Comment from National Alliance of Forest Owners (NAFO)

Summary: The National Alliance of Forest Owners (NAFO), joined by numerous state and national forestry organizations, supports the Section 45Z Clean Fuel Production Credit as a means to create markets for low-value woody biomass. They argue that the final regulations must ensure that forest-based fuels are eligible by using lifecycle modeling that accurately reflects forest carbon cycles and provides clear, practical pathways for producers to establish emissions rates.