How to Set Up a Sustainable Aviation Fuel (SAF) Plant in India: Greenfield Project Planning, Technology Selection, and Regulatory Guide

Introduction

For any energy sponsor or infrastructure investor planning a sustainable aviation fuel plant in India, the project is materially more complex than selecting a production technology. Successful projects require integrated planning across feedstock availability and supply chain, technology pathway selection, engineering design, utility infrastructure, environmental compliance, regulatory approvals, procurement, construction, and commissioning. SAF sits at the intersection of aviation, energy, agriculture, and environmental regulation, each dimension shapes what a viable project looks like.

Scope of this Guide

This guide answers the sponsor's set-up question directly. It covers how to set up a Sustainable Aviation Fuel plant in India through project planning, feedstock selection, production technologies, engineering requirements, regulatory approvals, and project execution before investing in a sustainable aviation fuel (SAF) plant. It walks through the sector context, complete project development lifecycle from feasibility through commercial operations, and the practices that separate structured SAF project development from projects that stall in regulatory limbo or fail on feedstock economics.

Table of Contents

• Introduction
• Why Sustainable Aviation Fuel in India Matters
• SAF Plant Feasibility and Project Planning in India
• SAF Feedstock Selection and Supply Chain in India
• SAF Production Technology Pathways for India
• SAF Plant Engineering Design and Utilities in India
• Regulatory Approvals for SAF Manufacturing Plants in India
• SAF Plant Construction and Commissioning in India
• Common Mistakes and Best Practices
• Conclusion

1. Why Sustainable Aviation Fuel in India Matters

Four structural drivers make SAF a strategically important opportunity for Indian energy investors.

1.1 SAF Blending Mandates and Aviation Sector Growth

India has announced indicative SAF blending targets of 1 percent by 2027 and 2 percent by 2028 aligned with global aviation decarbonisation commitments. The Ministry of Petroleum and Natural Gas (MoPNG) and Ministry of Civil Aviation (MoCA) coordinate the sector policy.

Indian aviation continues rapid growth with domestic and international air traffic recovery driving increasing aviation turbine fuel consumption. The mandated blending percentages translate into substantial SAF production requirements creating a domestic demand base that supports investment.

1.2 CORSIA and International Compliance Framework

The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) established by the International Civil Aviation Organization (ICAO) provides the global framework for aviation carbon compliance. India has indicated participation from the voluntary phase starting 2027.

Indian carriers operating international routes face progressive CORSIA obligations. SAF is one of the primary compliance instruments alongside carbon offsets. Structured domestic SAF supply reduces foreign exchange exposure and CORSIA compliance cost for Indian carriers.

1.3 National Policy on Biofuels 2018 Framework

The National Policy on Biofuels 2018 (amended in 2022) provides the parent framework for biofuels in India including SAF-relevant provisions. The policy supports feedstock diversification, technology development, and commercial scale-up.

Ministry of Petroleum and Natural Gas (MoPNG) serves as the nodal ministry. Complementary policies including the SATAT scheme for compressed biogas, ethanol blending programme, and biofuel-linked incentives create an enabling policy environment. Structured policy support materially reduces early-mover investment risk.

1.4 India's Feedstock and Refining Ecosystem

India offers substantial feedstock endowment for SAF production including Used Cooking Oil (UCO) collected through structured programmes, agricultural residues (rice husk, wheat straw), sugarcane derivatives (molasses, ethanol pathway), non-edible oilseeds, and municipal solid waste.

Public sector refiners (Indian Oil Corporation, Hindustan Petroleum, Bharat Petroleum) and private refiners (Reliance) provide infrastructure and offtake anchor. CSIR-Indian Institute of Petroleum (IIP), Dehradun has developed indigenous SAF technology. The ecosystem supports commercial-scale project development.

2. SAF Plant Feasibility and Project Planning in India

SAF plant feasibility and project planning provides the analytical foundation for informed investment commitment. Structured feasibility work materially reduces the risk of downstream project failures that unstructured entry routinely produces.

2.1 The Feasibility Framework

2.2 SAF Plant Capex and Financial Modelling

SAF plant capex and financial modelling translates project scope into investment decisions. Small-scale SAF plants (10,000-50,000 tonnes per annum) typically require INR 500-2,000 crore capex. Medium-scale plants (50,000-200,000 tonnes per annum) typically require INR 2,000-10,000 crore.

