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.