A broad coalition of industry leaders, including the American Carbon Alliance, submitted comments to Treasury and the IRS on the proposed Section 45Z Clean Fuel Production Credit, reinforcing the importance of finalizing rules that enable growth in sustainable aviation fuel (SAF).
The coalition represents more than 50 organizations across the SAF value chain, including airlines, energy producers, manufacturers, and technology developers, highlighting the widespread support for expanding domestic SAF production.
In its comments, the coalition emphasized that 45Z will play a critical role in scaling SAF production, strengthening U.S. energy independence, and creating new markets for American feedstocks.
To ensure the credit achieves those goals, the coalition outlined several key priorities:
- Maintaining a feedstock-neutral approach to avoid limiting SAF production pathways
- Ensuring proper treatment of agricultural carbon intensity and modeling tools
- Allowing mass balance accounting for certain feedstocks like RNG
- Expanding eligibility to include additional fuel pathways and technologies
- Providing a clear and timely process for emissions rate determinations
The coalition also stressed that final tax guidance is essential to unlocking investment and allowing projects to move forward with confidence.
Without timely and workable implementation, producers may face delays or uncertainty that could slow the development of a domestic SAF industry at a critical moment.
The message from industry is clear: 45Z has the potential to drive significant economic growth and energy innovation, but only if the final rules provide the clarity and flexibility needed to scale.
