USDA Gets Climate Smart Farming Feedback

Agriculture (USDA)Aviation Fuel/Sustainable Aviation Fuel (SAF)BioRefineries/Renewable Fuel Production Farming/Growing Federal Agency/Executive Branch Federal Regulation Feedstocks Field/Orchard/Plantation Crops/Residues Infrastructure Marketing/Market Forces and Sales Opinions Policy Sustainability Treasury Department

July 26, 2024

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by Cindy Zimmerman (Energy.AgWired.com) The U.S. Department of Agriculture received lots of input from biofuels groups this week on how to prove the impact of climate-smart farming practices on the greenhouse gas (GHG) net emissions estimates associated with the production of domestic agricultural commodities used as biofuel feedstocks, in response to a Federal Register request last month. The Request for Information is expected to inform the U.S. Treasury’s upcoming proposed rule for implementation of the Inflation Reduction Act’s clean fuel production credit, otherwise known as the “45Z credit.”

The Renewable Fuels Association urged the use of a “book-and-claim” accounting framework for tracking and transferring the greenhouse gas benefits of climate-smart agriculture (CSA) practices through the biofuels supply chain.

According to RFA’s comments, “Decoupling CSA attributes from the physical feedstock and allowing the renewable fuel 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 carbon intensity values. At the same time, book-and-claim accounting will allow the grain market to continue operating rationally and efficiently for all participants.”

The American Coalition for Ethanol (ACE) stressed the need to use the Department of Energy’s GREET model to quantify emissions and greenhouse gas (GHG) credits associated with the production of biofuel feedstocks.

ACE comments included progress that has been made to monetize CSA practices and ensure corn ethanol is part of the climate solution through its USDA-funded Regional Conservation Partnership Program (RCPP) projects, as well as soil organic carbon studies and a carbon intensity calculator tool.

Clean Fuels Alliance America submitted a highly detailed, technical response emphasizing “the need for immediate guidance and certainty before biodiesel, renewable diesel, and sustainable aviation fuel producers and their farmer partners transition to the credit in January.”

Clean Fuels recommends that USDA extend its analysis of climate smart agriculture practices to winter annual oilseeds and to all feedstocks that have approved pathways under the RFS. Clean Fuels also recommends that USDA consider other practices defined by USDA’s Natural Resources Conservation Service and create regional, practice-based carbon intensity credit tables using ERS’ Farm Resource Regions.

Finally, the Sustainable Aviation Fuel (SAF) Coalition, which represents all facets of the SAF value chain, urges USDA to consider four overarching principles during the rulemaking process:

• Ensure federal policies are science-based and data driven to unlock the full potential to develop and deploy SAF and build on Congressional directives provided by the 40B and 45Z tax credits;
• Ensure federal policies are technology and feedstock neutral with the aim of reducing carbon intensity in a realistic and verifiable way;
• Provide sufficient flexibility to accommodate new feedstocks and technologies;
• Ensure simple and clear administrative practices that are implementable and manageable. READ MORE

Related articles

USDA Publishes Request for Information on the Production of Biofuel Feedstocks Using Climate-Smart Practices (U.S. Department of Agriculture)
Clean Fuels Submits Detailed Technical Response to USDA’s Climate Smart Ag Request for Information (Clean Fuels Alliance America)
RFA to USDA: Embrace Book-and-Claim Accounting for Climate Smart Agriculture Feedstocks (Renewable Fuels Association)
ACE Urges USDA to Rely on its Established Expertise and GREET for Climate-Smart Agriculture Credits (American Coalition for Ethanol)
THE SAF COALITION SUBMITS COMMENTS IN RESPONSE TO USDA’S REQUEST FOR INPUT REGARDING GREENHOUSE GAS MITIGATION REQUIREMENTS FOR BIOFUEL FEEDSTOCKS (The SAF Coalition)
USDA faces flood of suggestions on climate-smart biofuels: Industry and environmental groups weigh in on how biofuel production can reduce greenhouse gas emissions. (E&E News Greenwire)
Numerous Biofuels Groups Call on USDA to Give Farmers Flexibility for Climate Smart Ag (American Ag Network)
MN BIO-FUELS URGES USDA TO PROVIDE FLEXIBILITY FOR FARMERS & BIOFUEL PRODUCERS ON CLIMATE SMART REQUIREMENTS (Minnesota Bio-Fuels Association)
IRFA urges USDA to decouple climate-smart agriculture carbon credits from physical grain (Iowa Renewable Fuels Association/Biobased Diesel Daily)
Business Aviation SAF Coalition Urges Consistency, Flexibility in USDA Rules for Biofuel Feedstocks (National Business Aviation Association)
Corn Growers seek tax credit standards (National Corn Growers Association/Ag Update)
Vilsack pledges quick work on ‘climate-smart’ biofuels -- The Agriculture secretary said his department aims to make biofuels a key part of the clean fuels tax credit taking effect next year. (E&E News Greenwire)

