Urgent Call for Climate Leadership:

Reject So-called "Sustainable" Aviation Fuels (SAFs) Policy and Subsidies in MA

The "green" fuel that would come to haunt us

Open Letter to:

Governor Healey, the Governor's Administration, and MA State Legislators

Signed by:

STILL OPEN: To add your organization’s name, email us at info@spje.org or fill out this form

October 14, 2025

Dear Governor Healey, the Governor's Administration,
and Massachusetts State Legislators,

We, the undersigned organizations, urge you to reject policies and subsidies promoting the production and distribution of so-called "Sustainable" Aviation Fuels (SAFs) in Massachusetts.  As leaders who enacted sweeping climate legislation last November, you have the opportunity to lead with scientific integrity—or adopt costly policies rooted in industry aspirations over climate reality.

The aviation industry promotes SAFs as a solution for reducing aircraft emissions while continuing to expand air travel. The pitch is appealing—green flights without climate impacts—but independent, non-aviation funded research shows SAFs are neither sustainable nor scalable. Despite their name, SAFs would increase carbon emissions, waste public funds, and divert resources from more effective solutions to help reach MA 2050 net zero goals.

Why SAF Policies and Subsidies Should Be Rejected

SAFs Are Not a Climate Solution

SAFs are not clean or green. All fuel today labeled SAF is primarily fossil jet fuel. SAFs must be blended with fossil jet fuel— as low as 10% SAF, with a maximum of 50% blend allowed. 100% SAF use is not currently allowed.1 Marketing these fuels as "clean" or "sustainable" is misleading.

SAFs produce as much or more CO2 as conventional jet fuel in the atmosphere, even though they are proposed to reduce greenhouse gas (GHG) emissions. This applies to both blended SAFs (with fossil jet fuel) and 100% "neat" SAFs. The hypothetical benefit of SAF is that its production can absorb some CO2 to cancel its emissions when burned. However, basic science and practical limitations prevent SAFs from achieving this goal, when full lifecycle emissions are accounted for.2

Industry claims of 70–90% CO2 reductions rely on unrealistic assumptions: 100% "neat" SAF (not allowed), a 100% clean grid (not achievable for many decades), and zero emissions from land use changes or displaced feedstock uses (not realistic). In reality, full life cycle analyses show that SAFs produce as much, and sometimes more, CO2 as fossil jet fuel.3

Plans for ramping up SAF production are unrealistic. SAFs are currently 0.1% of US jet fuel supply (2023). To meet the US federal goal to completely replace fossil jet fuel with SAFs by 2050 (35 billion gallons), SAF production would need to increase by a staggering 227,400% over 2022 production levels.4 This is magical thinking. Producing sufficient SAF to meet Massachusetts state requirements would require more than all the electricity currently produced in the Commonwealth. Subsidizing e-fuel alone, just one type of SAF, would exceed the entire MA Transportation budget annually.5

All SAF Types Have Major Drawbacks

Biomass and carbon capture SAFs generate the same or more CO2 as conventional fossil jet fuel, when full life cycle emissions are taken into account, and each type of SAF is associated with severe environmental and energy impacts.

Crop-Based SAFs

Crop-Based SAFs threaten food security by competing for arable land, resulting in deforestation to replace lost land. To meet US 2050 targets for SAFs, from corn alone, would require 114 million acres—20% more than current US corn production. Bringing them to scale would devastate agriculture, threaten food security, accelerate deforestation and the loss of carbon sequestration.6

The EU has banned crop-based SAFs due to their threat to food security. The Trump administration recently extended a federal tax credit program, originally introduced by Biden, for corn, soy and other crop-based SAFs designed to encourage their increased production.7

Waste-Based SAFs

Waste-Based SAFs are processed from waste cooking oil or animal fats. They are the primary type of SAF produced today. However, the available supply is minuscule compared with SAF requirements. This is also true of wood scrap. These wastes have a small GHG benefit and represent a dead end for SAFs; it would be irresponsible to subsidize them. Moreover, due to their limited supplies, these waste SAFs encourage the clear-cutting of standing trees whose biomass is fraudulently sold as wood scrap.8 Limited waste oil has the potential to drive expanded palm tree plantations, for instance, then sold as "waste oil"9. Essentially, these conditions would mirror and amplify the same land use issues as crop-based SAFs.

