USDA Highlights the Role Farmers Play in Climate-Smart Policies with New Guidance

IL Corn Growers Association (ICGA) welcomes the U.S. Department of Agriculture’s (USDA) release of an interim ruleon Technical Guidelines for Climate-Smart Agriculture (CSA) Crops Used as Biofuel Feedstocks.

The interim rule includes long-awaited guidelines from USDA on how fuel producers can assess, value, and integrate the carbon reduction benefits of certain farming practices into the lifecycle analysis of the fuel they produce. Once finalized, the USDA guidelines could help the U.S. Treasury Department adopt these practices in clean fuel regulations and tax credit programs, like the 45Z clean fuel production credit.

“We have been waiting a long time for more information on how farmers can participate in a new sustainable aviation fuel marketplace,” said Garrett Hawkins, President of ICGA and farmer from Waterloo, IL. “The guidance released today is an important acknowledgment of the role farmers can play in decarbonizing the U.S. transportation sector.”

ICGA is encouraged that important updates were incorporated into this interim rule, including the decoupling of practices – an element that concerned many farmers who called bundling practices unworkable – and the recognition of additional practices and additional crops. The USDA added flexibility in their guidance which will be valuable for farmers seeking to participate.

However, ICGA is concerned that today’s rule doesn’t outline systems that will allow all farmers to participate.

“The piece of today’s guidance that feels the most challenging to accept is the mass balance approach to tracking the flow of low-carbon corn. We will suggest alternate systems to track this in our comments, as we believe the mass balance system prevents all farmers from participating in this new market opportunity,” said Hawkins.

ICGA predicts that the mass balance approach will extend this new market opportunity only to farmers who sell to an ethanol plant. Additionally, ICGA fears that mass balance tracking will encourage vertical integration, with ethanol plants driven to tell farmers what conservation practices to use to achieve the desired low carbon feedstock score.

“ICGA’s mission is to create a future for Illinois farmers in which they can operate freely, responsibly, and successfully. We are concerned that the interim rule’s record-keeping proposal could jeopardize our member’s opportunity to ‘operate freely’ in the future,” Hawkins said.

The USDA’s Interim Rule on Technical Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks will be published in the Federal Register on January 16, which will begin a 60-day comment period for the public to weigh in on the proposed rule.