HomeMy WebLinkAbout2025-05-00-HFAC-rpt (Accelerating the Adoption of Sustainable Aviation Fuels)N"
May 2025
May 12, 2025
The Honorable Maura Healey
Governor of Massachusetts
The Honorable Kim Driscoll
Lieutenant Governor of Massachusetts
Massachusetts State House
24 Beacon Street, Room 280
Boston, MA 02133
Subject: MA Interagency Sustainable Aviation Fuel (SAF) Workgroup Recommendations
Aviation is critical to the competitiveness of the Massachusetts economy, which is grounded in
travel intensive industries such as high technology, clean technology, biotechnology, higher
education, financial services, professional services, and tourism. MassDOT's Statewide Airport
Economic Impact Study (2019) concluded that Massachusetts airports contribute $24.7 billion
annually to the Commonwealth's economy and support 200,000 jobs in Massachusetts.
At the same time, we must look to reduce the state's aviation -related carbon footprint. The
Commonwealth has a legislative mandate to decarbonize and achieve Net Zero by 2050. Aviation is
a hard to decarbonize, critical industry whose major source of carbon emissions is jet fuel which is
outside of an airport owner's direct control (called Scope 3 emissions), since aircraft operators and
fuel providers are responsible for procurement of jet fuel including meeting safety standards and
logistics of production, delivery, and use. There will also be an economic cost to the aviation
industry from climate change. As identified by the International Civil Aviation Organization (ICAO),
economic costs will result from increased weather volatility, the need to reinforce infrastructure,
and higher operational costs due to rising temperatures, for example.
Recognizing this challenge, the Office of Climate Innovation and Resilience recommends advancing
Sustainable Aviation Fuel (SAF) in Massachusetts by pursuing opportunities to pilot technology and
enacting policies and actions to become a leader in supporting SAF energy sources and technologies
that have the potential to dramatically reduce life cycle aviation emissions (to near zero by 2050, for
example) and avoid indirect impacts on forests and croplands.
To meet this challenge, an interagency workgroup was convened to propose specific
recommendations based on research and expertise from industry stakeholders. The Massachusetts
SAF Workgroup (SAF Workgroup) is composed of key staff from the Executive Offices of Economic
Development (EOED), Energy and Environmental Affairs (EOEEA), Administration and Finance (A&F),
the Office of Climate Innovation and Resilience, Massachusetts Clean Energy Center (MassCEC),
Massachusetts Department of Transportation Aeronautics Division (MassDOT), and the
Massachusetts Port Authority (Massport).
The SAF Workgroup presents the attached report which recommends a series of actions that the
Commonwealth can take to incentivize the use of SAF at airports within Massachusetts and
regionally. We believe implementing these recommendations will lead to the early delivery of SAF to
state airports, lay the groundwork for the development of a SAF eco -system based on the region's
technology and academic strengths, incentivize infrastructure investments, and create jobs
associated with the production, handling, and delivery of SAF.
Finally, it must be acknowledged that this effort is unfolding in an uncertain federal regulatory
environment—major federal funding for clean energy and climate -related initiatives is at risk and
longstanding federal environmental regulatory frameworks are under review. Nevertheless, we
believe that state and multi -state level efforts to advance SAF are critically important if we are to
achieve our sustainability goals related to aviation.
Sincerely,
Interim Secretary Ashley Stolba, EOED
Secretary Rebecca Tepper, EOEEA
i .4' LSS& (,r~
Climate Chief Melisssa Hoffer, Governor's Office
K
Rich Davey, CEO Massachusetts Port Authority
Cc: Kate Cook, Chief of Staff
Secretary Monica Tibbits-Nutt, MassDOT
r,�Ltw'
Secretary Matthew Gorzkowicz, A&F
Dr. Emily Reichert, CEO MassCEC
Table of Contents
ExecutiveSummary............................................................................................1
Background........................................................................................................4
State Interagency SAF Workgroup......................................................................9
Observations and Findings...............................................................................11
Recommendations.......................................................................................... 20
Acknowledgements......................................................................................... 32
References...................................................................................................... 33
i I P a g e
The aviation industry acknowledges the urgent need to address climate change and ensure
sustainable flying. At the International Air Transport Association's (IATA) 77th Annual
Meeting in Boston, Massachusetts on October 4, 2021, the industry committed to achieving
net zero carbon emissions by 2050. This commitment, which is also integrated into the
Federal Aviation Administration's (FAA) Climate Action Plan and individual airline
environmental sustainability plans, encompasses a range of actions including the
development of new propulsion technologies, operational efficiency improvements, and the
transition from fossil fuels to sustainable aviation fuels (SAF). Most of the carbon abatement
is expected to be achieved by using SAF.
Therefore, immediate action is needed to spur investment in new aviation fuels that are not
derived from petroleum-based sources. Instead, sustainable fuels should rely on renewable
bio -sources that do not compromise food security or have adverse environmental impacts.
Examples include fuels developed from approved waste fats, oils, and greases (known as
hydro -processed esters and fatty acids or HEFA), waste bi-products from agricultural and
forest residues, and synthetic processes such as one under development by Massachusetts-
based Lydian Labs. Massachusetts can show leadership in this area now with a SAF policy
that begins to move the Commonwealth away from fossil fuels as the primary energy
source for our aviation needs.
SAF is a drop-in fuel produced from renewable feedstocks that offer the same performance
and safety as conventional jet fuel, while being fully compatible with the existing fuel
supply, infrastructure, and aircraft engines. A crucial element of any future state policy is
the inclusion of incentives for using and producing SAF with the highest emission
reduction benefits. In line with existing SAF policies, climate benefits should be
calculated across the entire lifecycle of the fuel, including production, transportation,
combustion, and associated indirect effects. Future Massachusetts policy should
recognize ambitious carbon intensity reduction thresholds. Such policies should focus
support for SAF on energy sources and technologies that have the potential to dramatically
reduce lifecycle aviation emissions (e.g., to near zero by 2050) and avoid indirect impacts on
forests and croplands.
Based on research, best practices from other states, and input from experts, the SAF
Workgroup identified the following short-term and long-term recommendations.
1 I P a g (.
Recommendation 1.
Undertake a regional planning study to better understand SAF production,
transportation, delivery, storage, blending and usage, the current jet fuel supply chain,
the potential for future blended SAF delivery, and regional feedstock opportunities.
Expected time frame — Massport has engaged the U.S. Department of Energy's (U.S.
DOE) National Renewable Energy Laboratory (NREL) to conduct the study, which is
expected to be completed by fall 2025.
Recommendation 2.
Create a Massachusetts and New England Region SAF Hub to include major employers,
academic institutions, and key aviation industry groups including airports, airlines, and
general aviation users to secure buy -in from key stakeholders, facilitate information
sharing, and identify priority short- and long-term initiatives that build SAF momentum.
Expected time frame — consistent with other, similar regional efforts, this effort should
be initiated in the near term and include a regional SAF workshop.
Recommendation 3.
Identify and market existing state programs and initiatives targeting greenhouse gas
emissions reduction, climatetech, and economic development to support SAF -related
production, innovative technology, and job creation. Additionally, explore federal
programs that may be available to bolster SAF inclusion in the Commonwealth's
climatetech ecosystem.
Expected time frame — as part of this effort, the SAF Workgroup reviewed and identified
an initial set of existing programs that can be leveraged. This should be a near-term
effort but continue into the medium and long term.
Recommendation 4.
Enact legislation to fund a tax credit for SAF usage, blending, storage, and production
infrastructure, as well as new SAF technology testing, adoption, and scale -up to address
cost barriers to production and demand and enable market uptake of SAF.
Expected time frame — initial discussions should begin in the near term.
Recommendation S.
Convene a Regional SAF Alliance, inclusive of the six New England states and New York,
which will work to align SAF policies and programs at a regional level and build the scale
needed to develop a SAF industry and expand feedstock sources.
Expected time frame — This effort may span the medium to long term but should
leverage the SAF Hub process once it is underway and involve the New England states
and New York.
The SAF Workgroup believes that implementing these recommendations will enable the
Commonwealth and the New England region to achieve early delivery of SAF to our airports
and establish a foundation for developing a regional SAF industry. By leveraging the region's
high-tech, clean -tech, and academic strengths, sourcing regionally derived feedstocks, and
promoting infrastructure development, we can not only help the region achieve its climate
goals but also create economic benefits and jobs related to the production, handling, and
delivery of SAF.
