Department of Energy – Office of Energy Efficiency and Renewable Energy
John Cabaniss
1000 Independence Ave SW
Washington, DC 20585
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Regarding: Procedures for Quantification, Reporting, and Verification of Greenhouse Gas Emissions Associated with the Production of Domestic Agricultural Commodities Used as Biofuel Feedstocks
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Mr. Cabaniss,
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On behalf of Incite.ag, a farmer-founded carbon intensity (CI) scoring and software company specializing in clean fuel and feedstock production, we appreciate the opportunity to provide comments on the Department of Energy’s intent to publish the 45Z Emissions Value Request Process.
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We view Section 45Z as more than a clean fuel incentive. It is a practical framework to connect the efficiency and innovation of America’s agricultural supply chain to enhanced fuel markets. If designed correctly, the emissions value request process can give producers a clear and timely path to reflect their operational improvements in carbon intensity scoring. To achieve that, DOE must ensure the process is workable for a wide array of clean fuel producer-plants, reflects real production data, and supports verifiable pathways.
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Recognizing Plant-Level Innovation with a Flexible GREET Architecture

DOE should design the Provisional Emissions Rate (PER) process to allow ethanol producers to file using a modified GREET1 or GREET R&D model with bounded flexibility and auditable integrity.
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While DOE may wish to fix certain background parameters in the 45Z-GREET model, locking producers into an emissions value they did not generate and cannot improve undercuts the purpose of Section 45Z. DOE should enable user-defined inputs, subject to documentation, including:

• Chemical and enzyme usage, including fermentation aids
• Fiber-based and/or cellulosic ethanol production, including Edeniq pathways
• Energy source data, including onsite surplus renewable electricity production, RECs / EACs, and renewable natural gas
  
• Transportation distances and logistics for both feedstock intake and fuel distribution
• Thermal efficiency and process flow metrics verified by metering or engineering records
• Novel co-products such as high-protein feeds and improved distillers corn oil extraction

Allowing these parameters to be updated in appropriately locked and verifiable GREET framework would let producers pursue measurable emissions reductions while maintaining model integrity.
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Feedstock Carbon Intensity
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Flexibility is especially important for feedstock emissions. The PER process must allow plants to reflect the actual CI of their inbound grain supply. Treating corn as a uniform commodity ignores the most powerful driver of CI reductions across the ethanol supply chain: the farmer and feedstock supplier.
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The USDA has issued technical guidance under 7 CFR 2100 and released the Feedstock Carbon Intensity Calculator (FD-CIC) to score on-farm emissions in grams CO₂e per bushel. These scores can be aggregated by fuel producers into a weighted average CI input for GREET1.
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We urge DOE to:
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• Accept CI scores calculated via USDA’s FD-CIC as valid inputs into a PER submission
• Allow feedstock CI data (g/bu) to replace or adjust default upstream emissions in GREET modeling
• Define third-party verification pathways to ensure the traceability and accuracy of feedstock-level data
  

This approach aligns with USDA’s framework and ensures that measurable on-farm reductions are carried through to the fuel-level CI score.
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Alternatives to FEED for Demonstrating Readiness
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DOE’s current proposal references Front-End Engineering and Design (FEED) studies as a prerequisite for demonstrating project readiness. While FEED is appropriate for capital-intensive projects involving new construction or major retrofits, it is not suited for agricultural feedstock CI programs. These programs are driven by data quality, traceability, and verification from farms, aggregators, and ethanol plants rather than engineering diagrams or cost estimates.
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Requiring FEED would impose unnecessary costs and delays while excluding the most scalable reductions in the sector: those tied to on-farm practices. Ethanol plants do not need a resource-intensive FEED package to show maturity of a feedstock CI program. Instead, readiness should be demonstrated through:
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• Adherence to USDA 7 CFR Part 2100 guidelines for CI scoring using the FD-CIC platform
• Auditable mass balance data at the plant or aggregator level to show low-CI grain is sourced and properly
  accounted for
• Documented farmer practice adoption through contracts, attestations, and supporting records
  
• Independent verification of data integrity through audits or attestations
  

These elements provide equal or greater confidence of readiness compared to FEED and reduce unnecessary administrative burden.
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Refining the Submission Process
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The 45Z emissions value request process must be cost-effective, transparent, and accessible, especially for ethanol plants and producers without large compliance teams.
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Key implementation principles include:
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• Modeling Platform: Allow use of version-locked GREET1 or R&D GREET with clear rules around modifiable
  parameters and audit trails.
• Submission Pathway: Provide a digital portal that accepts structured inputs (e.g., JSON, XML,
  standardized Excel) and supporting documentation in a secure format.
• Verification Options: Allow multiple forms of verification, including third-party attestations, processorlevel
  mass balance tracking, or aggregated supplier documentation.
• Timeliness: Commit to a 60-day turnaround for determinations.

DOE must also recognize the difficulty of submitting applications before final guidance is issued. Because year-end is approaching, many plants are at risk of missing the 2025 credit year. DOE should provide a safe harbor or grandfathering mechanism that allows producers to rely on older data or provisional submissions to preserve credit eligibility. Without such a provision, even early adopters could be penalized due to timing beyond their control. These submissions should also include:
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• Resubmission Flexibility: Permit updated submissions on an annual basis or when material operational changes occur.
• Clarity for First-Time Applicants: Publish template packets and worked examples of acceptable
  submissions to reduce onboarding time and support participation from smaller producers.

Conclusion
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Section 45Z can accelerate innovation in agriculture and fuel production, but only if the emissions value request process is timely, transparent, and workable. Producers are already making investments in renewable energy procurement, efficiency improvements, and low-CI grain sourcing. The DOE process must recognize those efforts without unnecessary delay.
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DOE should implement a system that allows reasonable flexibility in GREET inputs, accepts USDA feedstock CI data, provides verification pathways, and ensures determinations are issued quickly. These measures will reduce uncertainty, support continued investment, and give producers confidence to participate fully in the program.

Incite.ag stands ready to assist DOE with data, tools, and feedback to help ensure the process is practical and
effective.
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Sincerely,

Preston Brown
President | Founder
Incite.ag
preston@incite.ag
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Incite.ag guides producers across the agricultural supply chain to Turn Emissions into Income. Incite.ag’s CI scoring system unlocks novel revenue streams and empowers producers to take control of their unique CI Scores. Learn more by hitting the link below or reach out to the team directly at success@incite.ag or 815.373.0177.