Air Liquide
BusinessOther
Lifecycle modeling and credit certainty
Section 45Z Clean Fuel Production Credit
IRS-2026-0133-0001NPRM
Comments
525
Last activity Jul 4, 2026
Deadline
Closed on Apr 7, 2026
Closed Apr 7, 2026
Net supportiSupport minus oppose · campaigns included
+70%
+70% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Section 45Z Clean Fuel Production Credit
The proposed regulations would provide rules on the section 45Z clean fuel production credit as extended and modified by the One, Big, Beautiful Bill Act of 2025. Section 45Z provides a credit for clean transportation fuel produced domestically after December 31, 2024, and sold by December 31, 2029. The proposed regulations would address general requirements, such as credit eligibility, emissions rates, claim filing, and registration. The proposed regulations would also amend existing elective pay, credit transfer, and registration regulations for clarity and consistency. The proposed regulations would affect domestic fuel producers, credit claimants, and registrants.
- Posted
- Feb 4, 2026
- Comment period
- Feb 4, 2026 – Apr 7, 2026
- FR Doc
- 2026-02246
- CFR
- 26 CFR Parts 1 and 48
- Topics
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+70%
Net support
Support413Oppose45Other67
Aggregates include form-letter campaigns. Excluding them, net support is +70% across organic comments.
Who commented
Breakdown by commenter type.
Union
1
Individual
187
Government
18
Trade association
35
Advocacy
119
Academic
3
Business
158
Other
4
Comments over time
Weekly arrivals, stacked by stance.
Posted Feb 4, 2026Deadline Apr 7, 2026
Feb 2Feb 23Mar 16Apr 6Apr 27May 25Jun 15Jun 29
Support413Oppose45Other67
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
75%
12%
13%
Business
80%
3%
17%
Advocacy
82%
8%
9%
Trade association
89%
6%
6%
Government
83%
11%
6%
Other
25%
25%
50%
Academic
33%
67%
0%
Union
100%
0%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Support for 45z rules161
Carbon intensity (ci) methodologies70
Lifecycle modeling and credit certainty58
Feedstock definitions and integration42
Domestic feedstock prioritization37
Greet model ghg emissions32
Recognition of on-farm conservation practices26
Book and claim authorization22
Expedite usda feedstock calculator22
Feedstock-specific ci scores for manure19
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Support for 45z rules | Domestic feedstock prioritization | Lifecycle modeling and credit certainty | Recognition of on-farm conservation practices | Expedite usda feedstock calculator |
|---|---|---|---|---|---|
Air Liquide BusinessOther Air Liquide is requesting to testify in person at a public hearing regarding the proposed Section 45Z Clean Fuel Product | · | · | · | · | |
Alchemy CO2, PBC BusinessSupport Alchemy CO2, PBC, a carbon capture company, supports the proposed regulations but requests specific revisions to clarify | · | · | · | · | · |
Alternative Fuels & Chemicals Coalition AdvocacySupport The Alternative Fuels & Chemicals Coalition (AFCC), representing member companies in the renewable chemicals and biofuel | · | · | · | · | |
American Biomass Energy Association, American Loggers Council, Forest Landowners Association AdvocacySupport The American Biomass Energy Association, Forest Landowners Association, and American Loggers Council are advocating for | · | · | · | · | · |
American Fuel and Petrochemical Manufacturers Trade associationOppose The American Fuel & Petrochemical Manufacturers (AFPM) opposes the proposed regulations because they favor pro rata allo | · | · | · | · | · |
American Petroleum Institute Trade associationSupport The American Petroleum Institute (API) supports the proposed regulations regarding the Section 45Z Clean Fuel Production | · | · | · | · | · |
American Wood Council AdvocacySupport The American Wood Council supports the 45Z Clean Fuel Production Credit but urges the Treasury to ensure the regulations | · | · | · | · | · |