B a c k gr o u In d
The U.S. and global aviation industries have set a goal to be net zero by 2050.1 The FAA has
identified SAF as the critical pathway to de -carbonizing aviation. The Massachusetts Climate
Chief Report emphasizes the importance of SAF as a key component in reducing emissions
from long-distance transportation modes and achieving the Commonwealth's climate goals
(Figure 1).2 3 The report also identifies high speed rail as a strategy to accommodate short
haul trips such as Amtrak's Acela service in the Northeast Corridor (Boston -New York -
Washington DC).
The FAA and major commercial airlines plan to achieve net zero by 2050 through a
comprehensive set of actions (Figure 2).4 These include advancements in aircraft
technology and operational efficiency, new engine propulsion technologies such as electric
aircraft, the implementation of higher standards for engines, and the adoption of
sustainable aviation fuels.
1 INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA), Resolution on the Industry's Commitment to
reach Net Zero Carbon Emissions by 2050, (October 2021)
I�ttas, �nr�nr�nroiataorar c:�aiuteiutassetsc9 d784f75l,,)ac:90f0 760e998 i t _ . i ._
A..................................................................................................................................................................................................................................................................................................................................................................................................................................................................................
L2olution-rain-net-zero-carl,,)on-.missionsola f (last visited March 31 2025).
....................................................................................................................................................................................................................................................
2 FEDERAL AVIATION ADMINISTRATION, United States 2021 Aviation Climate Action Plan, p. 21,
(November 9, 2021)
I�ttas, �nr�nr�nrofaao��rav sites Essorav files 2Ci2 f f f Aviatirai�:lirnate Ac:tiraiu Iflaiuoadf last visited
l. ................i.i..................................................................................................................................................i............................i......................................................�..................................................................................................................................................................................................I..................
March 31, 2025).
'THE OFFICE OF CLIMATE INNOVATION AND RESILIENCE, Recommendations of the Climate Chief, p.
47 October 25 2023 ittt s, vt vt vt .rmass. tav drat rer-ormrmendatioris-of-tile-r:limate-
ccr:7'!„-7.7. (last visited March 31, 2025).
4 UNITED AIRLINES, Corporate Impact Report 2024
I�ttas, c:eliwara 2i.giMI2a to!Inj edoc:elm enviiwranmental.srustaii�al�ilit our-enviiwranmental .str t�-�
A...............i.i.....................A......................................................I................................................................................................/.........................................................................................................................................................................V...�............................................................................................................................................................�.yi..
(last visited May 12, 2025).
0
Figure 1
Analysis of Future Domestic and International Aviation CO2 Emissions
Million Metric tons CO,e
140
120
100
so
60
40
CM Reet renewal
CMFuture AC technology
amOperational efficiency
2.2% Alternate propulsion
20
0
2019 2022 2025 2028 2031 2034 2037 2040 2043 2045 2049
Sourcc00i[6tcd States, Corporate limp. act R'elport 2020
Figure 2
United Airlines -'Illustrative Decarbonization Roadmap
M��
The Commonwealth, through MassDOT and its airports, is actively engaged with new
electric and hydrogen fuel cell aircraft start-ups to advance the industry and prepare our
airports with the necessary infrastructure. For example:
• Beta Technology, a small electric aircraft manufacturer headquartered in Burlington,
VT, is installing charging infrastructure throughout the Northeast including
Massachusetts airports - Hanscom Field, Marshfield Municipal Airport, and
Westfield -Barnes Regional Airport.5
• Cape Air, a regional carrier based in Hyannis, MA, is partnering with Eviation for an
all -electric 9 -seat aircraft.6
• Alaka'i Technologies, based in Stow, MA, is testing a hydrogen -powered electric
vertical and takeoff aircraft (eVTOL).'
• MassDOT is also engaged with the Advanced Air Mobility/Integration Task Force
(AAM/ITF), a collaboration between government, industry, and academia, working
together at the forefront of air mobility to support infrastructure and operational
needs, aiming for a cleaner, greener and more equitable air transportation future.
Irmage.T -Alice: Electric Aircraft Prototype
5
BETA TECHNOLOGIES, Charge g network, Ittl:`.:'i..:..:...:....!.::.�:...!:.g..., (last visited May 12, 2025).
6 Y 9 f I�tta:`.: 1:......::...:.........:..:......:............�aI:ut........!�s future -
fu i�v�rv�rvar..ri..��i� coin .................................
CAPE AIR, Sustainability: Moving to an electric uture, .. ......................
.of, eIe trJc ayi at„i.2..n„oJ,]trn„I„ (last visited May 12, 2025).
' I�tt a:`.:' i'I<.gi (last visited May 12, 2025).
ALAKA I TECHNOLOGIES, Skai,
I. ii corn
While new aircraft and propulsion systems are crucial for the long-term clecarbonization of
the aviation industry, they alone will not achieve the industry's clecarbonization goals.
Factors such as aircraft size, travel distances, the current state of battery and hydrogen
technologies, and the lengthy certification process for new engines and systems all
contribute tothis oha||enge.o
�us�aima�|e�V�U�m�ue|s
1 heL(5� Aviotio/ C/trote Actio/ Pbn) asdrop-in|iquidhydrocarbonfue|s
producedfromrenevvab|efeedsLocksCH' bio+masLemateria|svviththesameperformance
andsafety asconventiona|]et fue|s, musLmeetsLandardsdeve|opedbythe
American�ocieh/andVlateria|s(A�TVI) to, ensurethesafeuseoffue|sinf|i�ht
operations, Todate,thehi,�,'1hesLb|endedradoapprovedfar safe operadonsisSO"'N
�AF
with 501'�, conventiona|]et fuel, FAA, researchers, and indusLry are vvorkinf"to
achieveOO"�, foroperations,
The aviation indusLry hasa|so reco�nizedthat�AF musL be produced su�ainab|yFor
examp|e,|[AOadoptedthe[arbonOfNettin�',andReduction�chemefar |nternationa|
Avation ([O�|A),, which a comp|ete setofcriteria ran�in�from
|and/aquaticsysLems,water qua|ih�|anduse,to, |oca|andsocia|deve|opmentandfood
security, There are aka, state |eve| requirements re|atedto susLainab|efue|s inc|udin�,
[a|ifornia'sLom �arbon Fue\4assachusetts'A|ternativeEnergVPort�o|io
�tandardThe[|eanEner,�,,1yand[|imateP|anfor2OSOaka,
provides
specificon susLainab|e biofue|s,
Although the U.S. produced 26 million gallons of SAF in 2023, about 0.1% of the nation's jet
fue|use,SAFproductionisquiok|ynanopingupasnevvp|antsbeoonoeopenationa|.yToday,
most of the SAF used in the U.S. is produced in Montana and California and used at airports
8 FEDERAL AVIATION ADMINISTRATION, United States 2021 Aviation Climate Action Plan, p. 18,
(November 9,ZUZ1)
/Aviation Climate Action Pla.n.,j,.�f (last visited March 31, 2025).
9 U.S. ENERGY INFORMATION ADMINISTRATION, U.S. production capacity for sustainable aviation
fuel togrow, (July 17,ZUZ4), Uast
visited May 12,ZUZ ).
7|Page
in California, where the regulatory and policy environment subsidizes the current cost
premium associated with the production, blending and delivery of SAF.11
While SAF's primary advantage is its easy integration into the existing jet fuel supply chain,
it comes with higher logistics and cost challenges, making it up to twice as expensive as
conventional fuel. This is due to the complex SAF supply chain, which includes feedstock
supply, non -feedstock inputs, preprocessing, logistics, pretreatment, conversion, blending,
and various regulatory approvals. These factors add to the cost, whereas conventional jet
fuel has been optimized over the years to remain cost-effective."
As SAF production increases, several states are implementing measures to help pay for the
SAF premium and derive benefits from related economic development. For example,
Illinois, Minnesota, and Nebraska offer tax credits to support SAF. There is an opportunity
for Massachusetts to engage similarly by implementing a statewide SAF strategy to further
the Healey -Driscoll administration's goals of advancing economic development, growing the
clean energy and climatetech sectors, and leading the fight against climate change.
Economic development opportunities could be wide-ranging from SAF production and
supply chain to advancing innovative green technology to produce synthetic SAF.
Establishing SAF production facilities creates jobs in manufacturing, engineering, and
operations. Investment in SAF technologies stimulates employment in the research,
development, and innovation sectors. Developing distribution infrastructure, including
transportation and storage, would similarly create new employment opportunities.
