Clean Fuels and CABA submit comments to CARB on Second 15 Day Package

Clean Fuels and CABA submit comments to CARB on 15 Day Package

Twenty-five trade associations representing producers, feedstock providers, blenders, consumers, and retailers of low-carbon, renewable fuels sent a letter to Treasury Secretary Janet Yellen, urging Treasury to finalize and publish guidance for the §45 Clean Fuels Production Credit as soon as possible.

Clean Fuels advocates policies to increase biodiesel, renewable diesel, and sustainable aviation fuel (SAF) production and the associated jobs, economic opportunities, agricultural markets, and environmental benefits. Co-processed fuel does not generate the same benefits and should not qualify for policy incentives.

Each of our industries are committed to reducing greenhouse gas emissions, and we recognize that sustainable biofuels offer some of the most substantial immediate benefits to deliver carbon reductions. The EPA should utilize the RFS to improve energy security, bolster domestic industry and manufacturing, and maintain America’s leadership in developing and using sustainable, clean transportation technologies. While our industries will continue to make investments in producing, distributing, and using low-carbon fuels, EPA can and should send a strong signal to the market through robust RVOs.

Clean Fuels, ASA, NOPA and U.S. Canola urge using the most recent version of the GREET model as the “similar methodology” option for determining SAF tax credit eligibility.

EPA's 2023 RFS volumes for biodiesel and renewable diesel are a step in the wrong direction.

The final RFS rule must increase the volumes for biomass-based diesel to reflect market conditions.

SAF derived from co-processing is ineligible for the tax incentive. Treasury should adopt GREET as the similar methodology.

The Proposed Renewable Fuel Standard Rules for 2023, 2024 and 2025 did not provide the expected upward trajectory for the biomass-based diesel industry.

Treasury should adopt the U.S. Department of Energy’s Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies
(GREET) model as the secondary methodology for calculating tax credits for sustainable aviation fuel (SAF) produced

Increased production of biodiesel and renewable diesel in 2023 illustrates the need for EPA to raise RFS volumes substantially.

Treasury should use GREET -- a U.S. lifecycle carbon emissions accounting model -- to determine tax credits for U.S. produced fuels.

EPA cannot discount the immediate benefits biodiesel and renewable diesel have as we decarbonize the heavy-duty sector.

Consumers want to decarbonize and are already doing so using Bioheat ® Fuel in existing home heating fuel systems. These systems merit Energy Star designation

Using biodiesel and renewable diesel today will lower health care impacts and costs for all populations living in and near these areas including minority, low-income, and indigenous populations.

The U.S. National Blueprint for Transportation Decarbonization notes that clean, sustainable fuels are needed right now to drive emissions reductions and set us on a road to a clean transportation future.

Our industry’s growth is consistent with the goals to address environmental health and provide consumer benefits at the pump

We urge EPA to re-examine its assessments of the biofuels and agricultural markets and the methodology it uses to assess land cover and land management change

Increasing production of clean fuels through the RFS improves U.S. energy security, lowers diesel fuel prices, and generates carbon and emission reductions today that are necessary to meet future national environmental goals

Infograph: Since 2011, California's biodiesel and renewable diesel use has reduced the state’s greenhouse gas
emissions by 105 billion pounds.

It is critical that Treasury and IRS implement a verified, current, and science-based emissions rate methodology to set tax credit values.

In 2021, while petroleum production fell, the biodiesel and renewable diesel industry grew and added jobs. Stable tax incentives were a key reason.

The biodiesel tax incentive supports thousands of rural jobs and environmental benefits worth $4 billion in 2020.

The RFS increases the supply of distillate fuels used to transport consumer items. The added supply keeps prices at the pump lower.

USDA's Rural Energy Pilot Program should support biodiesel and renewable diesel projects, not just distributed renewable electricity.

USDA can leverage existing programs to encourage voluntary adoption of agricultural practices that sequester carbon, reduce greenhouse gas emissions, and ensure resilience to climate change.

USDA should develop methods to assign changes in soil organic carbon to specific practices and crop rotations and then allow biofuel producers to incorporate these carbon reduction in lifecycle assessments.

Clean Fuels asks that USDA support Bioheat(R) fuel and SAF infrastructure and prioritize funding for existing and emerging markets.

The industry's federal policy priorities include stable tax incentives, funding for infrastructure, and optimizing the RFS to achieve carbon reductions.

Biodiesel, renewable diesel, and SAF are innovative technologies that can support USDA's goals for carbon reductions in the agriculture sector.

The clean fuels industry is a pivotal contributor to rural economies,
creating jobs and value-added markets. Biodiesel and renewable
diesel use can improve environmental health and reduce associated costs for both rural and urban communities. Cleaner, better fuels highlight the contribution that rural economies can make to the
nation’s overall climate and carbon reduction goals