SAF Configurations under the GHGP AMI Multi-Statement Reporting Structure
Executive Summary
4AIR supports the GHGP AMI White Paper’s proposed multi-statement reporting structure because it creates a practical framework for distinguishing:
Physical emissions inventories;
Market-based procurement and contractual attribute ownership;
Broader GHG impacts; and
Non-GHG transition indicators.
This structure is particularly important for Sustainable Aviation Fuel (“SAF”), where physical fuel delivery, contractual attribute ownership, Scope 1 claims, Scope 3 claims, and broader market-development impact may not always align.
4AIR recommends that SAF be treated in the same way as renewable electricity under Scope 2: SAF physically delivered to an airport and traced through segregation or mass balance is a reduction reported on the Physical GHG Inventory Statement (analogous to location-based reporting), while SAF claimed through book-and-claim is treated like a Renewable Energy Certificate (“REC”) and reported on the Market-Based GHG Inventory Statement. The key difference is that SAF can be used for both Scope 1 and Scope 3 emission reductions and the inventory that either should be included in depends on the underlying value chain relationship between the entities transacting for the reduction claim.
Core Principle: SAF Should Not Be Treated as a Single Reporting Category
SAF transactions can take several forms. Each structure has different implications for physical inventory accounting, market-based reporting, GHG impact reporting, and non-GHG indicators.
SAF can be purchased via a physical uplift, where local airport fueling infrastructure typically uses a mass balance chain of custody mechanism. Or SAF can be purchased via a book and claim chain of custody mechanism, where the SAF is delivered to a different airport than the aircraft uplifting fuel, minimizing transportation cost and carbon emissions. This chain-of-custody choice determines where the claim is reported: physical uplift traced through segregation or mass balance belongs in the Physical GHG Inventory Statement, while book-and-claim belongs in the Market-Based GHG Inventory Statement, mirroring the location-based and market-based split for renewable electricity under Scope 2.
Additionally, SAF typically has a scope 3 claimant, a passenger or cargo load that is indirectly responsible for those fuel emissions. SAF reductions can be sold to a scope 3 claimant who is within the supplying aircraft operator’s value chain already (a direct or “physical” customer) or it could be sold independently to a scope 3 claimant who isn’t already a customer of the aircraft operator. This affects the scope 3 claimant’s relationship to the emission reductions. A Scope 3 claim can sit in the Physical GHG Inventory Statement only where the underlying SAF was delivered and traced into the operator’s fuel supply and the Scope 3 claimant has a direct value-chain relationship with that operator; all other Scope 3 SAF claims would be reported on the market-based inventory.
In our opinion, the combination of these different situations results in unique appropriate treatments under the new GHGP AMI multi-statement framework. In viewing the Scope 1 claimant and the Scope 3 claimant as separate reporting perspectives, four potential SAF reporting configurations are:
* For the Scope 1 claimant, “physical” means SAF physically delivered into the airport fuel system from which the operator uplifts, traced through identity preserved, segregation, or mass balance chain of custody. For the Scope 3 claimant, “physical” also requires a pre-existing value chain relationship with that operator. This aligns with the concept of “physical connectivity/traceability” from the AMI Phase 1 Whitepaper.
SAF Configuration 1: Scope 1 physical / Scope 3 physical
Description
The aircraft operator has a physical SAF relationship and retains the Scope 1 benefit. A Scope 3 user may also have a direct physical or value-chain relationship to the same aviation activity, such as a contracted corporate travel program, charter movement, cargo service, or customer program linked to a defined operator or fuel supply chain.
This is the clearest case for physical inventory treatment. The aircraft operator reports the TTW benefit in its Scope 1 physical inventory where SAF is physically delivered into the airport fuel system it uplifts from, traced through segregation or mass balance, and it retains the Scope 1 attribute. This mirrors location-based Scope 2 reporting of renewable electricity physically supplied by the grid. The Scope 3 user may report a corresponding Scope 3 physical inventory claim where the relationship is tied to its own value chain, and the Scope 3 attribute is separately allocated and retired for that user.