Anew Climate LLC AdvocacySupport Anew Climate, a climate solutions company, supports the proposed regulations for the Section 45Z clean fuel production c | · | · | · | · | · |
Arkansas Soybean Association AdvocacySupport The Arkansas Soybean Association supports the proposed regulations for the Section 45Z Clean Fuel Production Credit, par | · | · | |||
Baker Commodities, Inc. BusinessSupport Baker Commodities supports the proposed Section 45Z regulations but requests specific modifications to ensure the credit | · | · | · | · | |
Bayer Crop Science BusinessSupport Bayer Crop Science supports the proposed Section 45Z regulations and urges the Treasury and IRS to finalize the rule exp | · | · | · | ||
Beta Analytic LLC BusinessSupport Beta Analytic, a laboratory specializing in radiocarbon dating, recommends that the Treasury adopt existing Renewable Fu | · | · | · | · | · |
Bioenergy Association of California AdvocacySupport The Bioenergy Association of California (BAC) supports the proposed 45Z regulations, noting they provide necessary guida | · | · | · | · | |
Bunge BusinessSupport Bunge, an oilseed processor, supports the Section 45Z clean fuel production credit but requests specific regulatory refi | · | · | · | ||
California Bioenergy LLC BusinessSupport California Bioenergy LLC (CalBio) supports the proposed regulations for the section 45Z clean fuel production credit but | · | · | · | · | · |
CFO Services BusinessOther CFO Services is providing an outline for a live presentation at the public hearing regarding the Section 45Z Clean Fuel | · | · | · | · | · |
Christianson PLLP BusinessSupport Christianson PLLP, a CPA firm providing services to renewable fuel producers, submitted constructive feedback on the pro | · | · | · | · | |
CNX Resources BusinessSupport CNX Resources Corporation supports the 45Z Clean Fuel Production Credit as a means to incentivize the capture and use of | · | · | · | · | · |
Coalition for Renewable Natural Gas AdvocacySupport The Coalition for Renewable Natural Gas (RNG COALITION) supports the proposed regulations for the Section 45Z Clean Fuel | · | · | · | · | |
Continuum Ag AdvocacySupport Continuum Ag, representing a network of farmers, supports the proposed 45Z regulations and urges the IRS and DOE to quic | · | · | · | ||
Corteva Agriscience BusinessSupport Corteva Agriscience supports the Section 45Z Clean Fuel Production Credit, noting its potential to boost rural economies | · | · | · | ||
CoverCress Inc BusinessSupport CoverCress Inc. | · | · | · | · | |
Darling Ingredients BusinessSupport Darling Ingredients, a major producer of renewable diesel and sustainable aviation fuel, supports the proposed Section 4 | · | · | · | · | · |
Darling Ingredients EXPOSED BusinessSupport Darling Ingredients, a major renewable fuel producer, supports the proposed 45Z regulations but argues that the "country | · | · | · | · | · |
Energy Marketers of America (EMA) Trade associationSupport The Energy Marketers of America (EMA), a federation of state and regional trade associations, supports the proposed "sui | · | · | · | · | · |
Environmental Defense Fund AdvocacySupport The Environmental Defense Fund (EDF) supports the implementation of the section 45Z clean fuel production credit but urg | · | · | · | ||
Farmer's Biogas Network AdvocacySupport Farmer’s Biogas Network, Inc., an organization representing dairy farms, supports the implementation of the Section 45Z | · | · | · | · | · |
Fuels America AdvocacySupport Fuels America, a coalition of renewable fuel producers and farmers, supports the proposed Section 45Z Clean Fuel Product | · | · | · | ||
Granite Falls Energy, LLC BusinessSupport Granite Falls Energy LLC, an ethanol producer, supports the proposed 45Z clean fuel production credit but urges the Trea | · | · | · | ||
Graphyte, Inc. BusinessSupport Graphyte, Inc., a carbon removal company, supports the Section 45Z clean fuel production credit and urges the Treasury a | · | · | · | · | |
