Specifically, Growth Energy’s comments on the 45Z tax credit called on Treasury and IRS to:
· Allow taxpayers to deduct emissions associated with indirect land use change from the current 45ZCF-GREET Model.
· Ensure that the 45ZCF-GREET User Manual allows producers to account for additional food and beverage-related emissions reductions, and all carbon capture, utilization, and storage (CCUS)-related emissions reductions verified using a Section 45Q lifecycle analysis.
· Allow on-farm agricultural practices to reduce carbon intensity (CI).
· Structure the Section 45Z regulations so that they have no arbitrary restrictions on the use of renewable energy certificates (RECs) to demonstrate CI reductions.
· Provide further flexibility and clarity in demonstrating compliance with the prevailing wage requirements.
· Clarify that exported ethanol that is “suitable for use as a fuel” is eligible for the Section 45Z credit.
· Promptly finalize the provisional emissions rate process.
Tags: Growth Energy, Section 45Z, Washington
Category: Fuels
