Section 45Z Clean Fuel Production Credit

The commenter provides a philosophical and satirical critique of capitalism, animal rights, and historical atrocities. The comment does not address the specific proposed regulations regarding the Section 45Z Clean Fuel Production Credit.

The commenter, representing a group called "The Shit Slingers Audit," argues that the proposed 45Z regulations are unconstitutional and create state-sponsored monopolies for large corporate feedlots. They claim the rules use arbitrary math to provide subsidies to industrial agriculture while unfairly penalizing independent farmers and non-lagoon agricultural methods.

The Horse Farmers of America is requesting that the Departments of Treasury and Energy update the 45ZCF-GREET model to include distinct emissions rates for Renewable Natural Gas (RNG) based on specific animal manure feedstocks. They argue that these updates are necessary to reflect actual operating conditions and to ensure that unconventional animal farmers are not discriminated against by aggregated emission rates.

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.

Evan H. Couture, representing the r/equinetarian Archive, opposes the proposed Section 45Z regulations. The commenter argues that the credit creates a market distortion by providing a taxpayer-funded subsidy to large industrial conglomerates while excluding small-scale producers and undermining consumer choice.

The National Apple Demolition and Market Stabilization Coalition (NADMSC) is petitioning the IRS and Department of the Treasury to establish a baseline provisional carbon intensity (CI) score for fuel derived from demolished surplus apples. They argue that the Section 45Z framework must remain technology-neutral and performance-based, asserting that the diversion of these crops from natural decomposition to fuel production qualifies for lucrative negative CI integers.

The National Apple Demolition and Market Stabilization Coalition opposes the proposed Section 45Z regulations, arguing that the tax credits create a market anomaly that incentivizes diverting agricultural output toward fuel production rather than human consumption. They contend that the current framework will lead to a "sub-economic inversion" where food becomes a secondary byproduct of the refining process and demand that the IRS include penalties for primary food diversion.

Sterk’s Horse Farms, LLC is requesting that the IRS formally register their proprietary "pre-fermented oat-and-waste matrix" as an eligible negative-integer feedstock for the Section 45Z clean fuel production credit. The company argues that their process is scientifically superior for carbon capture and demands that the Service avoid excluding their feedstock based on arbitrary sanitation or aesthetic standards.

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.

The American Oats Coalition for Energy Security (AOCES) supports the proposed 45Z regulations but argues they should be expanded to explicitly include oat-derived biomass as an eligible feedstock. They request specific technical adjustments to the Production Emission Reduction (PER) framework, including carbon sequestration credits and nitrogen input offsets, to maximize tax credits for oat-based biofuels.