Comment from IMAREAN Corp
IMAREAN CorpSupportBusiness
Summary: KVASIR Intelligence™ / CMetricsGlobal / IMAREAN is a company providing intelligence and verification services for climate-smart agriculture. They support the proposed 45Z regulations but argue that the rules should specifically recognize a "two-signal" architecture that combines procedural documentation with independent informational signals (like satellite imagery) to verify agricultural practices. They advocate for a "verified lower-bound settlement" approach to ensure credit integrity and prevent adverse selection or principal-agent risks.
This supplemental comment updates and extends KVASIR Intelligence/ CMetricsGlobal / IMAREAN’s March 7, 2026, submission on REG–121244–23. The comment addresses only the climate-smart agriculture / feedstock-practice component of the 45Z lifecycle carbon-intensity calculation. It does not address plant-side CI reduction strategies, facility registration, qualified-sale documentation, Form 7218 filing, SAF pathways, or other non-feedstock issues.
The comment explains why 45Z climate-smart agriculture substantiation requires two complementary evidence streams: a procedural signal and an independent informational signal. Procedural documentation records what was claimed, how the attribute moved through the transaction chain, and how the credit file was assembled. An independent informational signal establishes what can be verified at the field-year level for observable agricultural practices.
The comment identifies two related economic failure mechanisms in procedural-only architecture. At the First Point of Attestation, missing information creates adverse-selection risk because genuine, partial, and unsupported claims may enter the same premium-bearing pool. At Treasury, the same missing information creates principal-agent risk because the credit-claiming stack may rely on upstream agricultural inputs that Treasury cannot directly observe. The comment recommends that favorable credit treatment for observable climate-smart agriculture practice inputs be settled against independently verified practice, using a verified lower-bound settlement approach.
The comment further recommends that final regulations recognize independent informational evidence as a permissible substantiation category, establish verified lower-bound settlement principles, exclude uncertain acreage from favorable treatment unless otherwise substantiated, and permit retrospective use of archived field-year evidence for 2025 and 2026 transition-year claims.
The proposed approach is technology-neutral and does not ask Treasury to endorse a specific vendor, sensor, or algorithm. It asks Treasury to recognize the evidentiary category needed to make the climate-smart agriculture component of 45Z scalable, auditable, incentive-compatible, and administrable.