Comment from RNG Coalition

Summary: The Coalition for Renewable Natural Gas (RNG COALITION) supports the Section 45Z clean fuel production credit but urges the Treasury to allow a "non-Environmental Attribute Certificate (EAC)" pathway for pipeline-delivered RNG as a process fuel. They argue that eligibility should be demonstrated through commercially reasonable records and independent verification rather than a separate certificate market, which they claim would minimize administrative burdens and leverage existing natural gas market practices.