Comment from Roeslein Renewables

Summary: Roeslein Renewables expresses strong support for the proposed Section 45Z Clean Fuel Production Credit, particularly the provisions for negative emissions rates and species-specific emissions for manure-based RNG. The company urges the Department of Treasury and the Department of Energy to update the 45ZCF-GREET model with more accurate baseline emissions, species-specific carbon intensity scores, and additional production pathways like cellulosic biomass.