This configuration does not require a separate Scope 3 claim. If no Scope 3 attribute is allocated, the case remains a Scope 1 physical SAF claim by the aircraft operator only.
Position
Configuration 1 should be recognised as the strongest physical-inventory case, provided the SAF pathway, segregation or mass balance chain of custody, physical allocation, attribute ownership, WTT/TTW data, and registry retirement evidence are complete.
SAF Configuration 2: Scope 1 physical / Scope 3 book-and-claim
Description
The aircraft operator has a physical SAF relationship and may report the Scope 1 benefit. The Scope 3 user does not have a direct physical allocation or customer-specific fuel relationship; instead, it acquires a Scope 3 SAF attribute through a registry-backed book-and-claim instrument.
Position
For the aircraft operator, the Scope 1 treatment remains a physical inventory claim if the operator uses SAF and retains the relevant Scope 1 attribute. For the Scope 3 user, the claim is better suited to the Market-Based GHG Inventory Statement because the user’s claim depends on contractual attribute ownership and retirement rather than a direct physical relationship to the fuel uplift, in the same way a REC purchaser reports on a market-based basis.
Configuration 2 should allow co-existing Scope 1 and Scope 3 claims only where the claims are both tracked within a registry and clearly identified, allocated, and retired.
SAF Configuration 3: Scope 1 book-and-claim / Scope 3 physical
Description
The aircraft operator uses book-and-claim because SAF is not physically available at the operator’s airport, route, or operating location. The operator therefore holds the environmental attribute without any traced physical delivery of SAF into the fuel it uplifts.
A Scope 3 user may have a direct relationship with the operator or relevant service, such as business travel, air freight, charter, fractional ownership, or another defined aviation activity.
Position
Under a REC-equivalent approach, the operator’s Scope 1 claim belongs in the Market-Based GHG Inventory Statement. Because no SAF has been traced through segregation or mass balance into the fuel system the operator uplifts from, the operator’s physical inventory should continue to reflect the fuel it actually combusts, just as a company’s location-based Scope 2 inventory reflects the grid it actually draws from, regardless of the RECs it holds.
This treatment applies whether or not the attribute is sourced from a supplier, airport, or region with which the operator otherwise has a commercial relationship. A contractual or customer relationship alone does not establish physical traceability; only segregation or mass balance into the operator’s fuel supply does. Book-and-claim remains a credible and valuable mechanism, but its claim is contractual and should be reported on that basis.
The Scope 3 user’s claim follows the underlying instrument. Even where the Scope 3 user has a direct relationship with the operator, the underlying SAF claim is book-and-claim, so the Scope 3 claim should also be reported in the Market-Based GHG Inventory Statement. For reporting purposes, Configuration 3 is therefore treated the same way as Configuration 4.
SAF Configuration 4: Scope 1 book-and-claim / Scope 3 book-and-claim
Description
In this situation, neither the Scope 1 claimant nor the Scope 3 claimant receives the physical fuel or has a pre-existing value chain alignment with the emissions reduction supplier. Both rely on book and claim market-based instruments. This may occur where SAF is produced and delivered into the aviation system, while the operator sells off the right to claim the scope 3 attributes outside of its existing customer network.
Position
Both the Scope 1 and Scope 3 claims belong in the Market-Based GHG Inventory Statement. Configuration 4 is the direct SAF equivalent of a REC: the attribute is transferred and retired through a registry independently of the physical fuel either party uses, and should be reported on the same basis as market-based Scope 2 claims.
Configuration 4 can be credible only if the registry effectively records Scope 1 and Scope 3 attributes, transfer history, retirement beneficiary, and regulatory use. Without that clarity, claims should be limited to impact or non-GHG reporting.
What does physical traceability mean for SAF?
SAF qualifies for the Physical GHG Inventory Statement only when it has been physically delivered into the airport fuel system, terminal, or supply infrastructure from which the operator uplifts, and that delivery is traced through an identity preserved, segregation, or mass balance chain of custody. A commercial, contractual, or customer relationship between the parties is not sufficient on its own; the test is whether the SAF has plausibly entered the fuel the operator actually uses. This aligns with the concept of “physical connectivity/traceability” from the AMI Phase 1 Whitepaper – which should be further defined in their Phase 2 Whitepaper.
