Comment from mcr Energy LLC
mcr Energy LLCOpposeBusiness
Summary: The commenter argues that the proposed 45Z regulations rely on a flawed GREET model calculator that incorrectly penalizes manure-derived RNG while providing credits for landfill gas. They advocate for a revision of the model to align with standard lifecycle assessment principles and international regulatory frameworks that recognize the methane avoidance benefits of manure management.
See attached file(s).