The American Coalition for Ethanol (ACE) this week submitted virtual comments in response to the U.S. Department of Agriculture (USDA) request for information on the production of biofuel feedstocks using climate-smart agriculture (CSA) practices.
ACE CEO Brian Jennings emphasized the organization’s key priorities and encouraged USDA to continue engaging with Treasury and leverage ACE’s Regional Conservation Partnership Program (RCPP) projects to help inform more accurate and updated GHG credit values for CSA practices as the Treasury Department implements the 45Z Clean Fuel Production tax credit under the Inflation Reduction Act (IRA).
Jennings highlighted the following priorities:
Models and credit values for CSA practices should be routinely updated, incorporating data collected through ACE’s RCPP projects. Ultimately, our projects are designed to improve the accuracy of GREET and address perceived “information gaps” currently preventing farmers and ethanol producers from monetizing CSA practices in regulated markets.
45Z should allow individual CSA practices and stacking of agricultural practices. Do not require the all-or-none “bundled” approach from 40B or arbitrarily cap agriculture practice GHG credit values.
USDA has a long track record of stewarding federal taxpayer funds for commodity and conservation programs, ensuring that participating farmers meet necessary requirements to receive federal funds. If existing USDA protocols are sufficient for verifying the distribution of billions of taxpayer dollars for commodity and conservation programs, USDA protocols are equally sufficient for verifying the same practices for federal tax incentives such as 45Z. The Treasury Department should rely on existing USDA assets in the reporting and verification for the 45Z tax credit, and we encourage USDA to directly engage Treasury with respect to its expertise and experience in this area.