Comment from National Propane Gas Association
National Propane Gas AssociationSupportTrade association
Summary: The National Propane Gas Association (NPGA) supports the proposed regulations for the Section 45Z Clean Fuel Production Credit, specifically praising the clarity on feedstocks and the flexibility regarding credit transferability. While they support the rule, they express concerns that the GREET model used to determine greenhouse gas emissions may overstate emissions for propane based on flawed historical data.
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