Comment from JSDEP-41703 NOTICE OF REGULATORY CONFLICTREGULATORY CONFLICT (State of Texas v. Darling Ingredients Inc.)
JSDEP-41703 NOTICE OF REGULATORY CONFLICTREGULATORY CONFLICT (State of Texas v. Darling Ingredients Inc.)OpposeAdvocacy
Summary: The commenter, representing The Unknown Equinetarian Archive and Tennessee Citizens for Horse Meat, opposes the proposed Section 45Z regulations. They argue that the IRS is willfully ignoring existing state and federal data regarding feedstock fraud, toxic emissions, and energy inefficiencies, and they demand the integration of this data into the administrative record to invalidate the proposed tax credits.
To the Commissioners of the IRS and Legal Counsel of the Texas Commission on Environmental Quality:
Please find attached a formal Motion to Compel Multi-Agency Data Disclosure and accompanying State Enforcement Addendum, served concurrently upon the Internal Revenue Service Office of Associate Chief Counsel on this day, June 19, 2026. This filing officially demands that the IRS requisition TCEQ’s investigative logs, hydrogen sulfide air metrics, and the active civil enforcement filings from your February 2026 lawsuit against Darling Ingredients Inc. to integrate them into the federal Section 45Z administrative record. TCEQ is hereby put on notice that its state environmental quality data is being leveraged to block federal climate tax subsidy distributions.
Sincerely, Evan H. Couture
The Unknown Equinetarian