E-fuels (synthetic fuels, carbon capture)

In principle, e-fuels could capture the amount of CO2 during production that they later emit when burned. Unfortunately, the process is extremely inefficient, consuming enormous amounts of energy during production. The magnitude of electrical power necessary to produce sufficient e-fuel to meet MA aviation needs is much more than MA generates today.10 11

Aviation vs. Massachusetts Climate Goals – Not Aligned

The aviation industry's goal is to argue that aviation can continue to grow today because a new "green" fuel to reduce aviation emissions will be available tomorrow. To paraphrase Senator Mike Barrett's observation at a January 2025 meeting about SAFs, "This is like telling our children it's okay to smoke cigarettes because sometime in the distant future there will be a cure for cancer."

By contrast, Massachusetts' goal is to achieve net zero emissions by 2050 to stabilize the climate crisis and avert its worst consequences. SAFs cannot do this, or even contribute in any substantial way to this goal.

Massachusetts' should prioritize climate strategies with actual benefits, chief among them, the ongoing effort to convert the electric grid to 100% clean energy, a proven pathway that would benefit all sectors and the public at large, not just those who can fly.

SAFs Are Antithetical to Climate Leadership

The aviation industry's climate commitments lack credibility. SAFs come from the same Big Polluters playbook that gave us "clean coal", ethanol in gasoline to make cars run "cleaner", and filters for making cigarette-smoking "healthier". Each sounded promising—each wasted precious time. SAFs are no different.

We recognize the enormous pressure on lawmakers to support something labeled "sustainable." But the evidence is clear: SAFs would harm the climate, waste public funds, and delay better solutions.

Massachusetts is known for bold climate leadership. Backing SAFs would undermine that standing and tie the Commonwealth to a failing climate strategy.

Massachusetts should prioritize climate strategies with real, achievable benefits: 100% clean electric grid, clean public transit, and reducing demand for unnecessary flights, especially super-emitting private jets, the least defensible and most carbon intensive form of travel per passenger.

We, the undersigned organizations, respectfully urge you to reject SAF policies and subsidies, and stand with science, equity, and fiscal responsibility. Let Massachusetts lead—not with false solutions, but with real climate action.

STILL OPEN: To add your organization’s name, email us at info@spje.org or fill out this form

Signed

Endnotes

1. International Air Transport Association (IATA). "Sustainable Aviation Fuel: Technical Certification, Fact Sheet-2." https://www.iata.org/contentassets/d13875e9ed784f75bac90f000760e998/saf-technical-certifications.pdf

2.  Aviation Environment Federation. "Hope or Hype: Can SAF Really Justify Airport Expansion?" September 4, 2025. https://www.aef.org.uk/2025/09/04/hope-or-hype-can-saf-really-justify-airport-expansion/ 

3.  Institute for Policy Studies. "Barriers to Implementing Sustainable Aviation Fuel (SAF) in Massachusetts." October 14, 2025. https://ips-dc.org/report-barriers-to-implementing-sustainable-aviation-fuel/

4.  Institute for Policy Studies. "Alternatives to Jet Fuels: Promising Solution or Industry Hype?" May 2024. https://inequality.org/wp-content/uploads/2024/12/Sustainable-Aviation-Fuels.pdf

5.  Institute for Policy Studies. "Barriers to Implementing Sustainable Aviation Fuel (SAF) in Massachusetts." October 14, 2025. https://ips-dc.org/report-barriers-to-implementing-sustainable-aviation-fuel/

6.  World Resources Institute. "Under New Guidance, 'Sustainable' Aviation Fuel in the US Could Be Anything But." May 9, 2024. https://www.wri.org/insights/us-sustainable-aviation-fuel-guidance

7.  Yale Environment 360. "The 'Green' Aviation Fuel That Would Increase Carbon Emissions." May 27, 2025. https://e360.yale.edu/features/corn-soy-biofuel-aviation-congress

8.  Natural Resources Defense Council and Dogwood Alliance. "Investigation Shows Forests Destroyed to Supply Biomass." October 17, 2024. https://www.nrdc.org/press-releases/investigation-shows-forests-destroyed-supply-biomass

9.  Transportation & Environment. "Briefing: Used Cooking Oil (UCO): The Certified Unknown, An In-depth Look at Biofuel Certification and UCO Fraud." December 2024. https://www.transportenvironment.org/discover/briefing-used-cooking-oil-uco-the-certified-unknown/

10.  Jones, Nicola. "As Carbon Air Capture Ramps Up, Major Hurdles Remain." Yale Environment 360, March 20, 2024. https://e360.yale.edu/features/direct-air-capture-climate-change

11.  Institute for Policy Studies. "Barriers to Implementing Sustainable Aviation Fuel (SAF) in Massachusetts." October 14, 2025. https://ips-dc.org/report-barriers-to-implementing-sustainable-aviation-fuel/

For additional information, please contact info@spje.org  or visit Sustainable Aviation Fuels