Comment from American Coalition for Ethanol (ACE)

Summary: The American Coalition for Ethanol (ACE) supports the proposed 45Z regulations but urges the Treasury and IRS to ensure that low-carbon farming practices can be fully monetized through the inclusion of USDA's Feedstock Carbon Intensity Calculator (FD-CIC) in the GREET model. They also advocate for using existing USDA verification protocols to minimize administrative burdens and request specific inclusions for corn kernel fiber ethanol pathways.