Comment from American Biogas Council

Summary: The American Biogas Council (ABC) supports the proposed regulations for the Section 45Z clean fuel production credit, specifically praising the clarified definitions for "qualified sales," "related party sales," and "suitable for use" fuels. The organization advocates for the rapid release of the 45ZCF-GREET model, the inclusion of site-specific manure management inputs, and the adoption of a book-and-claim system for RNG used as process energy. They also oppose strict additionality, deliverability, and temporal matching requirements for renewable energy certificates (RECs), arguing that such rules would create unnecessary administrative burdens and increase fuel costs.