Growth Energy, the nation’s largest biofuel trade association, responded this week to a request for information (RFI) from the U.S. Department of Agriculture (USDA) about how the agency should account for the impact climate smart agriculture (CSA) practices have on lowering the carbon intensity of bioethanol production.
“While our biorefineries are focused on a range of innovative technologies to reduce carbon intensity at the plant, agriculture represents more than 50 percent of bioethanol’s carbon intensity (CI) score,” said Growth Energy Senior Vice President of Regulatory Affairs Chris Bliley in the comment. “It is therefore essential to recognize the full range of climate-smart agriculture (CSA) innovation taking place on the farm – including farm applications such as cover crops, reduced tillage, manure application, crop nutrient management, and other ag innovations – that can reduce the lifecycle CI score of bioethanol.”
As it has in previous comments to other agencies, Growth Energy emphasized the importance of giving farmers flexibility that allows them to get credit for each and every CSA practice they deploy. Specifically, Growth Energy reiterated how the U.S. Treasury’s guidance on the 40B sustainable aviation fuel tax credit was too restrictive, and would steer farmers away from climate smart ag by requiring them to use three specific practices before they could qualify for the credit at all.
“Using this restrictive all-or-nothing approach to recognizing the value of CSA practices will limit innovation and make farmers, blenders, and producers less – not more – likely to invest in emissions-reducing technologies,” Bliley said. “Numerous factors including local weather patterns, soil type and health, growing seasons, and equipment costs determine which CSA practices are feasible for a particular farm—and farmers should have the flexibility to implement the CSA practices that are most effective for their unique circumstances and allow producers the ability to maximize carbon reductions based on their specific farm.”
Read Growth Energy’s full comment here. Learn more about the importance of carbon reduction tax incentives to the future of biofuels here.
