Accompanying ACE’s letter was an analysis prepared by Ron Alverson of the ACE board of directors comparing modeled estimates of land use change (LUC) to what has occurred in the real world.
“As the much-anticipated deadline nears for 40B GREET for SAF, I stress the importance of GHG credits for climate-smart agriculture practices and a final methodology based on real-world observations of land use change instead of inflated assumptions generated from unreliable economic models,” Jennings wrote. “ACE believes carbon credits for climate-smart agriculture are essential because they incentivize on-farm practices which can reduce or even prevent land use change-related emissions.”
The ACE letter also references a recent USDA decision to provide $25 million for a Regional Conservation Partnership Program (RCPP) led by ACE. The funding will help farmers adopt reduced tillage, nutrient management and cover crops on nearly 100,000 acres across 167 counties surrounding 13 ethanol facilities partnering with ACE in a 10-state region of Illinois, Indiana, Iowa, Kansas, Minnesota, Missouri, Nebraska, Ohio, South Dakota and Wisconsin.
“Our USDA-RCPP project can help members of the Interagency Working Group minimize or even control land use change if you ensure GREET is used to provide carbon credits for climate-smart ag practices, not only for 40B, but also for the 45Z clean fuel production credit,” said Jennings.