Excerpt from American Coalition for Ethanol: Today, American Coalition for Ethanol (ACE) CEO Brian Jennings submitted feedback to the U.S. Department of Agriculture (USDA) request for information on procedures for quantifying, reporting and verifying the effect of climate-smart farming practices on the greenhouse gas (GHG) emissions associated with U.S.-grown biofuel feedstock crops.

“We strongly support USDA requesting information which can lay the foundation for policies to bring economic benefits to rural and farm communities while also combating climate change, and we are grateful to Secretary Vilsack for his leadership in working to create opportunities for biofuel policies to reward biofuel producers and farmers for so-called climate-smart agriculture (CSA) practices,” Jennings stated in the comments.

ACE’s comments begin by documenting the progress ACE has been making to monetize CSA practices and ensure corn ethanol is part of the climate solution through its USDA-funded Regional Conservation Partnership Programs (RCPPs), followed by responding to five topical areas addressed in the request for information, with an emphasis on not re-inventing the wheel in developing procedures for quantifying GHG reductions from biofuel feedstocks.

Selected priorities from ACE’s overall comments are summarized below:

USDA and other federal agencies should rely on the Department of Energy’s Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) model to quantify emissions and greenhouse gas (GHG) credits associated with the production of agricultural commodities used as biofuel feedstocks. While no model can fully replicate real-world activities, GREET is considered the global gold standard and represents the best available science.
GHG credit values for climate-smart agriculture (CSA) practices should routinely be updated by incorporating the best available science and results from real-world activities such as the two USDA-Natural Resource Conservation Service (NRCS) Regional Conservation Partnership Program (RCPPs) currently being led by ACE. These projects are specifically designed to address the perceived need for more empirical data on the GHG benefits of CSA practices and help improve the accuracy of the GREET model.
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 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.

ACE additionally submitted soil organic carbon studies and a carbon intensity calculator tool to further expand upon and demonstrate points made in the comments. READ MORE

Excerpt from The SAF Coalition: The Sustainable Aviation Fuel (SAF) Coalition today (July 25, 2024) submitted comments in response to the U.S. Department of Agriculture’s (USDA) request for information on Docket No. USDA-2024-0003, Procedures for Quantification, Reporting, and Verification of Greenhouse Gas Emissions Associated with the Production of Domestic Agricultural Commodities Used as Biofuel.

In their comments, the SAF Coalition supports USDA’s objective of accelerating the development and deployment of sustainable aviation fuels in the U.S. To achieve this, the Coalition urges USDA to consider four overarching principles during the rulemaking process:

Ensure federal policies are science-based and data driven to unlock the full potential to develop and deploy SAF and build on Congressional directives provided by the 40B and 45Z tax credits;
Ensure federal policies are technology and feedstock neutral with the aim of reducing carbon intensity in a realistic and verifiable way;
Provide sufficient flexibility to accommodate new feedstocks and technologies;
Ensure simple and clear administrative practices that are implementable and manageable.

To read the SAF Coalition’s full submission to the USDA click here.