This mirrors the Scope 2 distinction for electricity. Location-based reporting reflects the electricity physically delivered by the grid a company draws from, while market-based reporting reflects RECs bought and retired independently of physical supply. SAF claimed through book-and-claim, where the certificate is transferred and retired at the registry level with no physical linkage to the fuel the company receives or consumes, is the equivalent of a REC and belongs in the Market-Based GHG Inventory Statement.
Registry Controls Required Across Configurations
To make any configurations credible, SAF should always be tracked within a registry to ensure:
Unique issuance;
Registry-based ownership tracking;
Transfer history;
Clear Scope 1 / Scope 3 attribute separation;
Retirement controls;
Retirement beneficiary identification;
Lifecycle carbon intensity data;
Sustainability certification;
Evidence of production and delivery;
Evidence of whether regulatory claims have been made;
Audit logs;
Interoperability safeguards across registries.
A Real Example
Operator A normally uplifts 100,000 gallons from LAX airport and decides to purchase 50,000 gallons of SAF physically delivered into a pipeline fueling the LAX airport fuel system and tracked through mass balance. In addition, they are purchasing 50,000 gal of SAF via book and claim delivered to Houston, where the operator does not operate from. The mass-balanced SAF at LAX should be counted as a Scope 1 reduction on the Physical GHG Inventory Statement, comparable to location-based renewable electricity, while the Houston book-and-claim SAF should be reported on the Market-Based GHG Inventory Statement, comparable to a REC.
The Houston SAF would receive the same market-based treatment even if Operator A operated from Houston, unless the attributes were not decoupled until after the fuel was delivered to Houston. This highlights the value of preserving segregation or mass balance tracing to the airport where SAF is delivered before decoupling the environmental attributes, as it determines which statement the aircraft operator reports in.
Conclusion
SAF can fit into multiple GHGP AMI reporting statements depending on whether the claim is based on physical fuel use, contractual attribute ownership, broader mitigation impact, or non-GHG transition activity.
4AIR’s position is that the GHGP AMI Standard should reflect the underlying supply chain of where SAF is delivered, and not assume a SAF attribute is automatically a market-based instrument. True accounting for SAF depends on where and how the attributes are delivered in order to preserve the integrity of physical inventories while creating a credible, practical pathway for SAF book-and-claim within the market-based inventory statement. Scope 1 and Scope 3 SAF attributes should be capable of separate allocation and retirement where robust registry controls prevent double issuance and double claiming. SAF’s treatment can align to the same way as renewable electricity under Scope 2: SAF physically delivered to an airport and traced through segregation or mass balance is a Scope 1 or Scope 3 reduction on the Physical GHG Inventory Statement, analogous to location-based reporting, while book-and-claim SAF functions like a REC and is reported on the Market-Based GHG Inventory Statement.
About 4AIR & Assure
The Assure Registry was developed by 4AIR to support the traceability of SAF reduction claims by tracking SAF production, physical fuel movements, environmental attribute ownership, transfers, and retirements across both physical and book-and-claim supply chains. 4AIR’s experience shows that SAF can support credible Scope 1 and Scope 3 claims when supported by robust registry controls, lifecycle carbon intensity data, sustainability certification, and clear retirement logic.
Background Appendix – How ISO Chain of Custody mechanisms fit within GHGP’s value chain definition
ISO 22095 (Chain of Custody — general terminology and models) sets out four CoC models, on a spectrum of how tightly the "claim" stays tied to the physical material:
1. Identity preserved – physical product from a single source kept fully segregated and traceable.
2. Segregation – like-for-like sourced material kept separate from non-certified material, but sources can mix.
3. Mass balance – certified and non-certified material can physically mix, but volumes are tracked administratively so outputs "add up" to inputs.
4. Book and claim – the administrative record of a characteristic (e.g., "low-carbon" or "sustainable") is transferred/sold independently of any physical linkage to the material the end user actually receives or consumes.
