Comment from Life Cycle Associates LLC
Life Cycle Associates LLCSupportBusiness
Summary: Life Cycle Associates, LLC, representing the interests of energy developers, argues for more flexible and consistent methodologies for calculating carbon intensity under the 45Z credit. They specifically recommend allowing for bespoke natural gas upstream emissions data, alternative monitoring standards, and the mass-balancing of energy attribute certificates to ensure that lower-emission production pathways are accurately rewarded.
Please see my attached comments regarding Feedstocks for 45Z