Comment from Prime Mover Institute
Prime Mover InstituteOpposeAdvocacy
Summary: The Prime Mover Institute, a public interest organization, opposes the proposed regulations because they allow for a "book-and-claim" attribution mechanism for energy certificates that they argue does not result in actual emissions reductions. They contend that this mechanism exceeds the statutory requirements of Section 45Z, lacks independent justification for being imported from Section 45V, and creates a substantial fiscal burden on taxpayers.
Attached please find Prime Mover Institute’s Comment on the Proposed Rule Entitled: Proposed Regulations Under Section 45Z of the Internal Revenue Code (REG-121244-23), 91 Fed. Reg. 5160 (Feb. 4, 2026).