · Advancement of SAF as part of the European Parliament priorities in the new mandate, EU ETS revision

Meeting with Jens Gieseke (Member of the European Parliament)

25 Nov 2024 · Austausch zu EU Politik

Meeting with Nicolás González Casares (Member of the European Parliament) and NATURGY ENERGY GROUP

19 Nov 2024 · Energy policy

Meeting with Hildegard Bentele (Member of the European Parliament)

2 Oct 2024 · Sustainable Aviation Fuels

Meeting with Isabella Tovaglieri (Member of the European Parliament, Committee chair)

5 Sept 2024 · Decarbonisation of aviation sector

Response to Update of list of sustainable biofuel feedstocks

1 Jan 2023

SkyNRG welcomes the European Commissions ambition to expand the list of eligible feedstocks but also identifies multiple concerns. More specifically, SkyNRG is worried that investment certainty is undermined by the decision to place certain feedstocks on the Annex IX B list, which is capped. No impact assessment has been provided by the European Commission to understand how the ambitious renewable energy goals in transport can be achieved with this updated feedstock base. Furthermore, the European Commission does not clarify whether it is possible that a technology that is advanced today can be mature tomorrow. And, whether investing in an advanced technology (which by definition has the goal that it will be mature one day) will then be confronted to be moved to the capped Annex IX B part. Finally, we note that various feedstock categories lack the necessary guidance to make investment decisions, or for national authorities to approve certain feedstocks in their national schemes. We attach our elaborated feedback in the attached document.
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Response to Greenhouse gas emissions savings methodology for recycled carbon fuels and renewable fuels of non-biological origin

17 Jun 2022

SkyNRG welcomes this proposal outlining the calculation methodology for RFNBOs and RCFs, which sets the scene for project developers to align with the minimum 70% GHG reduction thresholds. However we believe the draft can be significantly improved by clarifying various elements and thereby enabling the private sector to develop projects with minimal risk. Our response can be summarized as follows: - More guidance. Even though an Annex was published with the draft Delegated Act, we believe more guidance is required to provide investors and project developers with the needed certainty around project design. Specifically on the calculation methodology of co-processing RFNBO/RCF feedstocks with conventional feedstocks, the use of biogenic CO2 from installations subject to ETS, like waste incinerators or pulp and paper factories. - Exclusion of the option to use the ‘marginal price’ method in combination with nuclear power to demonstrate eligibility with the 70% GHG reduction criterion as this creates an unfair level playing field. - Introduction of commonly accepted LCA standards to determine the emissions of RFNBO and RCF in case of co-production, instead of taking the average.
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