Grissan Renewable Energy BusinessSupport Grissan Energy US LLC, a renewable energy company, supports the proposed regulations but requests that the annual emissi | · | · | · | · | · |
Heartland Corn Products BusinessSupport Heartland Corn Products, an ethanol producer, supports the 45Z clean fuel production credit but urges the Treasury to ad | · | · | · | · | |
Hereford Ethanol Partners, L.P. BusinessSupport Hereford Ethanol Partners, L.P. | · | · | · | ||
HF Sinclair Corp. BusinessSupport HF Sinclair, an energy company, supports the proposed regulations for the 45Z Clean Fuel Production Credit and the under | · | · | · | · | |
Horse Farmers of America AdvocacySupport The Horse Farmers of America is requesting that the Departments of Treasury and Energy update the 45ZCF-GREET model to i | · | · | · | · | · |
IL Corn Growers Association AdvocacySupport The IL Corn Growers Association supports the 45Z Clean Fuel Production Credit as a means to provide economic relief to f | · | · | · | · | |
IMAREAN Corp BusinessSupport KVASIR Intelligence (IMAREAN) argues that the proposed regulations should explicitly recognize independent satellite-bas | · | · | · | · | · |
Intermediate Oilseed Crop Association (IOCA) Trade associationSupport The Intermediate Oilseed Crop Alliance (IOCA) supports the proposed 45Z clean fuel production credit, specifically prais | · | · | · | · | |
International Council on Clean Transportation AdvocacySupport The International Council on Clean Transportation (ICCT) supports the inclusion of emissions reductions from all stages | · | · | · | ||
Iowa Soybean Association Trade associationSupport The Iowa Soybean Association (ISA) supports the proposed regulations for the Section 45Z Clean Fuel Production Credit, p | · | · | · | ||
Kansas Corn Growers Association Trade associationSupport The Kansas Corn Growers Association supports the proposed 45Z clean fuel production credit but argues that the final rul | · | · | · | ||
Kansas Soybean Association AdvocacySupport The Kansas Soybean Association supports the proposed regulations for the Section 45Z Clean Fuel Production Credit, empha | · | · | |||
Kentucky Farm Bureau Federation AdvocacySupport The Kentucky Farm Bureau supports the proposed rulemaking for the Section 45Z Clean Fuel Production Credit, viewing it a | · | · | · | · | |
LanzaJet, Inc. BusinessSupport LanzaJet, Inc., a sustainable aviation fuel (SAF) producer, supports the proposed Section 45Z regulations but argues tha | · | · | · | · | · |
LanzaTech Global, Inc. BusinessSupport LanzaTech Global, Inc., a technology company focused on transforming waste into fuels, supports the 45Z Clean Fuel Produ | · | · | · | · | |
Life Cycle Associates LLC BusinessSupport Life Cycle Associates, LLC, representing the interests of energy developers, argues for more flexible and consistent met | · | · | · | · | |
Lyon-Lincoln Electric Cooperative GovernmentSupport Lyon-Lincoln Electric Cooperative, a distribution electric cooperative, supports the proposed regulations for the Sectio | · | · | · | · | |
Maas Energy Works BusinessSupport Maas Energy Works, a company that operates on-farm renewable energy facilities, supports the Section 45Z clean fuel prod | · | · | · | · | |
mcr Energy LLC BusinessOppose The commenter argues that the proposed 45Z regulations rely on a flawed GREET model calculator that incorrectly penalize | · | · | · | · | · |
MESKA BusinessSupport MESKA LLC, a renewable energy development company, supports the proposed regulations but urges Treasury to act quickly t | · | · | · | · | · |
Minnesota Farmers Union UnionSupport The Minnesota Farmers Union supports the proposed Section 45Z Clean Fuel Production Credit, noting its potential financi | · | · | |||
Monarch Bioenergy, LLC BusinessSupport Monarch Bioenergy, LLC, a renewable energy production company, expresses strong support for the Section 45Z Clean Fuel P | · | · | · | · | |
