Comment from American Carbon Alliance
American Carbon AllianceSupportAdvocacy
Summary: The American Carbon Alliance, a coalition of agricultural, biofuels, and energy stakeholders, requests that the Treasury and IRS provide specific guidance on compliance pathways for Section 45Q carbon oxide sequestration credits. They argue that if the EPA repeals or revises Subpart RR requirements, the IRS should allow Class VI well monitoring and independent mass balance accounting to satisfy monitoring and verification standards to ensure investment certainty.
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