Biofuels groups submitted comments this week to USDA on its interim rule for climate-smart agriculture guidance to support the new 45Z tax credit for clean fuel producers.
The Renewable Fuels Association emphasized the importance of policies that empower farmers while ensuring a robust and efficient renewable fuels market.
RFA highlighted the benefits of a book-and-claim supply chain management system, which would allow farmers to sell the emissions reduction value of their on-farm practices separately from their physical crops, thereby ensuring flexibility in the grain market while still incentivizing sustainable farming.
RFA also argued for including enhanced efficiency fertilizers as an eligible practice in the final rule.
The American Coalition for Ethanol highlighted the importance of ensuring the guidelines are fully integrated into the implementation of the 45Z Clean Fuel Production Tax Credit and adopted consistently in state and regional clean fuel programs. ACE also emphasized the need for continuous improvement of the Feedstock Carbon Intensity Calculator (FD-CIC) accounting for specific crop yield, climate, soil, and management-specific estimates of nitrogen use efficiency and nitrous oxide emissions, as well as making updates based on real-world data, such as findings from ACE’s own USDA-funded Regional Conservation Partnership Program (RCPP) projects.
Clean Fuels Alliance America recommends USDA incorporate intermediate oilseed crops – such as winter canola – as a conservation crop rotation practice and update the USDA FD-CIC model to include these crops. Clean Fuels also urges USDA to ensure that the standards and requirements in the CSA program are complementary to the requirements for other USDA programs, particularly crop insurance.