Comment from Food & Water Watch

Summary: Food & Water Watch and several other environmental and agricultural advocacy organizations are submitting comments on behalf of the IRS. They argue that the proposed regulations should not allow "factory farm biogas" to claim negative emissions credits, as doing so creates perverse incentives for factory farms to increase pollution and expand operations. They request that the IRS either apply a conservative baseline for these fuels or exercise its discretion to apply a "no less than zero" emissions rate.