Comment from Divergent Recycling
Divergent RecyclingSupportBusiness
Summary: Divergent Recycling, LLC and Levenhall LLC, a waste tire pyrolysis company, support the proposed regulations but request specific additions to the 45ZCF-GREET model. They argue that waste tire pyrolysis oil (TPO) should be included as a qualifying non-SAF transportation fuel using a zero-burden waste feedstock allocation methodology to provide investment certainty and reduce administrative burdens for domestic producers.
Commenters respectfully request that the Department of the Treasury and the Department of Energy add a waste tire pyrolysis oil production pathway utilizing domestic scrap tires as the primary feedstock to the 45ZCF-GREET model in the next scheduled update, applying the same zero-burden waste feedstock allocation methodology currently applied to used cooking oil and other waste-derived feedstocks, and that Treasury confirm in final regulations that tire pyrolysis oil produced from domestically sourced end-of-life tires constitutes a qualifying non-SAF transportation fuel under Section 45Z(c)(2); the full comment is attached as an exhibit to this submission.