The National Pork Producers Council asked the Treasury Department’s Internal Revenue Service to delay a proposed rule to implement the 45Z Clean Fuel Production Credit until two analytical tools are finalized and made available for public review and comment. 45Z Clean Fuel Credit provides a tax incentive for production of low- and zero-emission transportation fuels and the council says stakeholders must see the final models before a rule is set. NPPC told the IRS that without those tools, the pork industry cannot assess how the program will operate in practice or how it will affect farm economics.
The 45Z program covers fuels such as ethanol, sustainable aviation fuel and renewable natural gas and ties credit eligibility and amounts to feedstock carbon intensity scores. Producers see potential revenue from recognizing the economic and environmental value of livestock manure, but NPPC warned the rule’s current structure — which requires feedstocks to come from crops grown in North America — could shift demand and prices in grain and oilseed markets. The council called for clarity on how manure-based practices will be scored relative to crop production.
NPPC’s primary technical concern centers on the Feedstock Carbon Intensity Calculator that quantifies greenhouse gas emissions per bushel for field corn, soybeans and sorghum and feeds directly into 45Z eligibility and credit calculations. The current version of the calculator, NPPC said, does not account for the use of manure nutrients as a conservation practice input, a factor that can lower a farm’s carbon intensity score and thus affect credit value. Calculator omits manure was a central point in the comments filed with Treasury.
Model and market impacts
In a separate letter to Agriculture Secretary Brooke Rollins, Energy Secretary Chris Wright and Treasury Secretary Scott Bessent, NPPC joined 20 agriculture and energy organizations in requesting the timely completion and public release of updates to the GREET life-cycle analysis model. The GREET tool is used to evaluate energy use, greenhouse gas emissions and environmental impacts of fuels and is necessary to implement 45Z and calculate precise credit values. 20 groups co-signed the letter urging that GREET updates be available before a final rule is issued.
NPPC warned that the interaction between 45Z, sustainable aviation fuel markets and carbon intensity scoring will reshape feedstock economics, including feed grain markets, oilseed demand and the value of crop and livestock byproducts. Livestock producers need to know how those shifts will affect input costs, how manure will be scored versus crops, and whether environmental contributions from diverse livestock systems will be fairly valued under the program.
In its comments, NPPC urged the IRS to withhold issuing a final rule until the Feedstock Carbon Intensity Calculator and GREET model updates are finalized and released for stakeholder review, saying stakeholder feedback is impossible to provide meaningfully without the finished tools. The council emphasized that the calculator score determines 45Z program eligibility and the amount of the tax credit, making the technical fixes central to how the rule will operate in the field.
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