IRFA urges USDA to decouple climate-smart agriculture carbon credits from physical grain

The Iowa Renewable Fuels Association submitted comments to USDA July 25 in response to a request for information on potential future rulemakings to facilitate climate-smart agriculture (CSA) practices.

IRFA urged that any rulemaking should decouple CSA carbon credits from physical bushels of grain in order to unleash the full potential of clean fuels in current and future markets.

“Requiring full supply-chain traceability for every bushel produced using CSA practices is impractical, costly and counterproductive to the goals of 45Z (the new clean fuel production tax credit),” IRFA stated in the comments.

“Decoupling the CSA carbon credits from the physical bushel through a book-and-claim system unlocks numerous benefits for both farmers and clean-fuel producers—and maximizes the carbon reductions made possible by 45Z tax credits,” the organization continued.

IRFA also agreed with other groups in asking the USDA to recognize several more CSA farming practices, less “one size fits all” mandatory bundling and ensuring farmers receive full credit for the carbon reduction of each practice.

“While we recognize that there is uncertainty in some CSA modeling, we urge the department to adopt the best available science and to update any regulations as better science becomes available in a continuous cycle of improvement,” the organization stated in its comments.

“The only thing that is certain is that if adopting a CSA practice does not provide a return on investment to the farmer, adoption will be much slower than if it did,” IRFA said.

A copy of the comments can be found here.

IRFA represents the state’s liquid renewable fuels industry and works to foster its growth.

Iowa is the nation’s leader in renewable fuels production with 42 ethanol refineries capable of producing 4.7 billion gallons annually—including 34 million gallons of annual cellulosic ethanol production capacity—and 10 biodiesel facilities with the capacity to produce 416 million gallons annually.