Growth Energy sent the letter in response to the IRS’s call for public comment on its implementation of the IRA’s 40B Sustainable Aviation Fuel Tax Credit and the 45Z Clean Fuel Production Tax Credit. This is the third time Growth Energy has submitted comments to the IRS on these incentives, and the third time it has reiterated to the agency how important it is that the most thorough, accurate science be used to determine which producers are eligible for the tax credits and how much they can claim.