The Fire We Cannot See: Why India’s SAF Strategy Is Pathway-Mismatched to Its Feedstock

A detailed opinion piece on why India’s Sustainable Aviation Fuel strategy is pathway-mismatched to its feedstock, and what the 2028 CORSIA invoice will cost. The full 6,300-word report with seven illustrated figures is available as a PDF download at the foot of this piece.

Every October, the Indo-Gangetic Plain performs a quiet national arithmetic. Twenty million tonnes of paddy straw are set on fire in Punjab, Haryana and western Uttar Pradesh. The smoke travels south to Delhi. The airshed closes. Schools shut. Hospitals report a spike in respiratory admissions. The Supreme Court admonishes the states. The states admonish the Centre. The Centre commissions a committee. The rabi sowing begins. The smoke clears. The cycle waits for next October.

Eight months from now, on 1 January 2027, a second fire will start — one most Indians will never see. Every Indian international carrier will enter the mandatory phase of the Carbon Offsetting and Reduction Scheme for International Aviation. The offset liability through 2035 is projected at between one and a half and two billion US dollars.

These are the same fire. The first one produces the very feedstock that could extinguish the second. And India is currently on course to burn both ends.

This piece is not about whether Sustainable Aviation Fuel works. It works. It is certified under ASTM D7566, it is chemically indistinguishable from Jet A-1 at the tailpipe, and a Boeing 777 at FL370 cannot tell the difference. This piece is about a narrower and sharper question: of the Indian government’s announced SAF capacity build-out, what share of it uses the feedstock India actually has in abundance? The answer, as of April 2026, is approximately zero per cent.

The landscape, in one picture

India’s position on SAF is not an absence of activity. The government has announced targets. Indian Oil has commissioned a certified facility. BPCL has committed capital. Airlines have signed offtake agreements. What is missing is the arithmetic between the announced capacity and the target it is meant to meet.

The gap is not marginal. It is roughly three-fifths of the 2030 target. And every announced tonne of Indian SAF capacity through 2027 uses the same feedstock: used cooking oil, processed via the HEFA pathway. This is a specific strategic choice. It is also, at scale, the wrong one.

HEFA and ATJ — the two serious answers

There are eleven ASTM-certified pathways to Sustainable Aviation Fuel. Two account for essentially all commercial SAF production through 2030: HEFA (Hydroprocessed Esters and Fatty Acids) and ATJ (Alcohol-to-Jet). Two more — Fischer-Tropsch and Power-to-Liquid — are strategically important but do not operate at commercial scale in aviation fuel anywhere in the world today.

HEFA is commercial today, cheap, and fast. It uses used cooking oil, animal fat, and vegetable oils. It is also the pathway that runs out of feedstock at the exact blending percentage where India’s ambition is supposed to begin. India’s total used cooking oil supply, after accounting for existing biodiesel commitments, is around three to five hundred thousand tonnes per year — just enough to hit the 2030 5% target at theoretical maximum collection, with nothing left for the 2035 target or beyond.

ATJ uses ethanol from agricultural residue as its feedstock. It is technically immature at commercial scale — the LanzaJet facility in Georgia, USA, due online in late 2025, is the world’s first. It is capital-intensive, at roughly 2.5 times the cost per tonne of HEFA capacity. It is also the only pathway that can match the Indian feedstock base to Indian aviation fuel demand over the next twenty years.

This is not a minor engineering distinction. It is the central strategic choice that Indian SAF policy must make — and has not made.

The feedstock picture

The scale disparity between used cooking oil and crop residue is best shown visually. The KPMG report published in November 2025 cites 230 million tonnes of surplus agricultural biomass. The ICAO ACT-SAF feasibility study published the same year cites 140 million tonnes using a stricter definition. Either number dwarfs the used cooking oil supply by between two and three orders of magnitude.

India does not lack capacity. India lacks pathway capacity.

The distinction is crucial. In August 2025, Indian Oil’s Panipat refinery received India’s first ISCC CORSIA certification. Commercial production began shortly thereafter, targeting 30,000 tonnes per year of HEFA-pathway SAF from used cooking oil. Air India signed an offtake. The Minister of Civil Aviation announced it as a national milestone. All of this is true.

What is also true: that facility, at full design capacity, produces approximately six per cent of the 2030 5% blend target. One facility is not a plan. It is a prototype. And every additional announced Indian facility through 2027 — BPCL’s commitments across Mumbai, Kochi, and Bina; MRPL’s Mangalore plant — uses the same HEFA pathway on the same constrained UCO feedstock base.

The first cellulosic facility in India, IOC’s 86,800-tonne LanzaJet ATJ plant at Panipat, is scheduled for March 2028. That date depends on LanzaJet’s first-of-a-kind commercial facility in Georgia, USA, which was itself delayed more than a year. India’s entire cellulosic SAF hope through 2028 is anchored to a single US startup’s technology that has not yet demonstrated commercial reliability anywhere in the world.

The four-column bill India already pays

Aviation policy is usually discussed in the register of carbon and trade. For India specifically, the correct register is also public health. The twenty million tonnes of paddy straw burned in Punjab and Haryana each October is the single largest source of particulate matter in the National Capital Region during the burn window — and the NCR airshed contains some thirty million people whose respiratory systems bear the cost.