The clean energy and clean technology sectors (along with "blue tech") have been identified
as drivers of future employment and economic growth.12 Massachusetts has a rich
innovation ecosystem that can be leveraged to develop a statewide SAF strategy. For
example, MIT is currently undertaking FAA -funded research on the SAF supply chain and
io OFFICE OF GOVERNOR GAVIN NEWSON, Governor Newsom announces first -of -its -kind partnership
with airlines on sustainable aviation fuel, news release, (October 30, 2024),
IttAa....Q.? L'ewsom..announccs..first..of..its..kind..
............................................................................................................................................................................................................................
.
Isalt!l]iI�.....-.With..airline.o~..sustainal,,)lc..aviat..i..o.i]...f!c.l.i
.. ......................................................................................................................................................................................................................................................e.a.t..:.......O.c.t.%.2..C.3.C.%.2 ....%.2..C2.C.2.................
.
R.:.overnor 20Ne som%2Canounccs%20first%2Dof%2Dits%2DI<.ind%2C.I.a ..[1new .h.iI.a.2
nithRto
..................................................................................................................................................................................................................................................................................................................................................................................................................................................................................... ....%.. Cr................. ............
!ufold%2QJnciweasc%20from%20c:ui rent%2Cilcvels (last visited May 12, 2025).
11 NATIONAL RENEWABLE ENERGY LABORATORY, Calderon, O. R.; Tao, Ling; Abdullah, Z.; Moriarty,
K.; Smolinski, S.; Milbrandt, A.; Talmadge, M.; Bhatt, A.; Zhang, Y,; Ravi, V.; Skangos, C.; Tan, E.;
and Payne, C., Sustainable Aviation Fuel (SAF) State -of -Industry Report: State of SAF Production
Process (July 2024), .;Ott,.l`i..::.i'.i....:`...!i..l:.......g......................::::.i..V....,,rat,.!...........Iaf (last visited May 12, 2025).
doc.....
iz MASSACHUSETTS HIGH TECHNOLOGY COUNCIL, MassVision2050: Massachusetts Innovation
Sectors httI.a.....5:.....................................................................................................................5 ........isio. 2.05. .i~ novation-scctors .(last visited March 31
......................................................................................................................................................................
2025).
leads the Zero Impact Aviation Alliance (ZIAA), a group that includes Delta Air Lines, the
Boeing Company, Pratt & Whitney, World Energy and Massport - representing the full
aviation value chain. World Energy, the world's first commercial -scale producer of SAF, is
headquartered in Boston. The Commonwealth and the SAF Workgroup can draw on the
knowledge of local strategic management consultants and technology innovators that
possess expertise on SAF economics, technology, and logistics. In 2025, Lydian Laboratory, a
local MIT spin off company, will be producing synthetic 13sustainable aviation fuel in its
Charlestown R&D facility and plans to scale up production at a pilot plant located in North
Carolina. In addition to its Massachusetts connections, Lydian's technology is of particular
interest because it has the potential to reduce aviation emissions to near zero by 2050 and
is not dependent on bio -based feedstock.
State hnterageincy SXF Wurkgroup
States have a critical role to play in incentivizing the use of SAF as well as identifying
opportunities to promote economic development through production, delivery, handling,
blending and storage of SAF. Recognizing this opportunity, an interagency SAF Workgroup
was formed to:
1. Research best practices and current models of SAF adoption at the state level.
2. Identify existing federal and state programs that could be leveraged to support SAF use
and development.
3. Identify areas of opportunity for economic development within existing offerings and
explore new ones.
4. Identify stakeholder engagement needs to build an ecosystem for SAF advocacy and
support.
Based on these objectives, the SAF Workgroup identified a series of recommendations that
will align Massachusetts with the best practices of other successful states and position the
Commonwealth to be a leader in SAF adoption in the near term and, in the longer term,
incentivize an ecosystem of R&D activity, infrastructure deployment, and advocacy/support
for a SAF economy.
"Synthetic SAF, also known as power -to -liquid, is made through carbon capture and green
hydrogen (i.e., hydrogen produced from water). This is a technically challenging pathway both
on the production side and the need for green electricity. However, innovative start-ups are
successfully producing SAF at smaller scale today including Twelve from Berkley, CA, and Lydian
Labs from Boston.
Members of the SAF Workgroup included staff from:
• Executive Office of Energy and Environmental Affairs (EOEEA)
• Executive Office of Economic Development (EOED)
• Executive Office of Administration & Finance (A&F)
• Department of Transportation/Aeronautics (MassDOT)
• Office of Climate Innovation and Resilience
• Massachusetts Clean Energy Center (MassCEC)
• Massachusetts Port Authority (Massport)
The SAF Workgroup met bi-weekly beginning in December 2024 and concluded its work in
May 2025. They engaged with outside experts and compiled a library of background
materials to support the recommendations and serve as a reference for future work on SAF.
The team engaged with the following outside experts and organizations:
• Airports, Airlines and Fixed Base Operators
o Delta Air Lines
o JetBlue
o Jet Aviation
o Signature Aviation
o Westfield -Barnes Regional Airport
• Federal and State Government Entities
o Minnesota SAF Hub
o National Renewable Energy Laboratory (NREL)
o United States Department of Energy (U.S. DOE)
• Non -profits
o Massachusetts Airport Managers Association (MAMA)
o Mass Mobility Hub
• Start-ups and SAF Manufacturers
o Lydian Labs
o World Energy
• Universities
o Massachusetts Institute of Technology/Zero Impact Aviation Alliance
,D bs e Iry a t II an s and II: II Ird In
Through research and engagement with experts, the SAF Workgroup identified the
following key observations and findings related to aviation and SAF, which informed the
recommendations.
SAF nch..isir"y Co nlexl
Production
• SAF is a "drop-in" jet fuel, which means it can be mixed with or used as a direct
replacement for conventional jet fuel without any modifications to aircraft engines or
fuel infrastructure.
• Based on current safety standards, neat SAF (i.e., 100% SAF) must be blended with jet
fuel up to a maximum ratio of 50%. Today, the most common blend ratio is 30% SAF.
The FAA and the aviation industry are working towards permitting commercial aircraft
to use 100% SAF.
• SAF can be produced from a variety of non -petroleum-based renewable feedstocks
approved by the FAA including waste fats, oils and greases, agricultural and forestry
residues, and municipal waste, as well as fuels produced synthetically.
• Neat SAF must be produced using feedstocks, methods, and delivery channels such that
greenhouse gas emissions over the life cycle of the fuel are reduced, and the production
is sustainable. Research in this area points to pathways, shown in Figure 3, that present
the right combination of reducing greenhouse gases while using sustainable sources
such as converting waste fat, oil, and grease stocks (i.e., the hydrogenated esters and
fatty acids, or HEFA, production pathway).14
14 INTERNATIONAL COUNCIL ON CLEAN TRANSPORTATION, Andy Navarette, Nikita Pavlenko, and
Jane O'Malley, SAF policy scorecard: Evaluating state -level sustainable aviation fuel policies in
the United States, pp. 3-4, (November 2024),
Itt a....5,it�.....cic.ctoor vI.....-225.%L2%80%J3.SAIF.scorec .rd fi.nal..a.....dfil..........................................ci...............................................................................................................................................................................................................................
(last visited March 31, 2025).
