Energy Regulation Solutions

Maryna Hritsyshyna

Energy Regulation Solutions

Maryna Hritsyshyna

  • Energy Regulation Solutions

    Maryna Hritsyshyna

    About us

    Energy Regulation Solutions offers specialized regulatory consulting at the intersection of innovation, climate goals, and market readiness. We support developers, investors, and policymakers in navigating complex regulatory landscapes for hydrogen, CO₂, and Power-to-X technologies in the EU, Germany, and the US

Tag Archives: #aviation

Author Image Posted By : admin 18 Jul, 2025

Interaction of Certification and Standards for e-SAF Production

Last week, I had the opportunity to present my paper “Interaction of Certification and Standards for e-SAF Production” at a conference hosted by the Florence School of Regulation. This research is part of my broader PhD work on the interaction between law and technology in the regulation of Power-to-X (PtX) technologies.

✅ Key Points of the Presentation:

📌 General requirements

  • To be used in aviation, e-SAF must be certified under either the EU Renewable Energy Directive (RED) or the CORSIA scheme, and blended with conventional jet fuel in accordance with international standards such as ASTM D7566 and Def Stan 91-091.

📌 Legal Framework

  • There is a lack of harmonization between the EU legal framework and international aviation fuel standards.
  • The definition of SAF in the ReFuelEU Aviation Regulation does not align with the definition used in international standards.

📌 Certification

  • Particular attention should be given to the concept of “dual conformance” — i.e., a single batch of SAF being compliant with two different certification schemes (such as EU RED and CORSIA).
  • The coexistence of two certification schemes – EU RED and CORSIA within the EU raises questions about the feasibility of such dual conformance, a concept that is not yet defined under EU law.

☑️ Conclusion

  • A harmonized and coherent legal framework is essential for scaling up e-SAF production and deployment in aviation.
  • Aligning EU regulations with international safety and sustainability standards will help remove existing regulatory barriers and support the widespread adoption of e-SAF across the EU.
Maryna Hritsyshyna. Interaction of certification and standards for e-SAF production
GHG Emissions: aviation emits about 3% of global carbon dioxide, about 96% of GHG emissions in aviation belong to the large airplanes. Sustainable aviation fuel: a solution for medium and long-haul airplanes, allow reducing carbon emissions by 50-80% in comparison with the conventional fuel.
Interaction and impact of laws and standards for e-SAF production
ReFuelEU Aviation Regulation. SAF is aviation fuel blended with Synthetic Blending Component (SBC) according to the applicable standards and certified under sustainability requirements for GHG emission reduction. e-SAF is a SBC in the meaning of international standards or synthetic aviation fuels, produced using electrolytic hydrogen and CO2 as feedstocks.
Certification schemes under the EU RED and the CORSIA
Standards applicable to e-SAF: Quality of aviation fuel (Def Stan 91-09, ASTM D1655-22a), Production pathways and blending rates (ASTM D7566-22, ASTM D4054), Distribution of e-SAF (EI/JIG 1530 Standard).
Interaction between certification and standards for e-SAF
e-SAF certification, definition, ReFuelEU Aviation Regulation, the EU RED and CORSIA
existing barriers to e-SAF production and support e-SAF deployment in the EU
Author Image Posted By : admin 11 Jul, 2025

2nd Florence Aviation Regulation Conference

2nd Florence Aviation Regulation Conference, Florence School of Regulation

Just returned from the 2nd Florence Aviation Regulation Conference, co-organized by the International Institute of Air and Space Law (IIASL), Leiden University and the Florence School of Regulation.

It was an honor to contribute to such a high-level exchange of ideas shaping the future of aviation regulation.

I had the pleasure of presenting my paper on “Interaction of Certification and Standards for e-SAF Production”, exploring how regulatory frameworks and technical standards impact the uptake of sustainable aviation fuels in Europe.

The conference addressed a wide range of topics, including:

  • Interaction between CORSIA and the EU ETS
  • Implementation of the AI Act in aviation
  • Market incentives and social sustainability in the net-zero transition
  • Regulation of non-CO₂ effects in aviation
Author Image Posted By : admin 31 May, 2025

ICAO dashboard update

ICAO web site

Source: ICAO web site

✈️ The International Civil Aviation Organization (ICAO) updated the dashboard with publicly-available information on sustainable aviation fuel (SAF) offtake agreements.

📌 This dashboard covers various locations worldwide.

📌 Volumes refer to neat SAF; in case of blended SAF announcements the volumes refer to the fraction of SAF in the blend.

➡️ Source: ICAO web site. Offtake Agreements

Author Image Posted By : admin 22 Apr, 2025

SAF Flexibility Mechanism

SAF Flexibility Mechanism

Let’s talk about the SAF Flexibility Mechanism in the EU.

✅ Main Documents:

☑️ What is the SAF Flexibility Mechanism?

📌 the SAF flexibility mechanism allows an aviation fuel supplier to supply the minimum shares of SAF as a weighted average over all the aviation fuel it supplied across all EU airports for each reporting period.

📌 the SAF flexibility mechanism is intended to give the SAF industry sufficient time to scale up its production and supply capacities.

📌 this means that aviation fuel suppliers may supply aviation fuels containing higher shares of SAF in certain EU airports to compensate for aviation fuels containing zero or lower shares of SAF in other EU airports.

📅 The SAF flexibility mechanism applies from 1 January 2025 until 31 December 2034.

✅ Some key conclusions from SAF flexibility mechanism report:

📌 Compliance with targets:

  • Aviation fuel suppliers can claim the supply of SAF for the purposes of complying with their ReFuelEU Aviation obligations and contributing to the national RED targets.
  • EU law does not prevent a batch of SAF to be certified under more than one certification scheme (e.g. RED, CORSIA certified fuels).
  • Aircraft operators can claim the use of a given quantity of SAF under one GHG reduction scheme, including the EU ETS and ICAO’s CORSIA.

📌 Virtual trading of SAF sustainability certificates

  • there is no unified industry-wide position neither on the design or the necessity of implementing such an accounting mechanism system for the purposes of complying with current blended SAF obligations and of claiming their use under other pieces of EU law, such as the EU ETS that does not allow aircraft operators to claim the use of blended SAF without physically delivery.
  • virtual trading of SAF sustainability certificates may bring new dynamics to the market on the demand side, but it is not clear whether this would have any real impact on the production side at this early stage.

📌 Availability of blended SAF at EU airports

  • the risk of a significant geographic concentration of blended SAF in few EU airports is limited.
  • most aviation fuel suppliers operate only within the borders of their respective Member State, so the possibility of significant geographic concentration is already largely limited to national markets.
  • many EU airport managing bodies have clearly communicated their intention to make blended SAF available in the coming years on their premises.
  • projects for new SAF capacities are appearing in various locations across the EU.