The burden of not acting falls into four separate budgets across four separate ministries — aviation (offsets), health (NCR healthcare), agriculture (foregone farmer income), and petroleum (imported fuel). No single minister sees the aggregate. The burden of acting would fall on a single coordinating decision. That is the asymmetry at the heart of the policy paralysis.

The order-of-magnitude estimate is approximately ₹1.2 lakh crore per year in avoidable cost, split roughly as: NCR healthcare ~₹1 lakh crore, foregone farmer income ~₹19,000 crore, CORSIA offset outflow ~₹1,500 crore, plus foregone fuel import savings. A domestic cellulosic SAF industry, at scale, would convert somewhere in the range of ₹1 lakh crore per year of net cost into ₹40,000 crore per year of net value — farmer income, fuel substitution, carbon credit exports. The full arithmetic is in the PDF report.

Why hydrogen is not the answer this decade

Any complete analysis must address hydrogen-fuelled aviation. Hydrogen aviation is real, it is being developed by Airbus under the ZEROe programme with entry into service targeted for the mid-2030s, and it will eventually play a role. It is also, for the CORSIA-era question this piece addresses, the wrong conversation.

Hydrogen aircraft require an entirely new airframe, new engines, new fuel storage, new airport infrastructure, and new regulatory certification. Short-haul entry into service targets the 2035 window. Long-haul hydrogen aviation is not in any credible industry roadmap before 2050. For the 2027 CORSIA mandatory phase, hydrogen is irrelevant. For the 2030 blending target, hydrogen is irrelevant.

Where the hydrogen conversation does become useful is on Power-to-Liquid (PtL) SAF, synthesised from green hydrogen and captured CO₂. India’s National Green Hydrogen Mission target of five million tonnes by 2030, if realised, could underwrite a meaningful PtL SAF industry — but that linkage is entirely unmade in current Indian policy.

What India should actually be doing

The specific shape of India’s policy absence can be described in five items, each of which has a counterpart in jurisdictions that have succeeded, and each of which requires a coordinating decision rather than new legislation.

1. A statutory blending mandate under the Aircraft Act, converting the indicative 1%/2%/5% targets into binding compliance. Precedent: EU ReFuelEU.
2. A Contract-for-Difference price-support mechanism, transferring SAF price risk from refiner to state. Precedent: UK (2024 launch).
3. A cellulosic SAF viability gap fund of approximately ₹10,000 crore over five years, competitively awarded to integrated residue-to-SAF facilities. Precedent: US IRA 40B; Japan Green Transition Bonds.
4. An aviation-specific domestic carbon credit registry, retaining offset revenue within India. Precedent: Brazil’s RenovaBio.
5. A technology-transfer risk underwriting mechanism for first-of-kind facilities dependent on overseas technology providers. Precedent: UK Advanced Fuels Fund.

Each of these can be announced in a Union Budget. None require Parliamentary approval. All of them have been recommended in whole or part by the ICAO ACT-SAF Feasibility Study (2025) and the KPMG Fuelling a cleaner sky (November 2025) reports commissioned or received by the Indian government.

The closing argument

The seat-back safety card on every aircraft instructs passengers that, in the event of a loss of cabin pressure, oxygen masks will drop from the overhead panel. A passenger must secure their own mask before assisting others. A person who cannot breathe cannot help anyone else breathe either.

India’s aviation policy is currently reaching for the overhead panel. CORSIA is the cabin descending through ten thousand feet. The mask is there. The oxygen is there. The feedstock is in the fields. The refineries are standing ready to be upgraded. What is missing is the last mechanical step — the hand that pulls the mask down and secures it.

That step is, in the Indian institutional context, a single coordinating decision from the Prime Minister’s Office, authorising the Ministry of Civil Aviation to issue a statutory blending mandate under the Aircraft Act, backed by a Contract-for-Difference price-support mechanism administered by the Ministry of Petroleum and Natural Gas, and a viability gap fund for cellulosic SAF administered jointly with the Ministry of Agriculture. None of these require new legislation. All of them require the coordination of existing instruments.

The policy architecture is not missing. The decision is.

We are building the wrong kind of plant fast and the right kind of plant slow. We are paying for air quality in hospital bills and for carbon in forex reserves, when we could be paying farmers and saving both. We are treating as separate four problems that are, in their economic substance, one problem.

The fire we cannot see is the more expensive one. It is the fire of institutional inaction — the fire that burns, slowly, at the base of every policy paralysis that leaves a national opportunity uncollected. That fire has been burning for at least five years, since the original CORSIA reservation was filed. It is burning hotter now, because the deadline is closer. And it is, unlike the one over Delhi, entirely inside the government’s capacity to extinguish.

Capt. Amit Singh, FRAeS, is a Boeing 777 and Airbus A320 captain with over 18,000 flight hours. He is the founder of Safety Matters Foundation (safetymatters.co.in), hosts the mindFly Katha podcast, and writes on aviation safety, human factors and regulatory policy. Views expressed are personal.

Primary sources: ICAO ACT-SAF Feasibility Study for India (van Dyk & Deshpande, 2025); KPMG India Fuelling a cleaner sky (November 2025); DGCA India CORSIA Seminar Presentation; Lok Sabha Unstarred Question No. 4012 (12 December 2019); Argus Media coverage of IOC Panipat ISCC certification (21 August 2025); IATA Net Zero Progress Report 2024; ICAO Default Life Cycle Emissions Values for CORSIA Eligible Fuels (November 2025); ASTM D7566 and D1655 specifications.