Comment from American Fuel and Petrochemical Manufacturers
American Fuel and Petrochemical ManufacturersOpposeTrade association
Summary: The American Fuel & Petrochemical Manufacturers (AFPM) opposes the proposed regulations because they favor pro rata allocation over mass balance accounting, which the association argues is inconsistent with industry practices and operational realities. They argue that the proposed requirements are infeasible, increase audit complexity, and lack necessary safe harbor provisions for feedstock origin verification.
Please see the attached comments from the American Fuel and Petrochemical Manufacturers.