In the book-and-claim model, there is no requirement that the physical molecules of fuel a company actually burns/uses ever passed through the same supply chain as the certified low-carbon fuel it is claiming. A certificate representing the environmental attribute (e.g., a SAF or biomethane certificate) can be generated by a producer anywhere, sold and retired by a buyer anywhere else, while the buyer's actual physical fuel comes from an entirely unrelated, conventional source.
Mapping that to the GHG Protocol's "value chain" definition
The Scope 3 Standard's value chain concept is anchored to actual upstream/downstream activities tied to the reporting company's operations — i.e., the real flow of goods, services, and products connected to what the company actually does (procures, sells, uses).
Because book and claim severs the administrative claim from the physical flow, the "fuel" being claimed:
· May never physically enter the reporting company's actual operational boundary or supply chain at all.
· May be produced, distributed, and consumed in a completely different geography/system than the company's real fuel purchases.
· Is tracked and retired via a registry (contractual/administrative instrument), not via physical custody.
So strictly by the ISO definition, book and claim is not tracing physical fuel through the value chain in the mass-balance or identity-preserved sense — it's tracing (transferring) an attribute/claim through a registry, decoupled from the physical value chain. The GHG accounting treatment (e.g., under Scope 2 (market-based) for electricity RECs, or emerging SAF/biomethane guidance) then permits the company to report that attribute applied to its own consumption, even though physically the fuel/energy associated with the claim sits outside — often literally in a different part of the world from — the company's actual upstream/downstream operational value chain.
Alignment with Scope 2 location-based and market-based treatment
The AMI whitepaper notes that the new market-based inventory may affect the accounting treatment of Scope 2 market-based actions, such as RECs. This paper assumes that location-based renewable electricity remains in the physical inventory and that RECs move to the Market-Based GHG Inventory Statement. SAF should follow the same split: SAF physically delivered and traced through segregation or mass balance belongs in the physical inventory, and book-and-claim SAF, like a REC, belongs in the market-based inventory. Should the GHGP’s treatment of RECs change, SAF book-and-claim treatment should follow it, given the similarity of the two instruments.
Appendix 2: Definitions in accordance with GHGP and ISO
· Physical GHG Inventory Statement: used where SAF has been physically delivered into the reporting company’s fuel supply and traced through identity preserved, segregation, or mass balance chain of custody (analogous to location-based Scope 2 reporting), or, for Scope 3, where the reporting company has a direct value-chain relationship with an operator making such a claim.
· Market-Based GHG Inventory Statement: used where the reporting company relies on a qualifying contractual instrument, transfer, and retirement to support an inventory claim without physical traceability, including all book-and-claim SAF claims, analogous to RECs under market-based Scope 2 reporting.
· GHG Impact Statement: used to describe broader mitigation or market-development impact separately from an inventory claim.
· Non-GHG Indicators Statement: used for metrics such as gallons supported, SAF spend, SAF certificates purchased, regulatory volumes, investments, or other transition indicators where no emissions reduction claim is made.
· Scope 1: Direct emissions from sources owned or controlled by the reporting company. For an aircraft operator, this usually includes jet fuel combustion in operated aircraft.
· Scope 3: Indirect value-chain emissions outside the reporting company’s own operations. For corporate customers, business travel or freight movement by air is commonly Scope 3.
· Value-chain relationship: A direct operational, contractual, customer, supplier, or service relationship connecting the reporting company to the aviation activity.
· Book-and-claim: A chain-of-custody model that separates the environmental attribute from the physical fuel molecule. The fuel may be used in one location while the attribute is transferred and retired for an eligible claimant elsewhere.
· Physical inset: A reduction or attribute used within the claimant’s own aviation value chain.
· Physical offset: A reduction or attribute used outside the claimant’s value chain to compensate for emissions elsewhere.
· Tank-to-wake (TTW): Emissions from fuel combustion in the aircraft.
· Well-to-wake (WTT): Upstream lifecycle emissions from feedstock, production, processing, transport, and delivery before combustion.
· Lifecycle carbon intensity (CI): The measured or certified GHG intensity of the fuel across its relevant lifecycle boundary.