Large-scale integrated plants (above 200,000 tonnes per annum) can exceed INR 10,000-40,000 crore. Financial modelling covers capex profile, feedstock cost sensitivity, product pricing (SAF premium versus conventional jet fuel), utility costs, statutory levies, and multi-scenario IRR analysis.

2.3 Detailed Project Report (DPR)

The Detailed Project Report (DPR) consolidates feasibility findings into an investment-grade document supporting board approval, debt financing, and equity investor engagement. DPR components include executive summary, market analysis, technology selection with rationale, feedstock supply chain design, site selection and infrastructure, regulatory pathway, implementation schedule, capex and opex projections, risk register with mitigation, and multi-scenario financial modelling. Well-structured DPRs typically take 4-8 months to develop for SAF projects reflecting the multi-dimensional complexity.

3. SAF Feedstock Selection and Supply Chain in India

SAF feedstock selection and supply chain is often the single most consequential decision in SAF plant setup. Feedstock choice determines technology pathway, capex profile, ongoing operating cost, sustainability credentials, and regulatory eligibility for programmes like CORSIA.

3.1 Feedstock Options and Characteristics

3.2 Sustainability Criteria and Certification

SAF feedstocks must meet sustainability criteria to qualify for CORSIA and buyer sustainability commitments. Roundtable on Sustainable Biomaterials (RSB) certification and International Sustainability and Carbon Certification (ISCC) are the widely used third-party frameworks.

Criteria include lifecycle greenhouse gas reduction versus fossil jet fuel (typically 50 percent minimum for CORSIA), no deforestation or land-use change (ILUC risk), food security compatibility, water stewardship, labour and social standards, and biodiversity protection. Structured sustainability compliance from feedstock selection stage prevents downstream buyer rejection.

3.3 Supply Chain Design

SAF supply chain design covers collection network for distributed feedstocks (UCO, agricultural residues), aggregation infrastructure at intermediate points, storage and handling at plant boundary, pre-processing for quality standardisation, and reserve stock policy for seasonal availability variations.

Feedstock cost typically represents 40-60 percent of SAF production cost making supply chain economics central to project viability. Long-term supply contracts with structured pricing mechanisms materially reduce operating risk versus spot procurement.

4. SAF Production Technology Pathways for India

SAF production technology pathways for India are defined by ASTM D7566 (Standard Specification for Aviation Turbine Fuel Containing Synthesized Hydrocarbons). Structured SAF production technology selection matches feedstock, capex envelope, and commercial objectives to the right pathway.

4.1 ASTM D7566 Approved Pathways

4.2 SAF Technology Selection Criteria

SAF technology selection decisions weigh feedstock compatibility, CapEx and OpEx profiles, licensing availability, technology maturity, product yield and quality, and blend limit implications. HEFA-SPK is the most commercially mature globally with widely available licensing.

FT-SPK suits waste and biomass feedstocks abundant in India. ATJ-SPK leverages India's mature ethanol infrastructure. Emerging Power-to-Liquid (e-SAF) using green hydrogen and captured CO2 offers long-term potential particularly aligned with India's National Green Hydrogen Mission.

4.3 Technology Licensing and Partners

Technology licensing typically involves partnership with established providers offering process technology, engineering packages, catalyst systems, and commissioning support. Global providers include Honeywell UOP, Topsoe, Axens, LanzaJet, Fulcrum BioEnergy, Velocys, and Gevo.

Indian technology contributions particularly from CSIR-Indian Institute of Petroleum (IIP) provide indigenous options. Licensing agreements typically cover technology transfer fees, ongoing royalties, performance guarantees, and continuous improvement rights. Structured technology selection typically extends 6-12 months for informed decisions.

5. SAF Plant Engineering Design and Utilities in India

SAF plant engineering design and utilities translates technology selection and site characteristics into constructible plant configuration. Effective SAF plant design integrates process, mechanical, electrical, instrumentation, civil, and utility engineering in coordinated packages.

5.1 Basic and Detailed Engineering

Basic engineering (FEED — Front-End Engineering Design) establishes the plant configuration including Process Flow Diagrams (PFDs), Piping and Instrumentation Diagrams (P&IDs), major equipment sizing, layout planning, utility loads, and HSE philosophy.

