The report is currently being prepared for publication.
The analysis of the design options shows that different policy instruments can contribute differently to overcoming some market barriers. A state funded double-sided eSAF-CfD following the model of H2Global is the best way to achieve this, with the government entering into a long-term contract with the producer and a short-term contract with the distributor. However, this option cannot be implemented without subsidies. Financing from EU ETS revenues or a levy on airline tickets would be conceivable, but implementation would not be trivial. Long-term supply contracts (eSAF-PAs) can bring producers and distributors together in the private sector. Government guarantees against project failure could cover risks here, but even then, eSAF-PAs alone cannot solve the central market barriers. Both an amortisation account and flexible private-sector loans are less suitable for enabling the eSAF ramp-up, as they provide liquidity for distributors but do not offer real protection against high additional costs.
In order for the proposed eSAF-CfD options to contribute to the ramp-up, it is essential to reduce regulatory uncertainties for the eSAF ramp-up. The eSAF quota and penalties for non-compliance must be enshrined in law and reinforced with credible political backing.
Overall, the following steps can be derived to support the eSAF ramp-up:
- First and foremost, the uncertainties in the regulatory framework of the quota and the design of the EU ETS must be resolved. These two instruments form the market framework that requires the use of eSAF and are therefore fundamental to a successful ramp-up. All additional instruments should be subordinate to these and their limits clearly communicated.
- If the state is to intervene in the market to a limited extent, the standardisation of eSAF purchase agreements backed by government guarantees is the appropriate instrument to support the ramp-up. It is administratively lean, addresses some of the market barriers and paves the way for a free eSAF-PA market, which is important for the further development of the market.
In addition, a state funded double-sided eSAF-CfD can address and remove market barriers even more explicitly. This instrument is more complex in regulatory and administrative terms and carries an even greater risk that players will wait for the subsidy without trusting the quota. Communicating the limits of the subsidy is therefore essential here. In order to reduce the effort involved and take effect within a short period of time, it makes sense to structure the double-sided eSAF-CfD via a subsidy round from H2Global. To increase acceptance, financing the subsidy via a levy or from EU ETS revenues could be considered.