111 Page
2023 Jet fuel consumption
25.1 [ km r011arr,
Fa,,,.01 CI 1Jgg CO o/l-1J
Domeal4c supply
Fuel potentlal
pathway (l,oa;iae� o�izrl]ue�t/ynaa.r)
Carbon I.ntonailyr
CI) co',c^dt"IJ)
GHG reduction "%
100 p o G
Eatlmatepd production
cost (S/gallon) Technology
(Low - Medlaan - High) readiness
Waite oil HEFaO
I '1
&) U3 - &4on f r, rt.a
,do
Soybean oil HEFA
0..7-21
SA 00) - S5116 - S5.219
C oraivuu,r,I
01; ruG.i0r,
Corn grain alcohol -to -pet
6 1)
�
x,.30 - S&Oe - t76J,
t'rm al ry ru7
Municipal ®olid wauto gaalPlcatlon
to
12 .,c - ffi4.47 16 V)
Agilcultural rasAduo ga'sIficetlon
4 9
55 IS - $7..9995 - 4n2-2
tii riro i.lrilir ra
Other aecond-generatlon feedstocks
3
31- $7,41 - H0 41
Powe r-to-lIquids
S�
2C .5 - SO - 502 40
rt Y 'JV nCYCA'�a
III�01111111111
-21
sourcelolternalatla)mfl Ca)1)n d oil Uea n � ra nsO ortalttlon' 20221I
Figure 3
Key Characteristics of Relevant SAF Pathways in the United States
Demand
• In the U.S., the aviation industry uses about 29 billion gallons of jet fuel annually. SAF
production is in its infancy with current production at 93 million gallons through
September 2024 (Figure 4). However, SAF production is ramping up and is expected to
reach billions of gallons by 2030 and beyond. 11
1s U.S. DEPARTMENT OF ENERGY, U.S. DEPARTMENT OF TRANSPORTATION, U.S. DEPARTMENT OF
AGRICULTURE, U.S. ENVIRONMENTAL PROTECTION AGENCY, Sustainable Aviation Fuel Grand
Challenge October 2021 —September 2024 Progress Report, pp. 3-5, (December 2024),
V1PV1PV1Po2.22.1 r 19 5 5.. dcfaLult dile. .2 25 -Cid oaf.. IwC3• Iwe Iwe aralwt 2Ci2 o adf last visited
L...............i.i......................................................................................i.................................................................................................................................................................................L..............................................................L...............................................................L.................
March 31, 2025).
121 P a g e
Doawsfic �Vvu Sept 2.0,24)
t�
r �r
Ilcnp r S (hru Sept 202�
2016 2011 :2018 p'l19 90 20121 1 X22 M23 A124
thrill Sept
Source: l.USDO6:, USDO �, USDA, USV,::PA, `usta nalW e Av�aflon F ud Grand Chaff lreng e Oti:4rxb er
2023 -September 20221II Progress Report
Figure 4
U.S. SAF Production
• Industry projections shown in Figure 5 indicate that the U.S. could surpass its SAF target
of three billion gallons a year by 2030.16 Projects in various stages of development and
backed by an estimated $44 billion of investment already represent more than the
annual three -billion -gallon target. 11
16 Ibid., p. 16.
17 Sofia Cabrera, DOE Report Says US Domestic SAF Use Grew Significantly Under Biden, S&P GLOBAL
(January 14, 2025),
I�tta , v�rv�r�nro a lol� loc:orn c:ornrnradit in sA...............i.i...........................................I.....i............................................................................................................................V............n. news -reward' .ilatest-
..................i ........i................................................................................................................................
n Jnr . iwi�:�ult�uiw Ci � 2 drac iw arai t �u ..dorncstic-saf.-. use r ver si ��i�ifi�:an l �ui�d�iw..l,,)iden
............................................................. i...............................................................................................I..........................................y................................................................................................................................................................................................................................ y................................................................................
(last visited March 31, 2025).
131 P a g e
R
I
E
Low N � rsICAncal S AF KgOnNV[
'4
HJ,5VI Holwk,,M 95AF PolpmW
L01w riukofl SAF RXiMbM
Htl;,�hFutaft
AduaJSAF Prx)O*d
-4p-
Adual'RID, PrvIxed
2
I
IE
M2,1 2022 2 1 (Y2 3 2024 M25 2026 2,021 M28 2029 .,1,030
Source: USDOE, LJSDO , LJSDA, USEPA, Sustave naWe Avvaflon Fud Grand Chzfflenge Oclober
0 2023 -September 202211 Progress Report
Figure 5
U.S. SAF Production Potential
141 P zi g e
Policy Landscape
• States are successfully utilizing incentives and subsidies to help pay for the SAF cost
premium and the development of related production/blending/storage/delivery
infrastructure (Figure 6).18
ffJ LCFS or similar policy in,force JJ� Pen&ng orffailedl LCFS orsimilar policy No reported activity
Conversations in progress, on LCFS or similar policy Previously considered LCFS
= Directin cent.iives for SAF ire the states. of Washiinigton, Colorado, Mir�nesata,. and. Illi nws.
SourceRMI aao'taalt l s of state poky offices
Figure 6
SAF Policy Landscape and Exiting SAF Projects
• Today, most of the SAF produced is shipped to locations where the regulatory and policy
environments support SAF use by providing subsidies to help offset the SAF cost
premium.
• Successful states have taken the initiatives through regulatory, tax, and targeted
investments to develop a SAF economy that incentivizes the local use of SAF and aligns
strategic economic development initiatives to include SAF.
18 Andrew Chen et al., Refueling Aviation in the United States: Evolution of USSustainable Aviation
Fuel Policy,RMI 2024 Ihtt as, Iwlnioralw'! 'insi lit Iwef�uelili aviation -in -the-pus-evolution-of -�us-
I................i.........................................AZ.....................g.............�'..................................................g...........................................................................................................................................................................................................................
5.�u5tailial,,)Ie-ayiati.onf�uel-i, 2.!.iLY'„ (last visited May 12, 2025).
.:...... ........ ...... ......
151 Page
Infrastructure
• The Massachusetts airport system, as shown in Figure 7, consists of 38 airports including
commercial air service airports, general aviation airports, and facilities with shared
public and military use. MassDOT Aeronautics oversees 35 airports and Massport owns
and operates three including Boston Logan International Airport, New England's largest
commercial airport and international gateway with services from more than 50 airlines,
including major carriers that have committed to reaching net zero emissions by 2050
and 2040, respectively.
IJedinku RS?� �„ Au 1VUp
�i vo4U IlYvall
Vt"hW II.{I.
U nm,lr¢•I YQf�Y.I)
Uri Vag r �4JYV wI
�
ff Y 6lGf
a arJ��, r4 fp l"tl
�WlJp1�J �Lh "roh 11 ll
/.
uv"au Ib. of vgorui
_.
P�'I�nhu(I
i(114
�..
V4 aaM d a
tiwi A¢i ^+rE I4aNcd �w'A IbklfAl 0'PV V. U:$
fns✓pwa ti'RNRrc phkvvy✓ .�
"
,.
5Cr✓Y,hfrrrU4m
"AM
C OMN9C.RLIAL S.til{W L AIHY+C:)W.IS
GENERAL A'dNMN ON AYNYF"L R TS
ii AfLt fRf
Figure 7
Massachusetts Airport System
Ihr,• k rs Fry r[uzl
R9m� r.u1(�✓rxH d.r ia�E.r .�t�#
� Ewsraac,us�c�Pa �:, au�tr
"ID914 P
Iu,w+� r 4rrua iti
�'Nbdl
m dl"
�' PV.v rv+IC'mnBYn,ii VA 't r,A�aal9 6nr
Al {20U
MAu NuT..PF ;RI AM Niue Au urP al4l5!
Jr rm, � f Nr�rj
N1,1,W1,01 1 (At 1,1
Source': MassDM A eronwifics DMs�on
• Other major airports outside of Massachusetts that are important to the regional airport
system and future SAF use include Portland International Jetport (ME), Manchester -
Boston Regional Airport (NH), Rhode Island T.F. Green International Airport (RI),
Hartford Bradley International Airport (CT), and Patrick Leahy Burlington International
Airport (VT).
• The New England states used about 674 million gallons of jet fuel in 2023 according to
the U.S. Energy Information Administration.19 Massachusetts accounts for about 90% of
the region's consumption, or about 494 million gallons.
Economy
• The U.S. and the world economies are highly dependent on civil aviation for connecting
communities, facilitating business interactions, and supporting demand for goods and
services. U.S. civil aviation directly or indirectly supports $1.8 trillion in total economic
activity and 9.4 million jobs.20
• Aviation is also critical to the competitiveness of the Massachusetts economy with travel
intensive industries such as high tech, biotechnology, higher education, financial
services, and tourism. Massachusetts airports contribute over $24 billion to the
Commonwealth's economy annually and support 200,000 jobs in the state.21
• Massachusetts is the headquarters for 16 Fortune 500 companies (e.g., Liberty Mutual,
TJX, State Street, Biogen, Vertex Pharmaceuticals, etc.) and diverse businesses and
entities including renowned health care institutions, high technology and biotechnology
companies, specialized manufacturing, financial services, management consultancies,
and top-ranked institutions of higher education. These prominent businesses and
institutions that rely on air travel and have their own decarbonization goals can bring
meaningful corporate leadership and resources to ensure SAF adoption.
