Comment from IMAREAN Corp
IMAREAN CorpSupportBusiness
Summary: KVASIR Intelligence (IMAREAN) argues that the proposed regulations should explicitly recognize independent satellite-based remote sensing as an acceptable method for substantiating climate-smart agriculture practices. They contend that satellite MRV provides a scalable, low-cost, and independent observational layer that addresses the "self-attestation gap" and reduces compliance burdens for smaller entities.
MAREAN respectfully submits the attached formal written comments on the proposed regulations under Section 45Z Clean Fuel Production Credit (REG–121244–23), published in Federal Register Vol. 91, No. 23 (February 4, 2026).
These comments are submitted by Aurea Rivera, P.E., Founder and Chief Intelligence Officer, Licensed Professional Engineer (Ohio, Florida), NSPE Fellow, PMP, PMI-ACP, with a patent application pending on multi-spectral satellite verification methods for climate-smart agriculture practice determination.
The attached comments address a single, focused question: how Treasury should define acceptable substantiation methods for on-farm climate-smart agriculture practice adoption, specifically through independent satellite-based measurement, reporting, and verification (MRV). Six formal regulatory requests are included, with suggested regulatory language for Comment 1.
These comments are grounded in completed operational verification work covering approximately 1.66 million acres across Iowa and Illinois, with methodology technically reviewed by an independent MRV specialist and frozen at version 4.1. The full evidentiary basis, methodology documentation, and regulatory analysis are contained in the attached PDF.
KVASIR Intelligence is prepared to provide Treasury with demonstration verification reports, full methodology documentation, and participation in any technical working group convened to develop satellite verification standards under the final regulations. A request to testify at the May 28, 2026 public hearing has been submitted separately to publichearings@irs.gov.