Comment from The Breakthrough Institute
The Breakthrough InstituteSupportAdvocacy
Summary: The Breakthrough Institute, an independent research center, supports the proposed regulations but urges the Treasury to clarify that the exclusion for indirect land use change emissions should not also exclude direct land use change emissions. They argue that direct land conversion from crop-based biofuels is substantial and must be accounted for in the lifecycle greenhouse gas emissions calculations to ensure the credit accurately reflects environmental impacts.
Please see the Breakthrough Institute's comment attached. Thank you for your consideration and efforts.