Clean Fuels Commends USDA on Interim Rule for Climate Smart Ag

March 18, 2025

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(Clean Fuels Alliance America/WCAZ Radio) Today, Clean Fuels Alliance America submitted comments supporting USDA on its Technical Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks Interim Rule and incorporation of USDA FD-CIC. Clean Fuels 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.

“By establishing these technical guidelines, USDA is creating a novel market opportunity for U.S. farmers to distinguish their products and bring additional revenue to rural America,” Clean Fuels writes. “Clean Fuels appreciates the work that has gone into modeling the CSA practices for the biofuel feedstock crops included in the tool to date; however, we recommend adding canola (both spring and winter), carinata, domesticated pennycress, and camelina to USDA FD-CIC.”

Kurt Kovarik, Clean Fuels’ VP of Federal Affairs, added, “Biofuels are essential to farm security and prosperity. With the current economic challenges to farm security, farmers should have a strong financial stake in employing conservation practices and expanding oilseed crops that will unleash American biodiesel, renewable diesel, and sustainable aviation fuel growth.”

A copy of the comments is available at cleanfuels.org. READ MORE

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RFA to USDA: Follow the Science and Market to Maximize Benefits of Feedstock CSA Rules (Renewable Fuels Association)
ACE provides feedback on USDA’s biofuel feedstock guidelines and carbon intensity calculator (American Coalition for Ethanol/Ethanol Producer Magazine)
MN Bio-Fuels Submits Comments On Climate-Smart Ag Biofuel Feedstocks (Minnesota Bio-Fuels Association)
Climate-smart projects on life support as USDA withholds funding (Agri-Pulse)

Excerpt from Renewable Fuels Association: The Renewable Fuels Association today submitted formal comments to the U.S. Department of Agriculture’s Office of Energy and Environmental Policy regarding the interim rule on Technical Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks. RFA commended USDA for its efforts to support climate-smart agriculture (CSA) and emphasized the importance of policies that empower farmers while ensuring a robust and efficient renewable fuels market.

“USDA’s approach to climate-smart agriculture must ensure that farmers are incentivized to adopt sustainable practices while maintaining market flexibility,” said RFA President and CEO Geoff Cooper. “We support efforts to streamline verification processes, expand access to USDA’s Feedstock Carbon Intensity Calculator (FD-CIC), and enhance opportunities for farmers to participate in carbon reduction programs.”

In its comments, 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 advocated for a web-based version of the FD-CIC tool to improve accessibility and ease of use for producers and inclusion of Enhanced Efficiency Fertilizers (EEFs) in the final rule, recommending clear standards for verifying reduced nitrogen application rates that significantly lowers emissions from agriculture.

Additionally, RFA urged USDA to ensure that CSA initiatives do not impose unnecessary regulatory burdens that could discourage farmer participation. By implementing practical and science-based policies, USDA can enhance farm productivity, reduce emissions, and expand opportunities for biofuel producers to source sustainable feedstocks. READ MORE

Excerpt from American Coalition for Ethanol/Ethanol Producer Magazine: The American Coalition for Ethanol today provided feedback on the USDA’s technical guidelines for quantifying, reporting, and verifying greenhouse gas (GHG) emissions associated with agricultural production of biofuel feedstock and the Department’s Feedstock Carbon Intensity Calculator (FD-CIC), welcoming that they overall sufficiently inform farmers how individual conservation practices can reduce the carbon intensity (CI) of their crops.

ACE CEO Brian Jennings commended USDA for providing farmers a practical, science-based pathway to lower their CI scores and create new revenue opportunities. “USDA’s guidelines are a significant step forward in acknowledging the critical role farmers play in reducing greenhouse gas emissions,” Jennings said. “By avoiding the all-or-nothing bundling approach and allowing farmers to stack practices like reduced tillage and nutrient management, these guidelines create flexibility and real-world applicability for producers.”

ACE highlighted the importance of ensuring these 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. "Regulated fuel markets historically penalize ethanol based on many outdated assumptions around farm-level GHG emissions. It is long overdue for farmers to get credit for their conservation practices which, according to the latest science, reduce the overall carbon footprint of ethanol and other biofuels, and these USDA guidelines help unlock that value," Jennings added.

The organization also emphasized the need for continuous improvement of the FD-CIC tool. ACE recommended 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. Through these RCPP projects, ACE is working with farmers across 10 states and 167 counties to implement conservation practices on nearly 100,000 acres. The initiative will gather extensive soil and crop data to validate greenhouse gas benefits and inform updates to lifecycle models like GREET.