Detailed engineering translates FEED into constructible documents including detailed P&IDs, isometrics, structural drawings, electrical distribution, instrumentation loops, and control philosophy. FEED typically takes 6-9 months; detailed engineering typically takes 12-18 months for SAF plants. Structured FEED-detailed engineering handover with defined change management prevents cost overruns.

5.2 Utility Infrastructure Requirements

• Hydrogen supply: on-site steam methane reforming, green hydrogen production, or import
• Steam: high-pressure and low-pressure networks for process heat
• Power: HT connectivity typically 66kV or 132kV depending on plant scale
• Cooling water: circulation system with cooling towers, sizing to plant heat load
• Nitrogen and inert gas: for process safety and blanketing
• Compressed air: instrument air and utility air networks
• Fire water and firefighting infrastructure per NBC 2016 and OISD standards

5.3 Process Safety and HAZOP

Process safety is central to SAF plant engineering given hydrogen handling, high-temperature operations, and flammable product streams. Hazard and Operability (HAZOP) studies at basic engineering stage identify process risks. Layer of Protection Analysis (LOPA) evaluates safety layer adequacy.

Safety Instrumented Systems (SIS) per IEC 61511 provide automated protection. Oil Industry Safety Directorate (OISD) standards provide petroleum-specific safety requirements. Structured process safety integration during design prevents post-commissioning safety retrofits.

5.4 Digital and Automation Architecture

Modern SAF plants operate on distributed control systems (DCS) with advanced process control (APC) for optimisation. Enterprise integration through Manufacturing Execution Systems (MES) and ERP supports operational visibility.

Predictive maintenance using IoT sensors and analytics reduces unplanned downtime. Cybersecurity per IEC 62443 protects operational technology. Structured digital architecture during initial design is materially cheaper than post-commissioning retrofit.

6. Regulatory Approvals for SAF Manufacturing Plants in India

Regulatory approvals for SAF manufacturing plants span multiple central and state agencies covering environmental, safety, aviation, and fuel-specific dimensions. Structured sustainable aviation fuel regulatory approvals sequencing at project outset materially compresses total approval timelines.

6.1 Central Approvals

6.2 State Approvals

State-level approvals include Consent to Establish (CTE) and Consent to Operate (CTO) from State Pollution Control Boards under Water Act 1974 and Air Act 1981, Fire NOC from State Fire Services, Factory Licence under OSH Code 2020 in force from 21 November 2025, Building Permission from local municipal authority, and Change of Land Use where applicable. State industrial estate allotments through corporations like MIDC, GIDC, KIADB, SIPCOT, TSIIC, or APIIC simplify several parallel approvals through single-window processes.

6.3 Sustainability Certification

Third-party sustainability certification is prerequisite for CORSIA eligibility and buyer engagement. Roundtable on Sustainable Biomaterials (RSB) and International Sustainability and Carbon Certification (ISCC) provide the widely accepted frameworks.

Certification covers feedstock traceability from origin through processing, lifecycle greenhouse gas emissions per RSB or ISCC methodology, mass balance accounting, and ongoing compliance verification. Structured certification typically takes 6-12 months and requires alignment across the entire supply chain.

6.4 Product Quality and Fuel Certification

SAF product must meet ASTM D7566 specification for synthesised paraffinic kerosene with subsequent blending certified under ASTM D1655 (Jet A/A-1 specification). BIS certification supports domestic fuel supply. Individual airline and airport authority acceptance may require additional testing per specific procurement processes.

Directorate General of Civil Aviation (DGCA) coordinates with aviation stakeholders on operational integration. Structured product certification workflow parallel with plant commissioning prevents post-commissioning delays to first commercial supply.

7. SAF Plant Construction and Commissioning in India

SAF plant construction and commissioning translates engineered design into operational plant. Construction and commissioning together typically extend 30-48 months for medium-scale SAF plants — the longest phase in the project lifecycle.

7.1 Procurement and Contracting Strategy

Procurement strategy options include EPC (Engineering, Procurement, Construction) with single contractor accountability, EPCM (Engineering, Procurement, Construction Management) with owner retaining execution risk, and multi-package with separate contracts for major disciplines.

EPC suits sponsors preferring fixed cost with contractor risk transfer; EPCM suits sponsors with in-house project management capability seeking cost transparency. FIDIC contract templates (Silver Book for EPC turnkey; Yellow Book for design-build; Red Book for construction) provide widely used international contract frameworks.

