"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," they explained.
The American Coalition for Ethanol pointed out the effectiveness of the Department of Energy’s GREET model in calculating emissions and highlighted their efforts in enhancing the economic viability of CSA practices.
Clean Fuels Alliance America emphasized the urgency of clear guidelines for transitioning to the new credit system, suggesting that the USDA’s analysis should be extended to additional feedstocks and that region-specific carbon intensity credits be established.
Lastly, the Sustainable Aviation Fuel Coalition pressed for federal policies that are scientifically grounded and adaptable to new technologies and feedstocks, ensuring straightforward and manageable administrative practices.
These contributions are crucial as they will inform the USDA’s strategies in fostering a more sustainable and environmentally friendly biofuel sector.