National Association of State Departments of Agriculture AdvocacySupport The National Association of State Departments of Agriculture (NASDA) supports the proposed regulations for the 45Z Clean | · | · | · | · | |
National Corn Growers Association Trade associationSupport The National Corn Growers Association supports the Section 45Z Clean Fuel Production Credit as a way to strengthen farm | · | · | · | ||
National Energy & Fuels Institute AdvocacySupport The National Energy & Fuels Institute (NEFI), representing small and mid-sized heating fuel businesses, supports the pro | · | · | · | ||
National Grain and Feed Association Trade associationSupport The National Grain and Feed Association (NGFA) supports the proposed Section 45Z Clean Fuel Production Credit, provided | · | · | · | ||
National Pork Producers Council Trade associationOther The National Pork Producers Council (NPPC) states that it cannot provide a meaningful position on the proposed 45Z regul | · | · | · | ||
National Propane Gas Association Trade associationSupport The National Propane Gas Association (NPGA) supports the proposed regulations for the Section 45Z Clean Fuel Production | · | · | · | · | · |
Nebraska Corn Growers Association AdvocacySupport The Nebraska Corn Growers Association supports the Section 45Z clean fuel production credit as a means to bolster farm i | · | · | · | · | |
New West Genetics Inc BusinessSupport New West Genetics, Inc., an agricultural seed genetics company, supports the Section 45Z framework but argues that it cu | · | · | · | · | · |
Oberon Fuels, Inc. BusinessSupport Oberon Fuels, a clean fuel producer, supports the proposed regulations for the Section 45Z clean fuel production credit | · | · | · | · | · |
POET, LLC BusinessSupport POET, a biofuel producer, supports the proposed Section 45Z clean fuel production credit and its implementation by the T | · | · | · | ||
Renewable Fuels Association Trade associationSupport The Renewable Fuels Association (RFA), a trade association for the ethanol industry, supports the proposed 45Z clean fue | · | · | · | ||
Roeslein Renewables BusinessSupport Roeslein Renewables expresses strong support for the proposed Section 45Z Clean Fuel Production Credit, particularly the | · | · | · | · | |
Sievers Family Farms, LLC BusinessSupport Sievers Family Farms, LLC, a grain and beef cattle operation, supports the Section 45Z Clean Fuel Production Credit and | · | · | · | ||
Southwest Iowa Renewable Energy BusinessSupport Southwest Iowa Renewable Energy, LLC, a domestic ethanol producer, supports the proposed Section 45Z regulations but req | · | · | · | · | · |
Sustainable Advanced Biofuel Refiners Coalition AdvocacySupport The Sustainable Advanced Biofuel Refiners (SABR) Coalition, a group of biodiesel stakeholders, supports the proposed reg | · | · | · | · | |
Taxpayers for Common Sense AdvocacyOppose Taxpayers for Common Sense (TCS) opposes the expansion of the 45Z clean fuel production credit, arguing that it increase | · | · | · | · | |
Tennessee Farm Bureau Federation AdvocacySupport The Tennessee Farm Bureau Federation supports the proposed regulations for the Section 45Z clean fuel production credit, | · | · | · | · | |
Tennessee Soybean Association Trade associationSupport The Tennessee Soybean Association supports the proposed § 45Z regulations, emphasizing that the removal of indirect land | · | · | · | ||
The American Oats Coalition for Energy Security AdvocacySupport The American Oats Coalition for Energy Security (AOCES) supports the proposed 45Z regulations but argues they should be | · | · | · | · | |
The National Apple Demolition and Market Stabilization Coalition (NADMSC) AdvocacyOppose The National Apple Demolition and Market Stabilization Coalition opposes the proposed Section 45Z regulations, arguing t | · | · | · | · | · |