7.2 Construction Sequencing

• Site preparation: grading, boundary walls, security infrastructure
• Civil works: foundations, structural steel, buildings
• Utilities: power supply, water systems, steam network
• Mechanical: reactor vessels, columns, heat exchangers, piping
• Electrical: HT switchyard, transformers, motor control centres
• Instrumentation: control valves, transmitters, DCS installation
• Insulation, painting, and pre-commissioning checks

7.3 Pre-Commissioning and Commissioning

Pre-commissioning covers mechanical completion verification, hydrostatic testing of piping and vessels, electrical testing, instrumentation loop checks, and utility system commissioning. Commissioning progresses through cold commissioning (systems ready without process fluids), initial process introduction with controlled conditions, gradual capacity ramp-up, and performance test runs verifying design guarantees.

Commissioning typically extends 6-12 months for SAF plants including performance runs. Structured commissioning discipline with defined system readiness protocols prevents commissioning delays.

7.4 Commercial Operations Ramp-Up

Commercial operations ramp-up progressively increases production from initial trial batches through full nameplate capacity. Ramp-up typically extends 6-18 months depending on feedstock supply chain maturation, operator learning, and product quality stabilisation.

Structured ramp-up planning includes phased feedstock scaling, progressive product qualification with buyers, and continuous operator training. First commercial cash flow typically occurs 30-45 months from project sanction for medium-scale plants supporting the financial modelling that drives investment commitment.

8. Common Mistakes and Best Practices

8.1 Underweighting Feedstock Supply Chain

SAF projects that select technology before validating feedstock supply chain routinely face operating cost surprises.

Best practice: long-term feedstock contracts secured before construction commitment; multiple feedstock sources including primary and alternate suppliers; sustainability certification prerequisites documented from origin; feedstock cost sensitivity analysis integrated into financial modelling.

8.2 Skipping Structured Technology Evaluation

Selecting technology based on vendor sales rather than structured evaluation produces suboptimal matches to feedstock and commercial objectives.

Best practice: structured technology selection process with multiple pathway evaluation; independent process engineering review; reference plant visits where feasible; performance guarantee negotiation with clear KPIs.

8.3 Deferred Sustainability Certification

Sustainability certification treated as post-commissioning formality produces buyer engagement delays.

Best practice: RSB or ISCC certification pathway defined at project outset; supply chain traceability designed from feedstock origin; lifecycle greenhouse gas assessment integrated with engineering design; structured certification parallel with commissioning.

8.4 Inadequate Approval Sequencing

Approvals sequenced serially produce timeline extension.

Best practice: parallel initiation of central and state approvals; pre-consultation with regulatory authorities during feasibility; structured documentation preparation matching approval requirements; regulatory advisory engagement at project outset.

8.5 Weak Change Management During Construction

Design changes rushed through during construction produce cost overruns and quality issues.

Best practice: structured Management of Change (MOC) processes; multi-functional review of proposed changes; documented change orders with financial and schedule impact assessment; disciplined baseline preservation until validated changes are integrated.

Conclusion

Setting up a sustainable aviation fuel plant in India is a multidisciplinary project spanning aviation, energy, agriculture, and environmental regulation. India's SAF blending targets, CORSIA participation, National Policy on Biofuels framework, and mature refining and feedstock ecosystem collectively create an attractive development window for structured entrants.

Sustainable aviation fuel manufacturing demands integrated planning across feasibility, feedstock supply chain, technology pathway, engineering design, utilities, regulatory approvals, procurement, construction, and commissioning. Sponsors combining rigorous feasibility discipline, structured technology selection, comprehensive regulatory sequencing, and disciplined project execution consistently deliver commercial-scale SAF facilities that meet blending targets and CORSIA sustainability requirements.

Three closing reminders for SAF project sponsors. First, validate feedstock supply chain economics before technology commitment. Feedstock cost typically represents 40-60 percent of SAF production cost, supply chain design determines project viability more than technology choice.

Second, sequence sustainability certification from feedstock origin. RSB or ISCC certification is prerequisite for CORSIA eligibility and buyer engagement; retrofitting sustainability compliance is materially expensive versus designing it in.

Third, engage integrated end-to-end project advisory rather than fragmented single-discipline support. SAF projects require coordinated engineering, regulatory, feedstock, and financial expertise that fragmented advisory cannot deliver.