Comment from OPAL Fuels, Inc.

Summary: OPAL Fuels, Inc., a biofuels company, supports the proposed Section 45Z regulations but urges the Treasury and DOE to update the 45ZCF-GREET model. They specifically request the inclusion of a food waste-to-RNG pathway and the incorporation of avoided methane benefits from Automated Collection Systems (ACS) in landfill gas-to-RNG pathways to improve technical accuracy and financial certainty for investors.