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NCFC Comments to IRS on Definition of Energy Property and Rules for Energy Credits

March 18, 2024
  Submitted via

Vivian Hayes
Internal Revenue Service
U.S. Department of Treasury
Room 5203, P.O. Box 7604,
Ben Franklin Station,
Washington, DC 20044

Attention – Comments Regarding the Definition of Energy Property and Rules Applicable to the Energy Credit; REG-132569-17

  1. Introduction
Thank you for this opportunity to provide comments regarding the Notice of Proposed Rulemaking on the definition of energy property and rules applicable to the energy credit. Our feedback highlights concerns that the proposed rule would have a negative impact on farmer-owned cooperatives.

Since 1929, the National Council of Farmers Cooperatives (NCFC) has been the voice of America’s farmer-owned cooperatives. NCFC members include regional and national cooperatives, which in turn consist of nearly 2,000 local farmer cooperatives across the country. Farmer cooperatives—businesses owned, governed, and controlled by farmers and ranchers—are an important part of the success of America’s supply chain that includes suppliers of goods, services, and energy to the country’s working lands, the farmers and ranchers responsible for the abundance that comes from those lands, and the processing, manufacturing, packaging, marketing and sale of that abundance to agriculture’s customers. More information about NCFC can be found at

NCFC has a very diverse membership, which we view as one of our sources of strength – our members are located throughout the country, provide agronomy and other technical expertise and services, supply nearly every agricultural input imaginable, drive innovation, develop new technologies, provide credit and related financial services, market a wide range of commodities, produce value-added products, and produce energy for our nation’s supply chain.
  1. Single Ownership Requirement Concerns
The proposed rule would have a harmful impact on biogas equipment owners with shared ownership, a common arrangement for agricultural energy producers. Because biogas equipment is prohibitively expensive, farmers and ranchers work with cooperatives or other organizations to facilitate shared ownership of equipment. Such arrangements allow producers to participate in green energy markets and benefit from the allowable tax incentives. As American supply chains continue to demand greener and more sustainable energy solutions, it is critically important that IRS regulations do not leave farm communities behind. Biogas energy production allows producers to reduce climate impacts while improving energy solutions for American consumers. The current proposed rule would stifle this process towards greener, more sustainable energy solutions while simultaneously hurting farmers and ranchers. The rule as proposed would have an exclusionary effect on American agriculture and specifically on farmer-owned cooperatives by denying the tax credit to owners of shared biogas equipment. We ask that you remove the single-ownership requirements for the applicable tax credit.
  1. Conclusion
Farmer-owned cooperatives stand ready to work with the IRS to ensure that the proposed rule does not have a negative impact of farmers and ranchers who are involved in the production of biogas. We appreciate the opportunity to provide feedback and look forward to further discussions on this issue.   Sincerely, 

Charles F. Conner
President & CEO

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