The Transport Project AdvocacySupport The Transport Project, a national coalition of transportation and fuel industry stakeholders, supports the proposed 45Z | · | · | · | · | · |
U.S. Canola Association AdvocacySupport The U.S. | · | · | · | ||
U.S. Chamber of Commerce BusinessSupport The U.S. | · | · | |||
Weaver and Tidwell, LLP BusinessSupport Weaver and Tidwell, L.L.P., a qualified certifier, supports the proposed regulations but urges the IRS to implement a sp | · | · | · | · | · |
Yosemite Clean Energy, LLC AdvocacySupport Yosemite Clean Energy (YCE) supports the proposed 45Z regulations but requests specific modifications to improve accessi | · | · | · | · | · |
You Dump It, You Drink It Co. AdvocacyOppose You Dump It, You Drink It Co. | · | · | · | · | · |
Alchemy CO2, PBC
BusinessSupport
Alternative Fuels & Chemicals Coalition
AdvocacySupport
Lifecycle modeling and credit certainty
American Biomass Energy Association, American Loggers Council, Forest Landowners Association
AdvocacySupport
American Fuel and Petrochemical Manufacturers
Trade associationOppose
American Petroleum Institute
Trade associationSupport
American Wood Council
AdvocacySupport
Anew Climate LLC
AdvocacySupport
Arkansas Soybean Association
AdvocacySupport
Support for 45z rules
Domestic feedstock prioritization
Expedite usda feedstock calculator
Baker Commodities, Inc.
BusinessSupport
Domestic feedstock prioritization
Bayer Crop Science
BusinessSupport
Support for 45z rules
Domestic feedstock prioritization
Beta Analytic LLC
BusinessSupport
Bioenergy Association of California
AdvocacySupport
Support for 45z rules
Bunge
BusinessSupport
Domestic feedstock prioritization
Recognition of on-farm conservation practices
California Bioenergy LLC
BusinessSupport
CFO Services
BusinessOther
Christianson PLLP
BusinessSupport
Lifecycle modeling and credit certainty
CNX Resources
BusinessSupport
Coalition for Renewable Natural Gas
AdvocacySupport
Support for 45z rules
Continuum Ag
AdvocacySupport
Recognition of on-farm conservation practices
Expedite usda feedstock calculator
Corteva Agriscience
BusinessSupport
Support for 45z rules
Domestic feedstock prioritization
CoverCress Inc
BusinessSupport
Expedite usda feedstock calculator
Darling Ingredients
BusinessSupport
Darling Ingredients EXPOSED
BusinessSupport
Energy Marketers of America (EMA)
Trade associationSupport
Environmental Defense Fund
AdvocacySupport
Lifecycle modeling and credit certainty
Recognition of on-farm conservation practices
Farmer's Biogas Network
AdvocacySupport
Fuels America
AdvocacySupport
Support for 45z rules
Expedite usda feedstock calculator
Granite Falls Energy, LLC
BusinessSupport
Support for 45z rules
Domestic feedstock prioritization
Graphyte, Inc.
BusinessSupport
Expedite usda feedstock calculator
Grissan Renewable Energy
BusinessSupport
Heartland Corn Products
BusinessSupport
Lifecycle modeling and credit certainty
Hereford Ethanol Partners, L.P.
BusinessSupport
Lifecycle modeling and credit certainty
Expedite usda feedstock calculator
HF Sinclair Corp.
BusinessSupport
Support for 45z rules
Horse Farmers of America
AdvocacySupport
IL Corn Growers Association
AdvocacySupport
Expedite usda feedstock calculator
IMAREAN Corp
BusinessSupport
Intermediate Oilseed Crop Association (IOCA)
Trade associationSupport
Expedite usda feedstock calculator
International Council on Clean Transportation
AdvocacySupport
Lifecycle modeling and credit certainty
Recognition of on-farm conservation practices
Iowa Soybean Association
Trade associationSupport
Support for 45z rules
Domestic feedstock prioritization
Kansas Corn Growers Association
Trade associationSupport
Domestic feedstock prioritization
Lifecycle modeling and credit certainty
Kansas Soybean Association
AdvocacySupport
Support for 45z rules
Domestic feedstock prioritization
Expedite usda feedstock calculator
Kentucky Farm Bureau Federation
AdvocacySupport
Recognition of on-farm conservation practices
LanzaJet, Inc.