"We’re proud to lead this effort to collect real-world data on the benefits of low carbon feedstocks for biofuels,” Jennings said. “Our goal is to empower farmers and ethanol producers with the tools to capitalize on their low carbon practices through clean fuel markets and tax credits such as 45Z.”

ACE also urged USDA to coordinate closely with the Treasury Department to streamline verification and recordkeeping, leveraging USDA’s existing expertise and infrastructure. “Farmers have trusted USDA to administer conservation programs for decades. It makes sense to build on this system rather than creating new, costly requirements,” Jennings said.

Finally, ACE reiterated its support for a book-and-claim system that allows farmers to decouple carbon intensity attributes from physical grain, maximizing participation and efficiency — similar to successful approaches like the generation of renewable energy credits from low carbon electricity production and biomethane production. READ MORE

Excerpt from Minnesota Bio-Fuels Association: The Minnesota Bio-Fuels Association submitted comments to the USDA's interim rule on technical guidelines for Climate-Smart Agriculture (CSA) crops used as biofuel feedstocks.

In the comments, our executive director, Brian Werner, said the adoption of CSA practices by Minnesota farmers and the incorporation of Argonne National Laboratory's GREET model is crucial towards meeting the ethanol industry's goal of net-zero ethanol production by 2050.

"We appreciate that the Interim Rule utilizes the Argonne GREET model and the Feedstock Carbon Intensity Calculator (FD-CIC), provides additional flexibility for producers by unbundling CSA practices, and allows biofuel producers to track incoming reduced-CI crops and outgoing reduced-CI biofuel through a mass balance system," he said.

To successfully build on this initial framework, Werner said the use of Argonne's GREET and FD-CIC models should be maintained while a broader collection of CSA practices defined by the Natural Resources Conservation Services (NRCS) should be recognized and a book-and-claim approach to tracking the environmental attributes of CSA commodities should be incorporated.

"These improvements will help unlock additional value to farmers, ethanol producers, and rural communities in Minnesota," he said.

Read Werner's full comments below:

Dear Mr. Hohenstein:

Thank you for the opportunity to offer comments on USDA’s Interim Rule on Technical Guidelines for Climate-Smart Agriculture (CSA) Crops Used as Biofuel Feedstocks.

The Minnesota Bio-Fuels Association (MBA) is the largest non-profit renewable fuel trade association in the state of Minnesota, representing nine ethanol facilities that collectively produced nearly 800 million gallons of renewable fuel and, along with the entire statewide ethanol industry, contributed $2.1 billion to Minnesota’s economy in 20241.

Given that roughly half of the lifecycle greenhouse gas emissions associated with fuel ethanol are derived from the process of growing corn as a biofuel feedstock, we view the adoption of CSA practices by farmers in Minnesota, and their incorporation into lifecycle models like the Argonne National Laboratory’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model, as crucial to meeting our goal of achieving net-zero ethanol production by 2050.

In July 2024, MBA submitted public comments to USDA related to the quantification, reporting, and verification of CSA practices for agricultural commodities used as biofuel feedstocks. Furthermore, in December 2024, MBA submitted joint comments with the Minnesota Corn Growers Association to the House of Representative’s Ways and Means Committee on incorporating CSA practices in the modeling for the 45Z tax credit. Those letters are enclosed as their content broadly applies to this Interim Rule.

We appreciate that the Interim Rule utilizes the Argonne GREET model and the Feedstock Carbon Intensity Calculator (FD-CIC), provides additional flexibility for producers by unbundling CSA practices, and allows biofuel producers to track incoming reduced-CI crops and outgoing reduced-CI biofuel through a mass balance system.

To successfully build on this initial framework, we ask that you maintain the use of Argonne GREET and FD-CIC as approved lifecycle models, recognize a broader collection of CSA practices as defined by the Natural Resources Conservation Services (NRCS), and incorporate a book-and-claim approach to tracking the environmental attributes of CSA commodities. These improvements will help unlock additional value to farmers, ethanol producers, and rural communities in Minnesota.

Again, thank you for the opportunity to provide comments, and we look forward to working with you to enhance farm profitability and environmental outcomes.

Sincerely,

Brian Werner

We had previously submitted comments to the USDA in July last year on the quantification, reporting and verification of CSA practices for agricultural commodities used as biofuel feedstocks. You can read those comments here.

In December of 2024, we submitted joint-comments with the Minnesota Corn Growers Association to the House of Representatives's Ways and Means Committee on incorporating CSA practices. You can read those comments here. READ MORE