• Massachusetts has a proven record in state programs and initiatives that support clean
energy and climate technology, manufacturing, R&D and commercialization,
infrastructure, and economic development to potentially support the development of a
SAF economy.
• Massachusetts is also home to significant university and private -sector research entities
that are well situated to help address potential scientific and technical hurdles to SAF
production and delivery.
19 U.S. ENERGY INFORMATION ADMINISTRATION, Table F2: Jet fuel consumption, price, and
expenditure estimates, 2023,
�nr�nr�nrocioottccd dto alp a?inc:filc=== Sttccdc a f�ucl I�trnl f�ucl "fol�trnl last
1................i.i............................................................L................i.......
.......................................................................................1...............1................ ....................... ...................i ............
...............................................................L....................................i..............................i.................................IL.....................................
visited March 31, 2025).
20 FEDERAL AVIATION ADMINISTRATION, The Economic Impact of U.S. Civil Aviation, September
2024,
I tt.l :`i..::.i . v�ro ..... p....:.:::�".�.p..i"i.p..fi!..!_c..-..!..!" ..I ..:.:::!:...I raiwt (last visited May 12, 2025).
21 MASSACHUSETTS DEPARTMENT OF TRANSPORTATION AERONAUTICS DIVISION, Statewide Airport
Economic Impact Study Update, p. 2, (January 2019),
I�tta : v�rv�rv�rorn o o doc: ciwon �utic:.cc:onomic-i.mj, �c:t �t�ud 2019 dov�rnlo�d(last visited
1................i.i.........................................................................i................i.......................................................................................................................................................................................I.........................................................V....................................................................................................
March 31, 2025).
171 P a g e
• Massachusetts' economic strengths in R&D, innovation, venture capital, and high tech
are a natural fit for innovative technology and processes related to synthetic SAF.
• According to a survey conducted by ICAO among aviation industry stakeholders, climate
change presents specific business risks to aviation. These risks include physical threats
such as rising sea levels and storm surges, which can affect access, infrastructure, and
operations at coastal airports. Extreme weather events, higher temperatures, and
changes in wind patterns may lead to increased flight cancellations and delays,
infrastructure damage, and payload restrictions, meaning flights would need to carry
fewer passengers and cargo in hotter temperatures. The combined effect of these risks
can lead to significant financial losses for airlines.22 For example, a study from the
University of Illinois and University of Michigan estimates that climate change can
significantly impact the ability of airlines to recover from operational disruptions,
concluding that estimated daily recovery costs can increase by 15.7% to 49.4%, on
average.23
• The FAA identified SAF as critical pathway to de -carbonizing aviation. Neat SAF (i.e.,
100% SAF) can reduce greenhouse gases by over 90% depending on the feedstock and
production process.24 While the U.S. produced 26 million gallons of SAF in 2023, which
amounts to approximately 0.1% of the nation's jet fuel use, SAF production is quickly
ramping up as new plants come online.
• Tackling the Commonwealth's (and the region's) aviation -related carbon footprint is
consistent with the Commonwealth's legislative mandate to achieve net zero by 2050.
22 INTERNATIONAL CIVIL AVIATION ORGANIZATION COMMITTEE ON AVIATION ENVIRONMENTAL
PROTECTION, Aviation and Climate Change Factsheet, 2020
I�tt a : �nr�nr� ic:2oJ.nt enviiwrai~�i� ental. aLgjat �::tiran Doc:�ui� ent,Eaa tsheet Business and Economics
I................i.i...................................................................................Z.................................................................................................I..............................................................Z..........................................................................................................................................................................................................................................................................................
.E.] n a1,o,,la f (last visited April 16, 2025).
23 Jane Lee, Lavanya Marla, and Parth Vaishnav, The impact of climate change on recoverability of
airline networks, Transportation Research Part D: Transport and Environment, Volume 95 (June
2021) Itta: v�rv�rv�roc:iciuc:cdiiwcc:toc:ornc:iciuc:ciwtic:lcI:� aii t3t92Ci92tCi6tCiSy lastvisited
...................I.....................................................................................................................................................................................................................i............................................................../..I.............i......................................................................................................................................
May 12, 2025).
24 Prussi, M.; Lee, U.; Wang, M.; Malina, R.; Valin, H.; Taheripour, F.; Velarde, C.; Staples, M. D.;
Lonza, L.; Hileman, J. I., CORSIA: The first internationally adopted approach to calculate life -cycle
GHG emissions for aviation fuels, RENEWABLE SUSTAINABLE ENERGY REVIEW, p. 7, (June 2021),
v�rv�rv�ro c:iciuc:cdiiwcc:toc:orn c:ici~.... . tic:lc aii 136403212:tC 06833 sec:tioi� cited I:� last
I................i .i.....................................................................................................................................................�'.......................................................................................i ..I.............i.........................................................................................................................................................................................................................................y
visited March 31, 2025).
• One of the recommendations from the Massachusetts Climate Chief is for Massport and
MassDOT to develop a plan to reduce aviation emissions including consideration of
alternative fuels. The Report also recommends advancing SAF in Massachusetts. zs
SAF Conskieralions
• If the region sets an initial target of 2% blended SAF, the total neat SAF needed would
be about 13.5 million gallons for New England and 10 million gallons for
Massachusetts. 26 The target percentage and fuel standards could be raised over time as
SAF options become more available. For example, the European Union has set SAF
adoption goals with a minimum 2% target in 2025 ramping up to 6% by 2030 and 70%
by 2050, with explicit exclusions for crop -based fuels and increasing percentage
standards for synthetic fuels that utilize clean electricity as the primary energy source.27
• Existing Massachusetts, California and international policies and recommendations, and
industry research and standards will inform the appropriate policies the Commonwealth
should pursue related to approved feedstocks and a net greenhouse gas emissions
reduction target. For example, some midwestern agricultural states follow U.S. EPA
guidelines and set a minimum net greenhouse gas emissions reduction standard of 50%
when compared to fossil -based jet fuel on a life cycle emissions basis. Massachusetts
has historically exceeded minimum recommended guideline, for example by limiting
eligible feedstocks to wastes such as used cooking oil and forestry residues.
• Feedstock options that may be advantageous for Massachusetts and the New England
region include municipal waste, waste oils, wood wastes and residues, and synthetic
fuel technologies that draw carbon directly from the atmosphere. A proposed state and
regional planning study (see Recommendation 1 below) will provide guidance to inform
policy related to feedstock options.
2s THE OFFICE OF CLIMATE INNOVATION AND RESILIENCE, Recommendations of the Climate Chief, p.
47 Recommendation 18, (October 25, 2023), InttI�5.:;..i
-of-
. o a��tia� m......... .................
the-c:lunate-chief-octol,,)er-2 -2023(last visited March 31 2025).
.......................................................................................................................................................................................................................
26This corresponds to approximately 100,000 metric tons of carbon dioxide emissions or, using a
recent U.S. EPA value of $190 per ton, $19 million dollars of potential avoided damage from
climate impacts of the combustion of fossil jet fuel.
27 EUROPEAN COMMISSION, European Green Deal: new law agreed to cut aviation emissions by
promoting sustainable aviation fuels, press release, (April 15, 2023),
I�tt a c:o �uiwra a o �u c:ornrni irai� aiw c:oiwi�ciw d t it en/i.1, 2.3 2389 last visited May12
L...............i.i.................................................L............................................................................................................L......................................................................i..........................................................L................................................................... (
2025).
"� e c ar n Ir n en d a t b In s
Based on research and discussions with various experts, the SAF Workgroup identified five
recommendations that cover a range of actions to achieve successful implementation of
SAF including: baseline logistics planning, stakeholder, and multi-state/regional
engagement, leveraging existing resources and programs, and state policy and legislation.
By enacting these short-term and long-term recommendations, Massachusetts, in
collaboration with industry, neighboring states, and other critical partners, can pursue
opportunities to pilot technology and implement meaningful policies and actions. This
approach aims to position Massachusetts as a leader in the early adoption of SAF,
potentially reducing life cycle aviation emissions dramatically (e.g., to near zero by 2050). As
discussed in this report, a key aspect of any implementation plan will be to establish policies
that support sustainable aviation fuels that do not compromise food security or have
adverse environmental outcomes.
Recommendation 1.
Undertake a regional planning study to better understand SAF production,
transportation, delivery, storage, blending and usage, the current jet -fuel supply chain,
potential for future blended SAF delivery, and regional feedstock opportunities.
