Comment from American Forest & Paper Association

Summary: The American Forest & Paper Association (AF&PA) supports the proposed regulations and urges the Treasury to include transportation fuels from pulp and paper manufacturing byproducts (such as tall oil, methanol, bark, and lignin) in the 45Z credit with an emissions rate of no greater than 50 kg CO2e/mmBTU. They also support the exclusion of electricity from the definition of "transportation fuel" to protect the forest fiber supply.