Comment from Environmental Defense Fund

Summary: The Environmental Defense Fund (EDF) supports the implementation of the section 45Z clean fuel production credit but urges the Treasury and IRS to establish a rigorous framework for measurement, monitoring, reporting, and verification (MMRV). They specifically advocate for flexible, farm-responsive guidelines for climate-smart agriculture, the use of high-quality data for carbon intensity (CI) calculations, and the alignment of domestic sustainable aviation fuel (SAF) standards with international frameworks like CORSIA.