Policy Memo: Landing Fees on Private Aviation to Support Sustainable Aviation Fuel
To: Senator Marko Liias, Chair, Senate Transportation (Washington State)
From: Tarun Thomas Philip
Summary
Private aviation makes up only about 4% of overall civil aviation activity, but it accounts for a disproportionate share of emissions, with some estimates placing its climate impact as high as 19% [1] of aviation’s greenhouse gases. Each private jet flight emits many times more carbon per passenger than commercial aviation, yet the small number of travelers and their wealth make this sector highly responsive to targeted policies.
This memo recommends a temporary landing surcharge on private aviation during the 2026 FIFA World Cup in Washington state. Revenues would be dedicated to narrowing the price gap between conventional jet fuel and Sustainable Aviation Fuel (SAF). This policy would produce measurable near-term carbon reductions, accelerate SAF adoption, and demonstrate a scalable model that could be replicated across airports nationwide.
What is SAF?
SAF is a drop-in replacement for conventional jet fuel made from renewable sources such as waste oils, agricultural residues, or captured carbon. Unlike batteries or hydrogen, which are decades away for long-haul aviation, SAF is the only scalable option available now to cut emissions from existing aircraft.
Image: Geospatial pattern of private aviation, 2023[2]
Why Target Private Aviation
- High emissions, few users: Private jets during FIFA could burn ~2 M gallons of fuel. A 20% SAF blend would require around 400,000 gallons of neat SAF, displacing around 3070 metric tons of CO₂ (that is equal to taking ~670 cars off the road for a year).[3]
- Ability to absorb costs: A $1,250–$2,000 landing fee is negligible compared to the cost of a private flight, but enough to cover most of SAF’s $2–$3 per gallon premium.
- Kickstarting SAF adoption: Closing this price gap builds demand, helps scale production, and moves SAF toward cost parity.
- High-visibility pilot: FIFA offers a global stage for a simple message: “If you land here, you leave on cleaner fuel.”
How the Surcharge Works
The policy would impose a temporary landing fee on all private and chartered aircraft, exempting medical, emergency, military, and training flights. Revenues would accrue in a dedicated SAF Buy-Down Fund, ensuring transparency and accountability. The fund would be used exclusively to reduce SAF’s price premium for aircraft departures during the FIFA period.
Federal and state incentives that are already in place amplify the policy’s impact. Washington’s Clean Fuel Standard credits and new federal SAF tax credits together cover much of the price gap. The landing surcharge closes the last $2–$3 per gallon, making SAF available at near parity with conventional fuel. Where physical SAF is unavailable, certified book-and-claim purchases allow every flight to credibly claim a cleaner departure.
Image: West Coast Markets SAF Value Stack Comparison – February 2025[4]
Image: Private Aviation FIFA World Cup 2022[5]
Cost-Benefit Analysis
A landing fee of $1,250–$2,000 applied across ~2,000 flights during FIFA would generate ~$4 M in revenue. At a $2 per gallon subsidy, this covers 2 M gallons of blended jet fuel – equivalent to 400,000 gallons of SAF. The resulting emissions savings, ~3,070 tons of CO₂, cost roughly $1,300 per ton avoided. While higher than the EPA’s social cost of carbon, the policy targets a small, wealthy group of super-emitters, creating fairness and efficiency.
The broader benefits outweigh the per-ton cost. The policy creates reliable demand for SAF, encouraging producers to expand capacity. Concentrated, short-term uptake demonstrates market viability to investors and unlocks financing for new production facilities. Additionally, the program sustains local jobs in fuel handling, monitoring, and air quality assessment.
Addressing Potential Objections
Critics may argue that affluent travelers will simply avoid Washington airports, undermining revenue and emissions goals. Yet during FIFA, demand for local access is effectively inelastic – teams, sponsors, and VIPs must land in or near the host city. Risks of “leakage” to other airports are low given congestion, visibility, and logistical constraints.
Some question the politics of targeting a small affluent group, since similar efforts have faced resistance. This proposal differs by dedicating all revenues to lowering SAF costs, ensuring fairness, and by being temporary and transparent, making it a pragmatic pilot rather than a punitive tax.
Some private fliers may already choose to purchase SAF voluntarily. In those cases, the surcharge ensures equity: every flight pays into the system, but those already using SAF directly benefit from lower prices or book-and-claim credits.
Reporting and Monitoring
Transparency will be critical for credibility. In line with the SAF transition plan at Paine Field:
- Air quality monitoring: Install compact air quality monitoring stations (AQMS) before FIFA to capture baseline data (CO₂, SO₂, NOₓ, O₃, particulate matter). Continue during and after FIFA to measure changes tied to increased traffic and SAF use.
- Impact reporting: Publish results in late 2026, including fuel volumes, SAF blend levels, credits generated, and emissions avoided. Reports should be shared with the public, the Dept. of Ecology, WSDoT Aviation, Snohomish County, and Cascadia stakeholders.
- Dashboard updates: During FIFA, weekly dashboards can show arrivals, gallons of SAF uplifted, average blend, and CO₂ avoided, reinforcing transparency and accountability.
Image: Carbon-intensity of key events in 2022[6]
Sunset and Future Expansion
The surcharge should sunset after the FIFA World Cup (June 11–July 19, 2026), followed by a public evaluation of results. If the pilot proves successful, the legislature should consider extending the policy for five years and broadening it to include commercial aviation. Scaling the model would amplify SAF demand, expand monitoring infrastructure, and further establish Washington as a hub for clean aviation leadership.
Next Steps
- Draft legislation establishing the private aviation landing surcharge and the SAF Buy-Down Fund.
- Coordinate with WSDOT Aviation, Ecology, Boeing Field, and Paine Field to finalize fee collection and reporting protocols.
- Begin SAF contracting and monitoring infrastructure in 2025 to ensure full readiness for FIFA 2026.
Quick Math
- Revenue: 2,000 flights x $2,000/landing = $4,000,000
- Gallons supported at $2/gal buy-down = $4M / $2 = 2.0M gal blended fuel
- Neat SAF at 20% blend: 20% × 2.0M = 400k gal SAF
- CO₂ avoided: Each gallon Jet-A = 9.6 kg CO₂; assuming SAF cuts around 80%
- 400k × 9.6 × 0.8 = ~3,070 t CO₂ avoided
- Cars equivalent: Divide by 4.6 t/car/yr (EPA average[7])
3,070 ÷ 4.6 ≈ 670 cars
References
1ICCT – Air and greenhouse gas pollution from private jets, 2023
2Image: Nature.com - Private aviation is making a growing contribution to climate change
3For specific, please refer Quick Maths section.
4Image: Stillwater Associates - Tracking the Stacks: Comparative Values for RD and SAF in West Coast Markets
5Image: Nature.com - Private aviation is making a growing contribution to climate change
6Image: Nature.com - Private aviation is making a growing contribution to climate change
7EPA – GHG Emissions from a Typical Passenger Vehicle