USDA received testimony Tuesday at a public consultation on climate-smart agriculture (CSA) and biofuel feedstocks urging federal agencies to embrace book-and-claim supply chain management approaches to decouple CSA carbon credits.

Renewable Fuels Association President and CEO Geoff Cooper said in his testimony that innovative supply chain management solutions are needed to fully realize the benefits of CSA practices in the 45Z program.

“If 45Z and other regulations require that physical commodities grown using CSA practices be rigidly tracked through the supply chain and delivered to biofuel production facilities, this could severely limit the adoption of such practices, and it could cause significant distortions in grain flows and pricing,” he said. “Decoupling CSA attributes from the physical feedstock and allowing the biofuel producer to use book-and-claim accounting would encourage widespread adoption of CSA practices by growers and broad incorporation of CSA emissions improvements into biofuel lifecycle CI values.”

Iowa Renewable Fuels Association (IRFA) Policy Director Nathan Hohnstein made similar comments to USDA, stating that decoupling would allow farmers to have maximum participation potential.

“As many have pointed out, there are massive benefits to a book and claim model including spurring widespread adoption of CSA by farmers and allowing biofuel producers to source feedstock efficiently, all while easing the enforcement burden of tracking individual kernels or grains by federal regulators…” stated Hohnstein during the session today. “Such a process would not only lower expenses and risk of inaccurate credits thereby benefiting farmers and increasing adoption of CSA practices.”