Comment from Continuum Ag
Continuum AgSupportAdvocacy
Summary: Continuum Ag, representing a network of farmers, supports the proposed 45Z regulations and urges the IRS and DOE to quickly finalize and publish the Feedstock Carbon Intensity Calculator. They recommend aligning the calculator with the latest DOE R&D GREET model and adopting a "Book and Claim" approach to link farm practices to biofuel production.
We appreciate the efforts of the IRS and look forward to further 45Z rule updates that provide clarity as to the inclusion of feedstock CI Scoring and associated CI reductions. Our recommendations regarding this are attached.