About the SAF Coalition
The Sustainable Aviation Fuel (SAF) Coalition represents the entirety of the SAF value chain. Through the coalition, our members are working together to rapidly invest in the SAF sector and advocate for the incentives and policies necessary to promote U.S. economic competitiveness in the emerging SAF marketplace. READ MORE

Excerpt from E&E News Greenwire: Groups representing renewable fuels urged the Department of Agriculture to take a broader view of farm practices that can cut emissions, while some environmental groups pushed for a turn away from crop-based fuels altogether.

The Agriculture Department received more than 240 responses to its formal request for information on climate-smart practices tied to biofuel production, for which the public comment period ended Thursday. They’ll help inform the implementation of a clean fuels tax credit next year, officials have said.

The input was sought as the Treasury Department finalizes details of the tax credit, in Section 45Z of the Internal Revenue Code, for fuels that reduce greenhouse gas emissions. The USDA has also been stepping up its promotion of climate-smart agriculture in the final months of the Biden administration, and the comments could feed into that effort. READ MORE

Excerpt from American Ag Network: You can read more about each groups submissions to USDA and corresponding statements at the links below:

Growth Energy: https://growthenergy.org/wp-content/uploads/2024/07/Growth-Energy-USDA-RFI-response-7-25-2024.pdf

RFA: https://ethanolrfa.org/media-and-news/category/news-releases/article/2024/07/rfa-to-usda-embrace-book-and-claim-accounting-for-climate-smart-agriculture-feedstocks

Clean Fuels: https://cleanfuels.org/clean-fuels-submits-detailed-technical-response-to-usdas-climate-smart-ag-request-for-information/

American Coalition for Ethanol: https://ethanol.org/ace-news/ace-urges-usda-to-rely-on-its-established-expertise-and-greet-for-climate-smart-agriculture-credits

SAF Coalition: https://thesafcoalition.com/news-post/the-saf-coalition-submits-comments-in-response-to-usdas-request-for-input-regarding-greenhouse-gas-mitigation-requirements-for-biofuel-feedstocks/ READ MORE

Excerpt from Minnesota Bio-Fuels Association: Last week, the Minnesota Bio-Fuels Association (MN Bio-Fuels) submitted comments urging the the U.S. Department of Agriculture (USDA) to provide additional flexibility for farmers and biofuel producers in the upcoming 45Z guidance by “unbundling” climate-smart agricultural (CSA) practice requirements and including a broader array of conservation practices and industrial decarbonization technologies into the models.

In the letter, MN Bio-Fuels also weighed in on the traceability of CSA feedstocks and recommended “decoupling” CSA attributes from physical grain in a “book-and-claim” accounting system. Without changes that reflect the realities of grain marketing, sales, purchases, and movements from feedstock growers to commercial grain aggregators, elevators, and ethanol plants, the 45Z tax credit will be limited in its applicability.

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“If implemented properly, these credits offer the opportunity to scale the production capacity of low-carbon, homegrown renewable fuels, support farmers and rural communities, and incentivize investment in additional technologies and conservation practices that will further reduce emissions and help the domestic renewable fuel industry achieve carbon neutrality by mid-century,” said Brian Werner, executive director of MN Bio-Fuels.

Among the comments submitted include the following:

USDA should allow Argonne GREET model to serve as a qualifying lifecycle model for 45Z
USDA should unbundle the CSA practice requirements and include the full list of Climate Smart Agriculture and Forestry Mitigation activities published by USDA’s Natural Resource Conservation Service (NRCS) as eligible for demonstrating GHG reductions. USDA should conduct further analysis to better quantify GHG emissions for biofuel feedstocks in the GREET model’s Feedstock Carbon Intensity Calculator to unlock a broader list of qualifying practices and promote farmer participation across diverse geographic conditions and soil types.
USDA should “decouple” CSA attributes from physical bushels of grain, as in a “book-and-claim” accounting system. A “book-and-claim” system would lower the cost of compliance and reduce GHG emissions associated with transporting grain.
When quantifying GHG emission outcomes related to both CSA and conventional farming practices, the USDA should rely on the predominant scientific consensus on the GHG emission benefits of biofuels and avoid incorporating discredited, outdated or flawed research on land use changes.
USDA should recognize that corn is a primary feedstock crop for biofuel production and include it in USDA’s quantification analysis for GHG emissions associated with CSA practices.

