Category
Transportation
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What’s good and what’s missing from biofuel safeguards in California’s updated Low Carbon Fuel Standard
California’s Air Resources Board (CARB) is on the verge of major updates to its Low Carbon Fuel Standard (LCFS).
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Allow hydrogen storage to receive credits under 48E regardless of ultimate end use
The Issue Limiting 48E eligibility to hydrogen storage used for power applications is not required by the statute and is difficult to administer. Hydrogen storage should qualify for the section 48E investment tax credit (ITC) irrespective of the ultimate end use of the stored hydrogen. Treasury’s proposed guidance limits the…
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Synthetic SAF can, and should, qualify for 45Z
Synthetic SAF will be an essential component of aviation decarbonization Synthetic sustainable aviation fuel (SAF) will be essential to decarbonizing aviation, especially as the sector’s demand for low-carbon energy carriers continues to grow. CATF analysis has shown that biofuel supply will not be able to keep pace with this demand…
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Carbon intensity of vegetable-based oils must full account for cross-market substitution effects
Carbon intensity calculations for vegetable oil-based fuels must fully account for the effects of cross-market substitutions, in line with Congress’ restrictions on palm fatty acid distillates Diverting certain vegetable oils toward the energy sector can create supply gaps that may be filled by carbon intensive palm oil Congress sought to…
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Negative emissions rates: potential for extreme, unintended fiscal and environmental consequences
Treasury must not include negative emissions values in the published table of emissions rates or allow 45Z credits for blending fossil natural gas with biomethane or captured fugitive methane Negative emissions rates could have extreme, unintended fiscal and environmental consequences Assigning negative emissions rates to certain fuels––such as compressed biomethane…
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Properly accounting for indirect land use change
If Treasury uses GREET to model SAF lifecycle greenhouse gas emissions, it must modify it to be both similar to CORSIA and to fully account for indirect land use changes Statutory overview Section 45Z requires that lifecycle greenhouse gas (GHG) emissions for SAF be determined using either “(I) the most…
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Climate Smart Agriculture practices require differentiation
Climate Smart Agriculture practices should be differentiated based on the measurability of their impact on the carbon intensity of fuels In the final guidance for the 40B SAF tax credit, Treasury utilized the USDA Climate Smart Agriculture (CSA) pilot program to reward farming practices that can result in lower greenhouse gas…
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Statutory overview of 45Z
Statutory overview of the 45Z tax credit Section 45Z provides tax credits for clean fuel production based on the fuel’s carbon intensity. Unlike previous fuels credits,1 section 45Z is set up to incentivize deep reductions in the carbon intensity of transportation fuels by awarding higher credit amounts to cleaner fuels. …
