Clean Fuels emphasizes need for immediate 45Z guidance in climate smart ag comments filed with USDA

July 25, 2024

BY Clean Fuels Alliance America

Today, Clean Fuels Alliance America submitted a highly detailed, technical response to USDA’s Request for Information on climate smart agriculture practices for biofuel feedstocks. While USDA’s analysis of climate smart agriculture will have impacts beyond the §45Z Clean Fuel Production Credit, Clean Fuels emphasized the need for immediate guidance and certainty before biodiesel, renewable diesel, and sustainable aviation fuel producers and their farmer partners transition to the credit in January.

“We appreciate that Secretary Vilsack understands the importance of having guidance for the §45Z Clean Fuel Production credit well in advance of January 1, 2025, so farmers, producers and fuel customers have the certainty to continue to produce and use low-carbon biomass-based diesel,” Clean Fuels writes in the submission. “To set a practice-based crediting program up for success, farmers must know the credit value as soon as possible to help them assess what land management practices to employ as they make both planting and harvesting decisions ahead of the season.”

Clean Fuels recommends that USDA extend its analysis of climate smart agriculture practices to winter annual oilseeds and to all feedstocks that have approved pathways under the RFS. Clean Fuels also recommends that USDA consider other practices defined by USDA’s Natural Resources Conservation Service and create regional, practice-based carbon intensity credit tables using ERS’ Farm Resource Regions.

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Kurt Kovarik, vice president of federal affairs for Clean Fuels, added, “U.S. biodiesel, renewable diesel, and sustainable aviation fuel producers are already annually producing nearly 5 billion gallons of advanced biofuels that could qualify for the credit. They need policy certainty immediately to make the transition to the producer credit and maintain growth in the industry. Moreover, farmers producing biofuel feedstocks need to make decisions now to use climate smart farm practices next year and document the added value for the credit.”

 

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