A critical first step in the adoption of SAF and laying the groundwork for future
infrastructure development is a baseline study of the current supply chain that delivers jet
fuel to Massachusetts and the New England region, from production to delivery, storage,
and usage. The study should also assess the supply chain for the delivery of SAF to the
region in the short term as well as the regional production, handling, blending and delivery
of SAF in the long term. The logistics and planning study should take a regional approach
that includes all the New England states and New York.
Therefore, the SAF Workgroup recommends engaging with national experts as soon as
possible. The SAF Workgroup identified the U.S. DOE - NREL as a potential partner. NREL has
conducted similar studies around the country including a recent report for the Port
Authority of New Yok and New Jersey (Figure 5). In addition, scientists at MIT are currently
working on behalf of the FAA on sustainable aviation fuel and should be considered as
advisors to the study.
�riw ,�NIbt14 � � , � �vrram✓+a�ii,z
mU u6,,a t 6W �
m �rrrJ�aa�r�luAlva
9 i1.
Port Authority of New York and New
Jersey Sustainable Aviation Fuel
Logistics and Production Study
Kriskil Moriarty, AneU4a MilbTarrdt, and Ung Fao
NW,"' PY LS➢L qy Lab"Muy
NI@E4. isr�u tbnorotoey mi I S 9)K, � vi+C n�f�iuwrgw aii feQmDnr
pf�ise art F:n dH rnrv5 ¢8e W F�e�gu �eic
tMem�nreAYmsm All nmce fimr 5aaalnen�le f'.@W{VyI.L r,:0—Ir..i
.: rmpmtlY nu warn iv.msi aw�cwonna Enwti}Y
GimirrvuM1 Wm.0#F,-kf�YRQMIIL"W�,19q
Image: 2 U.S. DOE NREL Study for Port Authority of New York and New Jersey
To complement Massport's efforts, MassCEC plans to undertake a sector mapping study
of sectors with low -replacement rate infrastructure and complex decarbonization
challenges, such as marine and aviation. The study is intended to identify key industry
decision makers, levers for change, geographic distribution of infrastructure, and short-
term vs. long-term implementation recommendations. In addition to SAF, the study will
also explore electrification and hydrogen feasibility and recommendations for aviation.
Recommendation 2.
Create a Massachusetts and New England Region SAF Hub to include major employers,
academic institutions, and key aviation industry groups including airports, airlines, and
general aviation users to secure buy -in from key stakeholders, facilitate information
sharing, and identify priority short- and long-term initiatives that build SAF momentum.
A best practice the SAF Workgroup identified is the creation of a SAF Hub, a partnership
that includes a range of businesses and other stakeholders working with the state to: 1)
advocate for and support the delivery of SAF at regional airports; 2) create state policies to
support SAF production and use; 3) bring together innovators, producers, suppliers, and
transportation companies to coordinate SAF logistics; 4) identify and take action on short-
term initiatives that support the long-term commercialization of SAF; and 5) share reliable
and reputable information across key public and private stakeholders.
211 Pag(.
This successful model is being used in Minnesota (the Minnesota SAF Hub) and includes
major local employers across different industries, Delta Air Lines (Minneapolis -St. Paul is a
Delta connecting hub airport), academia, and nonprofit organizations (Figure 8).
Anchor Partners
0' XcelEnergy"
A, D E LTA ECOLAB" "9,
�1 McKinsey
B A r� cw a nn w i c A '° & Company
Forever
Green
Figure 8
Minnesota SAF Hub
supporting (Partners
Gi 6MINNESOTA
FOREST
CESSO
SRC ES.
Geos 'nQec""
4 rz�1ra.( Iteiiiiru[u(,��Jpo iia, SCCA uut Paull Rcgiio mall f: ILOJru01[r�,L Development ent fair nci,sNlp
Massachusetts participates in successful national, regional, and state consortium models,
particularly in the Offshore Wind sector, which can be emulated. MassCEC currently
participates in and/or leads:
• National Offshore Wind Research and Development Consortium (NOWRDC) (Figure
9), convened by U.S. DOE and New York State Energy Research and Development
Authority (NYSERDA) is a "nationally focused, not-for-profit organization
collaborating with industry to accelerate the deployment of offshore wind energy in
the U.S., address challenges and obstacles facing the offshore wind industry and
221Pag.^
maximize economic and social benefits, and reduce the levelized cost of energy of
offshore wind in the U.S." 28
TechrflcM scop port and funding for an international canllaliuoratiicnn Titin Innovate UKtcn
riesign and ruun coordinated grant sollicitaticuln (NOWRlDC .fi)
Xm l li Ipp' ,: �, I ( .'i;f ft is I rLrr"i .ill, (.)CS , ."'lr ,r �Yfii'i°/'� ,Jf1
d 't S'. rir s la Y�)i�ilf �r Il;,,. r "� �PIYi( u', ,! ��i� I J !;[J
,}�tG,
fr r rl ej "A Lrtrr r 0kF r d fl ,r; irl
l.lin'iverAyr ref Ma ,,achE.u,nwtha Lowell -- 0SW"w! bl acfa: mcnriitonri , na ;'Img clxYrlpOer visiiona P;u. Al
Rifts trove irsityr INos /el ilbuiid filirrn fil. n rrairnrl U rbiinc , nri ain hak arl inti alpsfrllr ..ipjorn
Technical support and founding for up to $10.6M in projects that addiress severM
umayor areas of need for floating offshore whid (No1N'R91C 4.0)
Pi irJj, yr,r i'f iHAi i a.J,r, 1oi :d Illi I]f.
Ire 'ire C rr lirl (' rnd' i r'F, err 11'o ;I
3. Ifr,r i. `F 'ki6!j vctk... iuJ 11 i<r ?r'dfo,/ii, Ill lir, 11'%f -,f,,) ri. %!�", (;
Figure 9
MassCEC Offshore Wind Partnership in Research and Innovation
0 NATIONALOFFSHORE WIND
Innovate UK
+w ro
U CLEAN ENERGY.
CENTER
Maryland. 0
• Regional Wildlife Science Collaborative for Offshore Wind (RWSC), sponsored by
NYSERDA and led by federal and state government, offshore wind companies, and
environmental non-government organizations. "RWSC collaboratively and effectively
conducts and coordinates relevant, credible, and efficient regional monitoring and
research of wildlife and marine ecosystems that supports the advancement of
environmentally responsible and cost-efficient offshore wind power development
activities in U.S. Atlantic waters." 29
• Massachusetts Fisheries Working Group on Offshore Wind Energy and
Massachusetts Habitat Working Group on Offshore Wind Energy, both convened and
led by MassCEC. "While the working groups are voluntary and informal, each
provide a critically important forum for maintaining a dialogue with key
stakeholders, getting feedback and guidance, and identifying issues and concerns.
28 National Offshore Wind Research and Development Consortium
i.!"!..a.�:.!.p.!"!..a..Iraffs.l:..p..re. i....:.pr-.'.i'. (last visited April 30, 2025)
29 ht j,5:: .`.L.:.p.Lg...Iry.`..:.::.!.:`�.:.::!"!.rav�r.:.::rwsc::. (last
Regional Wildlife Science Collaborative for Offshore Wind
visited April 30, 2025)
231 Page
Input from the working groups has directly resulted in accommodations to avoid
important marine habitat, fishing grounds, and marine commerce routes in the
designation of the wind energy lease areas."30 31
While each consortium or working group has a different directive, goal, membership
makeup, and funding mechanism, all include public and private stakeholder convening and
public information sharing to advance industry goals cost effectively and sustainably. Best
practices from the structure of each group can be used to inform the creation and direction
of the regional SAF Hub.
Recommendation 3.
Identify and market existing state programs and initiatives, and explore new
opportunities for targeting greenhouse gas emissions reduction, climatetech, and
economic development to support SAF -related production, innovative technology, and
job creation. Additionally, explore federal programs that may be available to bolster SAF
inclusion in the Commonwealth's climatetech ecosystem.
There are a range of federal programs that offer incentives for SAF production and usage
including tax credits, grants, and loans. These programs were created to incentivize SAF
usage, production, and investment in related infrastructure and innovative technologies.
However, the uncertain federal environment places these potential sources of funding at
risk. For this reason, the SAF Workgroup recommends that the Commonwealth focus its
efforts on leveraging existing state initiatives that target climate -related investments, while
monitoring potential federal opportunities. As shown in Figure 10, EOED identified
approximately 25 programs administered by various state agencies that have the potential
to support SAF based on an initial review. Ultimate eligibility determination depends on
program -specific criteria.
