Comment from CNX Resources
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Summary: CNX Resources Corporation supports the 45Z Clean Fuel Production Credit as a means to incentivize the capture and use of coal mine methane (CMM) as a low-carbon feedstock. The company argues that the regulations should recognize CMM venting as the primary counterfactual scenario in emissions modeling and opposes the expansion of negative emissions rate prohibitions to include process fuels.
Re: Comments requested under REG-121244-23 Pertaining to the Section 45Z Clean Fuel Production Credit
Thank you for the opportunity to comment regarding the Notice of Proposed Rulemaking REG-121244-23 relating to Internal Revenue Code1 Section 45Z, Clean Fuel Production Credit (“45Z Credit”) and the initial emissions rate table as established by the Inflation Reduction Act of 2022 (“IRA”). The contents of this comment focus on one clean fuel included in the 45ZCF-GREET model: waste gas captured from active and abandoned mining activity, also known as coal mine methane (“CMM”). CMM is a source of alternative natural gas, which, when directly used as a transportation fuel, is a subset of Compressed Alternative Natural Gas (“CANG”).
Brent Bobsein
CNX | Vice President of Sustainable Development