BusinessSupport
LanzaTech Global, Inc.
BusinessSupport
Lifecycle modeling and credit certainty
Life Cycle Associates LLC
BusinessSupport
Lifecycle modeling and credit certainty
Lyon-Lincoln Electric Cooperative
GovernmentSupport
Support for 45z rules
Maas Energy Works
BusinessSupport
Support for 45z rules
mcr Energy LLC
BusinessOppose
MESKA
BusinessSupport
Minnesota Farmers Union
UnionSupport
Support for 45z rules
Domestic feedstock prioritization
Recognition of on-farm conservation practices
Monarch Bioenergy, LLC
BusinessSupport
Support for 45z rules
National Association of State Departments of Agriculture
AdvocacySupport
Domestic feedstock prioritization
National Corn Growers Association
Trade associationSupport
Support for 45z rules
Domestic feedstock prioritization
National Energy & Fuels Institute
AdvocacySupport
Support for 45z rules
Lifecycle modeling and credit certainty
National Grain and Feed Association
Trade associationSupport
Support for 45z rules
Recognition of on-farm conservation practices
National Pork Producers Council
Trade associationOther
Lifecycle modeling and credit certainty
Recognition of on-farm conservation practices
National Propane Gas Association
Trade associationSupport
Nebraska Corn Growers Association
AdvocacySupport
Recognition of on-farm conservation practices
New West Genetics Inc
BusinessSupport
Oberon Fuels, Inc.
BusinessSupport
POET, LLC
BusinessSupport
Lifecycle modeling and credit certainty
Expedite usda feedstock calculator
Renewable Fuels Association
Trade associationSupport
Domestic feedstock prioritization
Lifecycle modeling and credit certainty
Roeslein Renewables
BusinessSupport
Recognition of on-farm conservation practices
Sievers Family Farms, LLC
BusinessSupport
Support for 45z rules
Recognition of on-farm conservation practices
Southwest Iowa Renewable Energy
BusinessSupport
Sustainable Advanced Biofuel Refiners Coalition
AdvocacySupport
Domestic feedstock prioritization
Taxpayers for Common Sense
AdvocacyOppose
Recognition of on-farm conservation practices
Tennessee Farm Bureau Federation
AdvocacySupport
Domestic feedstock prioritization
Tennessee Soybean Association
Trade associationSupport
Support for 45z rules
Domestic feedstock prioritization
The American Oats Coalition for Energy Security
AdvocacySupport
Domestic feedstock prioritization
The National Apple Demolition and Market Stabilization Coalition (NADMSC)
AdvocacyOppose
The Transport Project
AdvocacySupport
U.S. Canola Association
AdvocacySupport
Domestic feedstock prioritization
Lifecycle modeling and credit certainty
U.S. Chamber of Commerce
BusinessSupport
Support for 45z rules
Recognition of on-farm conservation practices
Expedite usda feedstock calculator
Weaver and Tidwell, LLP
BusinessSupport
Yosemite Clean Energy, LLC
AdvocacySupport
You Dump It, You Drink It Co.
AdvocacyOppose
18 organization-typed comments could not be identified.
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- Apr 16, 2026Divergent RecyclingSupportBusiness📎 Attachment
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.
Read comment → - Apr 9, 2026POET, LLCSupportBusiness📎 Attachment
POET, a biofuel producer, supports the proposed Section 45Z clean fuel production credit and its implementation by the Treasury. The company advocates for specific refinements, including the recognition of regenerative agricultural practices, expansion of the Provisional Emissions Rate process for innovative production methods, and clarifications on "qualified sales" and feedstock designations for sustainable aviation fuel.
