Growth Energy: Changing GREET Would Undermine Climate Goals, Harm U.S. Biofuel Producers

WASHINGTON, D.C.—Growth Energy, the nation’s leading biofuel trade association, continued to urge the Internal Revenue Service (IRS) to follow the science, and the law, when developing greenhouse gas (GHG) lifecycle analysis (LCA) models used to assess eligibility for tax incentives under the biofuels provisions of the Inflation Reduction Act (IRA).

In comments on proposed Section 45V hydrogen regulations submitted today to the IRS and forwarded to the IRA Interagency Working Group, Growth Energy called on the IRS to follow Congress’s intent and ensure that any “successor” LCA model developed to assess eligibility for IRA biofuels tax incentives, such as those governing hydrogen in Section 45V, sustainable aviation fuel (SAF) in Section 40B, and biofuels generally in Section 45Z, “closely adheres in function and conceptual approach to the Argonne GREET model in existence at the time Congress enacted the IRA.”

Growth Energy also argued that such successor GREET models should incorporate the best available science “based on accurate and credible data, particularly when accounting for inputs such as emissions from indirect land use change (iLUC) which can be relevant to biofuels’ LCA.” Growth Energy underscored the importance of using the best available science, noting that updated estimates of biofuels’ iLUC impacts are “two to four times lower” than the U.S. Environmental Protection Agency’s 2010 assessment. Outdated LCAs can “dramatically overestimate the carbon intensity of energy or fuel sources, risking the possibility of excluding them from qualification under the IRA,” which “not only undermines the decarbonization goals of the IRA but also harms producers and businesses.”

Growth Energy then offered a framework for “evaluating the best available science that the IRS should incorporate into any successor GREET model.” Adopting Growth Energy’s recommendations, the comment argued, will “create stability and certainty regarding the significant investments being made in low-carbon energy and fuel sources.” Failing to do so would jeopardize the ability of American biofuels to participate in next generation opportunities like SAF.

Today’s comment letter referred specifically to the IRS’ proposal for 45V but echoed many similar statements made previously by Growth Energy about the importance of modeling and the accuracy of the Argonne National Lab’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model. Read the full version of today’s letter here.