Clean Fuels Policy Priorities

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.

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.