Additionally, Werner said the 45Z tax credit guidance should be done in a timely manner or the congressional intent of the credit to increase low-carbon domestic renewable fuels and further decarbonize existing biofuel production would be undermined.

“We understand the importance of due diligence when it comes to the quantification, reporting, and verification of CSA agricultural practices and their impact on biofuel CI scores. However, ethanol producers cannot make forward-looking business decisions when facing regulatory uncertainty,” he said.

Read our full comments here. READ MORE

Excerpt from National Business Aviation Association: In a recent letter to the USDA’s Office of Energy and Environmental Policy, the Business Aviation Coalition for Sustainable Aviation Fuel urged the agency to largely follow the approach used with the Renewable Fuel Standard and other existing biofuel audit programs as it develops its rule detailing how companies should quantify, report and verify greenhouse gas emissions associated with SAF production.

“The BizAv SAF Coalition encourages the department to enable as much adaptability and flexibility in its framework as is practicable and encourages the USDA to embrace a performance-based approach in its analysis, focusing on outcomes rather than prescriptive and exclusionary lists of acceptable feedstocks,” the coalition said in its letter.

Without the right approach and flexibility with the greenhouse gas rules, the U.S. will not be able to meet the SAF Grand Challenge goals, the coalition said. “It is likely that we will only achieve those goals through the existing scale and capabilities of U.S. agriculture through access to sustainable crop-based feedstocks,” the coalition said.

When finalized, the greenhouse gas rules will impact how SAF producers can take advantage of the Clean Fuel Production Credit enacted in the Inflation Reduction Act.

That credit gives SAF producers up to $1.75 per gallon if they are creating the fuel using feedstocks that generate low or zero greenhouse gas emissions.

Sustainable aviation fuel is a key part in business aviation’s ambitious plan to reach net-zero carbon emissions by 2050. Read the coalition’s letter to USDA.

About the Business Aviation Coalition for Sustainable Aviation Fuel

The Business Aviation Coalition for Sustainable Aviation Fuel is a coalition of leading international aviation groups. Members include the Commercial Aviation Alternative Fuels Initiative (CAAFI), Canadian Business Aviation Association (CBAA), European Business Aviation Association (EBAA), the General Aviation Manufacturers Association (GAMA), Vertical Aircraft International (VAI), International Business Aviation Council (IBAC), the National Air Transportation Association (NATA) and the National Business Aviation Association (NBAA). The SAF Coalition’s work is supported by a Steering Committee that includes dozens of aviation businesses that represent all points along the SAF supply chain.

More information about SAF and the Coalition is available at futureofsustainablefuel.com.

About NBAA

Founded in 1947 and based in Washington, DC, the National Business Aviation Association (NBAA) is the leading organization for companies that rely on general aviation aircraft to help make their businesses more efficient, productive and successful. The association represents more than 10,000 company and professional members and provides more than 100 products and services to the business aviation community, including the NBAA Business Aviation Convention & Exhibition (NBAA-BACE), the world’s largest civil aviation trade show. Learn more about NBAA at nbaa.org.

Members of the media may receive NBAA Press Releases immediately via email. To subscribe to the NBAA Press Release email list, submit the online form. READ MORE

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Treasury Department Transportation Fuels Policy tax policy Sustainability Renewable Diesel/Green Diesel/HVO/Paraffinic Diesel Regulations-Federal public comments monitoring/measuring reporting verifiction (MRV) market forces land use change Jetfuel (Sustainable Aviation Fuel (SAF)) GREET Greenhouse Gases Regulated Emissions and Energy Use in Transportation Model GHG (Greenhouse Gas Emissions) ethanol/bioethanol environmental policy Department of Energy (DOE) Department of Agriculture (USDA) corn/maize corn ethanol climate smart/conservation agriculture Carbon Intensity (CI)/Carbon Footprint book-and-claim BioRefineries/Renewable Fuel Production Biofuel biodiesel Aviation Fuel/Sustainable Aviation Fuel (SAF) Agricultural Policy 45Z Clean Fuel Production Tax Credit 40B Sustainable Aviation Fuel Tax Credit

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