Comment from The National Apple Demolition and Market Stabilization Coalition (NADMSC)
The National Apple Demolition and Market Stabilization Coalition (NADMSC)OpposeAdvocacy
Summary: The National Apple Demolition and Market Stabilization Coalition opposes the proposed Section 45Z regulations, arguing that the tax credits create a market anomaly that incentivizes diverting agricultural output toward fuel production rather than human consumption. They contend that the current framework will lead to a "sub-economic inversion" where food becomes a secondary byproduct of the refining process and demand that the IRS include penalties for primary food diversion.
This Addendum officially updates the administrative record under 5 U.S.C. § 553(e) to present a foundational structural critique regarding the long-term allocation incentives generated by the proposed Section 45Z regulations. The current statutory framing introduces a severe market anomaly: the complete lack of human-centric point-of-sale subsidies paired with multi-layered, stackable incentives for industrial refining creates an environment where processing caloric matter for fuel is fundamentally more liquid and secure than distributing food to humans.
Because the open market operates on capital flow rather than human utility, the financial delta between unsubsidized human retail and guaranteed, technology-neutral federal tax windfalls dictates an inevitable systemic trajectory. At current localized and international production scaling rates, the primary market incentive will shift to routing 100% of standard agricultural output through a refining matrix first to harvest the upfront Section 45Z credit values.