Comment from Fuel Cell and Hydrogen Energy Association (FCHEA)

Summary: The Fuel Cell and Hydrogen Energy Association (FCHEA) supports the proposed regulations for the Section 45Z Clean Fuel Production Credit but requests several specific modifications to ensure industry feasibility. The association argues for clearer definitions regarding "primary" feedstocks, the inclusion of Power-to-Liquids (PtL) pathways in the GREET model, and the ability for taxpayers to "lock in" emissions models and provisional rates to provide long-term investment certainty.