Read comment → - Apr 6, 2026Prime Mover InstituteOpposeAdvocacy📎 Attachment
The Prime Mover Institute, a public interest organization, opposes the proposed regulations because they allow for a "book-and-claim" attribution mechanism for energy certificates that they argue does not result in actual emissions reductions. They contend that this mechanism exceeds the statutory requirements of Section 45Z, lacks independent justification for being imported from Section 45V, and creates a substantial fiscal burden on taxpayers.
Read comment → - Apr 6, 2026Sustainable Advanced Biofuel Refiners CoalitionSupportAdvocacy📎 Attachment
The Sustainable Advanced Biofuel Refiners (SABR) Coalition, a group of biodiesel stakeholders, supports the proposed regulations for the Section 45Z clean fuel production credit. They advocate for the timely release of updated emissions models (45ZCF-GREET), the exclusion of indirect land use change (ILUC) emissions, and the simplification of prevailing wage and apprenticeship requirements to reduce administrative burdens on producers.
Read comment → - Apr 6, 2026Christianson PLLPSupportBusiness📎 Attachment
Christianson PLLP, a CPA firm providing services to renewable fuel producers, submitted constructive feedback on the proposed 45Z Clean Fuel Production Credit regulations. They advocate for specific technical refinements regarding verifier definitions, facility boundaries, emissions rounding, and transition relief to ensure program integrity and administrative feasibility.
Read comment → - Apr 6, 2026American Forest & Paper AssociationSupportTrade association📎 Attachment
The American Forest & Paper Association (AF&PA) supports the proposed regulations and urges the Treasury to include transportation fuels from pulp and paper manufacturing byproducts (such as tall oil, methanol, bark, and lignin) in the 45Z credit with an emissions rate of no greater than 50 kg CO2e/mmBTU. They also support the exclusion of electricity from the definition of "transportation fuel" to protect the forest fiber supply.
Read comment → - Apr 6, 2026W2Fuel LLCSupportBusiness📎 Attachment
W2Fuel LLC, a biodiesel production company, supports the proposed regulations for the Section 45Z clean fuel production credit but requests specific clarifications and improvements. The company advocates for a clearer definition of "Producer" to include tolling clients, more precise rounding for carbon reduction scores, and a more practical definition of "repairs" regarding prevailing wage requirements.
Read comment → - Apr 6, 2026Life Cycle Associates LLCSupportBusiness📎 Attachment
Life Cycle Associates, LLC, representing the interests of energy developers, argues for more flexible and consistent methodologies for calculating carbon intensity under the 45Z credit. They specifically recommend allowing for bespoke natural gas upstream emissions data, alternative monitoring standards, and the mass-balancing of energy attribute certificates to ensure that lower-emission production pathways are accurately rewarded.
Read comment → - Apr 6, 2026The Tax Law Center at NYU LawSupportAcademic📎 Attachment
The Tax Law Center at NYU Law, a public interest initiative, submitted comments regarding the proposed regulations for the Section 45Z Clean Fuel Production Credit. They support the proposed definitions for "production," "facility," and the exclusion of electricity as a "transportation fuel," while recommending that the credit should not provide benefits for climate-smart agriculture practices due to scientific uncertainty and lack of verification mechanisms.
Read comment → - Apr 6, 2026Business Council for Sustainable EnergySupportAdvocacy📎 Attachment
The Business Council for Sustainable Energy (BCSE) supports the proposed regulations for the Section 45Z clean fuel production credit, emphasizing the need for regulatory certainty and clear guidance for investors. They advocate for specific technical updates, including a continuous update process for the 45ZCF-GREET model, the inclusion of a mass balance approach for RNG, and the integration of USDA feedstock carbon intensity calculators.
Read comment →