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Clearing the Emissions Smoke: Asking the Right Questions The key questions we should be asking about SAFs include: Fuel Source? What is the source of the fuel? Is it a biofuel? From what source of biomass? Is it a synthetic fuel? If so, what is the source of energy for its creation? What is the life cycle emissions impact? Scale/Timetable for Deployment? What is the scale and timetable for bringin. [...] While the IRA pointed to the ICAO criteria (or other criteria acceptable under the Clean Air Act) to determine the eligibility of fuel for the tax credit, the Biden administration released guidance in December 2023 that clarified fuel eligibility and may allow the use of additional albeit less rigorous eligibility criteria.18 Ethanol producers lobbied for the government to allow a specific emissio. [...] In the words of the Biden administration, this will look like “an extremely complicated system of systems, including feedstock production, collection, and distribution to SAF production facilities; conversion of feedstock to fuel; and transport, storage, and delivery of the finished fuel to the infrastructure required to fuel aircraft.” The administration has estimated that the “extremely complica. [...] According to IATA’s assessment, SAFs will be responsible for roughly two thirds of the reduction in carbon emissions by 2050.46 If this is to occur, tens of billions of gallons of sustainable aviation fuel will need to be produced over the next 26 years, a herculean task considering the little supply currently in the market, the prohibitive cost of manufacturing alternative fuel, and the growing d. [...] Thanks to the unpopular 2017 Trump tax law, the ultrawealthy receive enormous benefits when they purchase a private aircraft and have the ability to write-off their jet as a business expense.55 The business aviation industry lobbied in favor of the legislation and the NBAA set an institutional record by spending nearly $4 million in lobbying funds that year.56 One of the tax subsidies the private.