RFS tells USDA climate-smart agriculture is a unique opportunity to decarbonize biofuels

October 1, 2024 |

In Washington, testimony at a USDA public consultation on climate-smart agriculture (CSA) and biofuel feedstocks, RFA President and CEO Geoff Cooper endorsed the “extraordinary opportunity” for CSA to help decarbonize renewable fuels and urged federal agencies, including the Treasury Department, to embrace book-and-claim supply chain management approaches.

“If 45Z and other regulations require that physical commodities grown using CSA practices be rigidly tracked through the supply chain and delivered to biofuel production facilities, this could severely limit the adoption of such practices, and it could cause significant distortions in grain flows and pricing,” he said. “The existing agricultural supply chain is massive and complex, yet highly efficient. It encompasses hundreds of thousands of participants, including farmers, grain elevators, processors, livestock feeders, shippers, and others. If the potential benefits of CSA practices are to be fully realized in the 45Z program, innovative supply chain management solutions will be needed.”

Cooper continued, “Decoupling CSA attributes from the physical feedstock and allowing the biofuel 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 CI values. At the same time, book-and-claim accounting will allow the grain market to continue operating rationally and efficiently for all participants.”

Additionally, RFA believes that CSA practices should not be bundled for the purposes of CI scoring. Cooper strongly endorsed the use of the Argonne National Laboratory’s GREET model for carbon intensity scoring of various feedstock and biofuel pathways, but noted that ‘proxy’ factors should be used—at least initially—for the GHG reductions associated with individual CSA practices. “This approach would avoid issues related to significant geographical variation in CSA emissions impacts and challenges associated with accurate measurement of GHG impacts at high spatial resolutions,” Cooper said.

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Category: Policy

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