EOED developed this set of programs based on existing resources available to climatetech,
startups, manufacturing, and other ecosystem support organizations (e.g., hubs,
accelerators, etc.). The analysis considers both the relevant uses of funds for SAF companies
throughout their commercialization phases (e.g., R&D activities and facility construction),
and the typical needs of growing businesses (e.g., workforce training and equipment). This
list is tailored to scaling SAF businesses and includes manufacturing and selected sector -
agnostic programs, rather than being limited to climatetech programs.
so Fisheries Working Group on Offshore Wind Energy ::.1..a..:././....Y.Y.Y..::.1 .:.a..a..:: y/....i...n.(.p.:de. ...i..l..a./...(.%.a...h.e..l:.i.e.a..::.w..p!::L<.'.!..i..g.::.
cu�aa r�i� puff al�c�i ,u�ii� i� gX, (last visited April 30, 2025)
31 Habitat WorkingGroup on Offshore Wind Ener !2.�ta,a,,,,,,,,_ u�.m aa. caw/inn -d( tail a/Ii�lbrtat-u^�o lcii�,,,,,
p gY . 1 //.............................:.................
g,y,(last visited April 30, 2025
241PaFe
Mase tomes Acavn
Innayattaoa CiramitS
MassWentmes lEpnnders
5choal
[Ilmakeketh Tax Incentive
MassEEC 2H3ulEund
( Prt tYltJ lrVti.'ul f
M as.Wemtures 59161
Targete
5rarvt pnoram ISTART)
Cammar[ializatipn M Vonwrea
Actelemtar
MassWenkuwas ❑ae Teth
p
tive pra gram OEblpj
F
Wawk6awte Tealrnln. Frond–
�mmanwealalpa ...
E &G
Equipment Loans
�FUN��Fu
5eletki on 5ervltas
Mase tomes Acavn
Innayattaoa CiramitS
MassWentmes lEpnnders
5choal
[Ilmakeketh Tax Incentive
MassEEC 2H3ulEund
( Prt tYltJ lrVti.'ul f
M 7 hI f
partnership I mgvam
Mass. Manukactuwing
Accelerate program
Mazsl7cvelapment
Commercial Heal Estate
Loans
MassCEC AmplilTyMasz
MassCEC Inrravallan
Ecosystem program
MassCEC CdticalMass
MassCEC Clean Energy
ImernshlP program Por
Em 1 erz
Mass. Manufatkwring
nnavatlo�e IHHiative 8M212
M p elopmemt Tax
Exempt and Taxable Bond
Flmancdm M.nufacturmllI
MaxsCIEC Catalyst&t}lCES
ergingg Technology Mas7 hlapmemnology Fund
Emi
Mas.s7alantfar Employers
a,,CEC. Mass ClimatekeI
studla
"MassTerhal &
neXlrch
❑eaelapmemt Ma�tchlaug
Car t
'Mass7ech 7echnolagy&
Inmvarcioe Ecosysfiem
r—t pro ram
M.assCEC InnavafeM ss
I, ;Icalw
1., WIle VVI ,,r[ ,I I,,je;i r. h n,e asl
cI, Y ae Icf rel rau r. ll,Kti�fw, .I, ,�rh, ..u. I-nni ,�,m ,I�x.11c. rwn,.
Figure 10
Potential SAF -Eligible Programs Administered by State Agencies
Illustrative examples of how SAF companies may utilize these programs include:
MassDevelopment Emerging Tech Fund —This program provides loans to technology
companies for expansion, working capital, or equipment purchases. This could help a
growth -stage SAF technology business interested in setting up manufacturing
operations in Massachusetts.
• MassCEC Innovation Ecosystem Program —This program provides grants to
Massachusetts ecosystem support organizations (ESOs) for activities to grow a climate
tech innovation ecosystem and commercialize early-stage technology. A SAF hub (see
Recommendation 2) could apply for this program.
• MassCEC Critical Mass Program —This program provides grants to eligible climatetech
startup companies undertaking deployment -scale projects to support the transition
from development and demonstration of technical prototype solutions to sustainable
commercial operations. A SAF manufacturer startup could apply for this program.
251PaFe
2030 Im mstm a nt Fund
Figure 11
MassCEC Technology -to -Market Programs
In addition to these programs, MassCEC has a Climatetech Funding portfolio to support
research, development, demonstration, and deployment of innovative technologies. As
shown in Figure 12, MassCEC's 2030 Fund strategically invests in MA -based climate -focused
startup businesses targeting clean transportation technology.
@ ve tar ent : TI,ve 2030 Fund
it `
�� ��iI
Figure 12
MassCEC 2030 Fund
i �,,,1 � � rr err
R"A' , 14"i i nt d Si z e
��,/l /, ,ilf/11�1/K
r � r, la J
I F i r,, In, 'r, i z -e
v, t i ' �.!!v" b fa I I "F P'�vk
Stage
� Pre -Seed, Seed, A Rounds
Technology
b, Mitigation
�, Adaptation
�, Resilience
There are also clean energy and climate workforce development programs that could be
leveraged to support the workforce and infrastructure related to the SAF supply chain,
including MassCEC's Clean Energy Internship Program for Employers, which facilitates the
placement of college students and recent graduates into paid internships with verified clean
energy companies across Massachusetts by providing stipends for interns. Any company
working on SAF could apply for this program.
While the Commonwealth's current climatetech program ecosystem has available
opportunities to support early-stage research, development, and demonstration of SAF
production and technologies, there is a gap in programs and funding once companies move
into the deployment stage. The SAF Workgroup recommends that once existing programs
have been identified and marketed, the state should begin to explore potential program
structures and funding sources to develop new programming aimed at supporting
companies through deployment and commercialization. This will ensure that production
and technology growth do not stall and that programs are available to encourage
companies to continue deployment in Massachusetts.
271PaF(.
Long- �::" re(.,ori,rri,rerr(.Ia iorrs>
Recommendation 4.
Enact legislation to fund a tax credit for SAF usage, blending, storage, and production
infrastructure, as well as new SAF technology testing, adoption, and scale -up to address
cost barriers to production and demand and enable market uptake of SAF.
Like all new technology, the production of SAF results in a premium price when compared
to conventional jet fuel. The price of SAF per gallon can be up to two times or more than the
price of conventional jet fuel. As a result, subsidies to help pay for this "green premium" are
critical in the short to medium term to support the scale -up of SAF production and delivery.
Such subsidies can also be justified on an economic basis because they help avoid the
economic costs of climate change, such as adapting airports to sea level rise or reducing
impacts to airline operations from increased severe weather events. There are federal
incentives in place that support the production, blending and related infrastructure as well
as grants that target innovative technology." 33
Also, the Commonwealth has policies and programs in place that could help to incentivize
and pay for SAF infrastructure development (see Recommendation 3).
Today, SAF use is concentrated in states that have adopted tax credits and incentives.
Incentives range from broader, regulatory measures (e.g., a low carbon fuel standard for
the transportation sector) to targeted tax credits (Figure 13).
sz INTERNAL REVENUE SERVICE, Sustainable Aviation Fuel Credit, (September 30, 2024),
................i.i.v.....�...r...v.....�...r...v.....�...r....o......................................................................................................................f.....o................l.......c.......ri.w .o.a.cw .d.�ca� �.�....................................................................................................................................................�.12.i.............d........i...t.... last visited
March 28, 2025).
"U.S. DEPARTMENT OF ENERGY, U.S. DEPARTMENT OF TRANSPORTATION, U.S. DEPARTMENT OF
AGRICULTURE, AND U.S. ENVIRONMENTAL PROTECTION AGENCY, SAF Grand Challenge
Roadmap Flight Plan for Sustainable Aviation Fuel, (September 2022),
I�tta , v�rv�r�nro it iw. o.ra sites de au.1t files 2Ci22 Cid I,,)ctra oaf c;roadm a iw araLt �cat..2Ci22oadf
I................................................................................................................................./............................................./........................../.......................................................................................................................................................................I.................................................................I..................................................I.................
(last visited March 31, 2025).
Low Cirbon rind Stand arfd
SAF rasx Credit
Figure 13
Example of States That Have Implemented Measures to Support SAF Production and
Use
Adopting a targeted SAF tax credit will expedite implementation. The tax credit can also be
phased in or out, limited to specific policy goals (e.g., to increase the use of SAF within
Massachusetts or establish clear eligibility criteria on GHG reduction), and constructed to
complement other state grant programs that may be better suited for manufacturing or
other infrastructure and technology testing and adoption.
