Section 45Z Clean Fuel Production Credit

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.

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 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.

The American Zooilllogical Association (AZA) expresses strong support for the Section 45Z framework and requests that humanure from composting toilets be added to the accepted feedstock list. They argue that human waste should be eligible for carbon intensity credits based on the same anaerobic digestion mechanics and avoided emissions methodology used for livestock manure.

Baker Commodities supports the proposed Section 45Z regulations but requests specific modifications to ensure the credit rewards domestic production. They advocate for standardizing the "tallow" designation to "U.S. Tallow" to prevent confusion with imports and suggest implementing rigorous chain-of-custody requirements for foreign feedstocks to prevent fraud and ensure credit integrity.

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.

The commenter, identifying as a member of a group called "CITIZENS IN FAVOR OF CORPORATE BAILOUTS," expresses extreme hostility toward the "equinetarian" movement and the specific script provided in the comment. They do not provide a clear position on the 45Z Clean Fuel Production Credit regulations themselves, but rather use the docket to mock and attack a specific ideological group.

Friends of Horse Use & Abuse (FHUA), a non-profit organization, supports the proposed regulations and specifically advocates for the inclusion of U.S. Equine Protein and U.S. Equine Lipid as primary feedstocks for Sustainable Aviation Fuel (SAF). They argue that equine biomass offers a low carbon intensity, improves soil health, and provides a more environmentally friendly alternative to ruminant-based bio-solids.

The U.S. Chamber of Equine Exploitation (USCEE) supports the proposed Section 45Z regulations and urges the IRS to expand credits for equine-derived feedstocks and lipids. They advocate for specific protocols to claim "negative emissions" credits and "triple-dip" the use of equine-derived materials for fuel, protein, and litter.

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.