Comment from International Council on Clean Transportation

Summary: The International Council on Clean Transportation (ICCT) supports the inclusion of emissions reductions from all stages of the fuel supply chain in the 45Z tax credit, provided they are verifiable and long-lasting. They argue that the current guidance lacks sufficient safeguards for soil organic carbon (SOC) credits and recommend implementing measured baselines, clawback provisions for reversals, and additionality requirements to ensure credits are not awarded for business-as-usual practices.