Four state tax credit schemes were reviewed for informational purposes. Three are
currently in place in Illinois, Minnesota and Nebraska, and the Michigan tax credit is
pending.
• Illinois, Minnesota, Nebraska, and Michigan tax credits are funded through a tax on
jet fuel.
• Credits provided for neat SAF range from $0.75 to $1.50 per gallon.
• Michigan, Minnesota and Nebraska have an annual cap on the credit: (1) Michigan's
cap is $4.5 million in 2025-26 and increases to $9 million in future fiscal years; (2)
Minnesota has a current cap of $7 million which will increase to $10 million in
FY2027, and $2.1 million in future years; and (3) Nebraska's cap is $0.5 million per
fiscal year. Illinois does not appear to have a limit other than the credit is applied to
the tax liability on fuel.
• Illinois, Minnesota, and Nebraska have sunset provisions- ranging from 2033 to
2035. The Michigan proposal requires domestic sources of feedstock by 2030 and, as
drafted, does not have a sunset provision.
In Massachusetts, the jet fuel tax is a local option.34 One strategy is to explore a tax credit at
the municipal level. Another strategy is to use existing state funds designated for addressing
climate change. Since the goal is to support initial start-up and transition, like other states,
the amount and timeframe of the credit can be phased out overtime.
Recommendation S.
Convene a Regional SAF alliance, inclusive of the six New England states and New York,
which will work to align SAF policies and programs at a regional level and build the scale
needed to develop a SAF industry and expand feedstock sources.
Imago: 3 - New England Governors & Eastern Canadian Premiers, 9/10/2024
An important consideration when thinking about developing a SAF industry is scale on the
demand side, to increase the potential volume of neat SAF that would be purchased and
blended, as well as scale on the supply side to provide enough regional feedstock sources to
make it economically feasible to construct local refineries and ancillary infrastructure.
States that have implemented policies to stimulate SAF use and production like Illinois,
Minnesota and California are geographically large and include a variety of potential options
for SAF feedstock.
Massachusetts is already successfully collaborating with New England states (and Canadian
provinces) on energy and clean energy transition through the New England Governors and
Eastern Canadian Premiers (NEG -ECP) Conference. We recommend building -on this model
34 MASSACHUSETTS DEPARTMENT OF REVENUE, Administrative Procedure AP 113:Jet Fuel Tax
I�tt a : �nr�nr�nrorn 5.5 !2y adi~ninistrativ aiwra�:cd�uiw� � a �. 3 �t_f�ugl.tax last visited March 28
L..........................................................................................................................................................................................................i.........................................................................L......................................II.................................................................
2025).
to include SAF.35 One approach is to use the SAF Hub (see Recommendation 4) to identify
and recommend specific policies at the multi -state level that would support the scale -up of
SAF in terms of both demand and supply. For example, aligning tax policies to ensure a
consistent credit scheme across participating states, or establishing common SAF standards
so that the entire region benefits from a unified, acceptable SAF fuel base.
ss OFFICE OF THE GOVERNOR, Governor Healey to Host New England Governors and Eastern
Canadian Premiers (NEG -ECP) Conference, news release, (August 14, 2024),
I�tta , v�rv�rwoin ora !.2vL5 .overi~�raiw.-healc ..tra.-host-i~ewsir�I�ird �overi~�e�rs-and..easteiwn-
I...............................................................................................................................................................................................................................y....................................................................................................................................�.........................................................................................................................................
::..!i...!...!!..::.:.I..1:...!!!..!...!::5..:::.!!..e.g.::.:e...:.I..:::.c.2„!!w!.::. (last visited March 31, 2025).
311 P a g e
Massachusetts SAF Workgroup, Members
➢ Executive Office of Economic Development -Naomi Berlin and Sarah Kalish
➢ Executive Office of Energy and Environmental Affairs -Emily Lamb (MassDEP) and
William Space (MassDEP)
➢ Executive Office of Administration and Finance - Quentin Palfrey and Micaela Leonarte
Paredes
➢ Governor's Office, Office of Climate Innovation and Resilience —Climate Chief Melissa
H offe r
➢ Massachusetts Clean Energy Center - Rhys Webb
➢ Massachusetts Department of Transportation/Aeronautics -Denise Garcia
➢ Massachusetts Port Authority - Flavio Leo
Outside Experts
(Presented to the Workgroup and/or contributed to the report)
➢ Dr. Florrian Allroggen, MIT
➢ Thomas Butler, Massachusetts Port Authority
➢ Adam Klauber, World Energy
➢ Amanda Ritter, Lydian Labs
➢ Jim Spaeth, U.S. DOE (now retired)
➢ Jamey Tesler, Mass Mobility Hub
➢ Christopher Willenborg, Westfield -Barnes Regional Airport (and Massachusetts Airports
Management Association)
321Pag(.
II"MeIrence
Cabrera, S. S&P GLOBAL. January 14, 2025. DOE Report Says US Domestic SAF Use Grew
Significantly Under Biden.
Chen, A., et al. RMI. 2024. Refueling Aviation in the United States: Evolution of US Sustainable
Aviation Fuel Policy.
Federal Aviation Administration. November 9, 2021. United States 2021 Aviation Climate Action
Plan.
Federal Aviation Administration. September 2024. The Economic Impact of U.S. Civil Aviation.
German Environment Agency. January 2022. Power -to -Liquids A scalable and sustainable fuel
supply perspective for aviation.
Hoffer, Melissa. October 2023. Recommendations of the Climate Chief.
Internal Revenue Service. September 30, 2024. Sustainable Aviation Fuel Credit.
International Air Transport Association. October 2021. Resolution on the Industry's
Commitment to Reach Net Zero Carbon Emissions by 2050.
International Civil Aviation Organization Committee on Aviation Environmental Protection.
2020. Aviation and Climate Change Factsheet.
International Council on Clean Transportation. November 2024. SAFPolicyScorecard:
Evaluating state -level sustainable aviation fuel policies in the United States.
Lee et. al. June 2021. The impact of climate change on the recoverability of airline networks.
Massachusetts Department of Revenue. February 5, 2024. DOR Administrative Procedures, AP
113: Jet Fuel Tax.
Massachusetts Department of Transportation. January 2019. Massachusetts Statewide Airport
Economic Impact Study Update.
Massachusetts Executive Office of Energy and Environmental Affairs. December 2022. Clean
Energy and Climate Plan for 2050.
Massachusetts Port Authority. June 27, 2022. Boston Logan International Airport Market
Analysis.
331PaL(.
National Renewable Energy Laboratory. Calderon, O. R.; Tao, Ling; Abdullah, Z.; Moriarty, K.;
Smolinski, S.; Milbrandt, A.; Talmadge, M.; Bhatt, A.; Zhang, Y,; Ravi, V.; Skangos, C.; Tan,
E.; and Payne, C. July 2024. Sustainable Aviation Fuel (SAF) State -of -Industry Report:
State of SAF Production Process.
The Office of Climate Innovation and Resilience. October 2023. Recommendations of the
Climate Chief.
Prussi et. al.. International Civil Aviation Organization. June 2021. CORSIA: The first
internationally adopted approach to calculate life -cycle GHG emissions for aviation fuels.
RMI. February 2024. Refueling Aviation in the United States.
United Airlines. 2024. Corporate Impact Report 2024.
U.S. Department of Energy (NREL). October 2021. Port Authority of New York and New Jersey
Sustainable Aviation Fuel Logistics and Production Study.
U.S. Department of Energy. March 2024.2023 Billion -Ton Report: An Assessment of US
Renewable Carbon Resources.
U.S. Department of Energy, U.S. Department of Transportation, U.S. Department of Agriculture,
and U.S. Environmental Protection Agency. September 2022. SAF Grand Challenge
Roadmap Flight Plan for Sustainable Aviation Fuel.
U.S. Department of Energy, U.S. Department of Transportation, U.S. Department of Agriculture,
U.S. Environmental Protection Agency. September 2024. Sustainable Aviation Fuel
Grand Challenge — September 2024 Progress Report.
U.S. Department of Energy. November 2024. Pathways to Commercial Liftoff. Sustainable
Aviation Fuel.
U.S. Energy Information Administration. July 17, 2024. U.S. production capacity for sustainable
aviation fuel to grow.
341PaL(.
351Paae