Comment from The National Apple Demolition and Market Stabilization Coalition (NADMSC)
The National Apple Demolition and Market Stabilization Coalition (NADMSC)SupportTrade association
Summary: The National Apple Demolition and Market Stabilization Coalition (NADMSC) is petitioning the IRS and Department of the Treasury to establish a baseline provisional carbon intensity (CI) score for fuel derived from demolished surplus apples. They argue that the Section 45Z framework must remain technology-neutral and performance-based, asserting that the diversion of these crops from natural decomposition to fuel production qualifies for lucrative negative CI integers.
Pursuant to 5 U.S.C. § 553(e), the National Apple Demolition and Market Stabilization Coalition (NADMSC) hereby petitions the Internal Revenue Service (IRS) and the Department of the Treasury to issue an administrative regulation establishing a baseline provisional carbon intensity (CI) score for fuel derived from unharvested and intentionally demolished surplus orchard products (Malus domestica).
Section 45Z statutorily mandates a technology-neutral, performance-based framework. The Service has no statutory authority to exclude a biological flux based on cultural comfort or the alternative utility of the feedstock (e.g., human nutrition).