USDA releases interim rule on CSA practices for corn, soy and sorghum feedstocks

January 16, 2025

BY Erin Krueger

The USDA on Jan. 15 published an interim rule that establishes guidelines for quantifying, reporting and verifying greenhouse gas (GHG) emissions associated with the production of biofuel feedstock commodity crops grown in the U.S. The interim rule is subject to a 60-day comment period and will be finalized by the incoming Trump administration. 

The guidelines contained in the interim rule aim to facilitate the recognition of climate-smart agriculture (CSA) within clean transportation fuel programs, creating new market opportunities for biofuel feedstock producers while enhancing climate benefits. 

Development of the interim rule follows a request for information (RFI) launched by USDA In June 2024 seeking public comments on procedures for quantifying, reporting and verifying the effect of CSA practices on the GHG emissions associated with U.S.-grown biofuel feedstocks. The agency gathered more than 250 comments as part of that effort and in December 2024 delivered the resulting interim rule to the White House Office of Management and Budget for interagency review. 

The interim rule released Jan. 15 addresses three feedstock crops, including corn, sorghum and soy. It covers CSA practices that could reduce GHG emissions or sequester carbon, including reduced till and no-till; cover cropping; and nutrient management practices, such as the use of nitrification inhibitors. Importantly, the interim rule allows for adoption of CSA practices both individually or in combination. This means that participating farmers would have the flexibility to adopt the CSA practices that make sense for their operation, while still being able to produce feedstocks with reduced carbon intensities under the rule. 

According to USDA, the rulemaking establishes standards that can be used to quantify, track and report the impacts of these CSA practices. It also establishes voluntary guidelines that may inform the development of requirements for other programs that incentivize low-carbon biofuels. 

The interim rule includes guidelines on biofuel feedstock crops and entities in the biofuel supply chain; quantification of farm-level crop-specific carbon intensity (CI), chain of custody standards for entities in the biofuel supply chain, including traceability and recordkeeping standards; auditing and verification requirements; and climate-smart agriculture practice standards for the biofuel feedstock crops included under the rule. 

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Along with the interim rule, the USDA has also published a beta version of the USDA Feedstock Carbon Intensity Calculator (USDA FD-CIC), which aims to facilitate the quantification of farm-level crop-specific CI. The agency said it will complete a peer-review process to finalize the methodology and resulting carbon intensities included in the calculator. It will also gather public feedback before establishing a final version. 

The Renewable Fuels Association is welcoming the release of the interim rule. “America’s ethanol producers applaud USDA for publishing these important guidelines, and we sincerely thank Secretary Tom Vilsack for his extraordinary vision and leadership,” said Geoff Cooper, president and CEO of the RFA. “The entire team at USDA deserves much credit for the enormous effort and technical work that went into this process. These new guidelines begin to open the door to new value-added opportunities for farmers and renewable fuel producers.”

Cooper noted that emissions related to feedstock production account for more than half of ethanol’s carbon footprint; and to date, policies and regulations have not allowed farmers and ethanol producers to embrace more efficient, lower-carbon feedstock production practices as a pathway for reducing the carbon intensity of renewable fuels and breaking into new markets like sustainable aviation fuel. 

“Today’s USDA guidelines finally create a much-needed structure for properly assessing, valuing, and integrating the carbon reduction benefits of certain farming practices into lifecycle analysis,” Cooper continued. “We thank USDA for developing this initial framework that could ultimately allow farmers to actively participate in carbon markets, bringing new revenue streams and unprecedented value creation to rural communities.”

Growth Energy is also applauding the rulemaking. “This new CSA rule hits all the right notes and will help set American ethanol up to deliver a more affordable, low carbon, homegrown energy solution to American drivers. Today’s announcement also sets the stage for new economic opportunities in rural America, as it means farmers could get credit for their work to grow more crops using fewer resources,” said Emily Skor, CEO of Growth Energy. “We commend USDA and specifically Secretary Vilsack for building this rule and the agency’s new feedstock carbon intensity calculator in a way that will maximize economic benefits to farmers, putting them in a position to help America’s ethanol industry unleash American energy dominance.   

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“We urge the incoming administration to use this new proposal to provide farmers with a new pathway to drive farm income,” Skor continued. “A strong rural economy depends on a strong American ethanol industry, and vice versa. This rule offers a path forward for all of these stakeholders, and we look forward to working with the Trump administration to make regenerative agriculture a part of their successful efforts to revitalize rural America."

The American Coalition for Ethanol said the guidelines create meaningful opportunities for farmers and biofuel producers.  "We commend Secretary Vilsack and the Office of Chief Economist for taking critical steps to support farmers and biofuel producers in achieving verifiable carbon reductions through climate-smart practices,” said Brian Jennings, CEO of ACE. “We’re pleased to see greater flexibility for farmers, including the stacking of practices and a departure from the all-or-none bundled approach previously required under 40B. ACE looks forward to continuing our collaboration with USDA and the Treasury Department as it finalizes the 45Z Clean Fuel Production tax credit under the incoming administration, ensuring these efforts are accurately recognized and rewarded.

“The ACE-led USDA-Natural Resource Conservation Service (NRCS) Regional Conservation Partnership Programs (RCPPs) are designed to help improve the accuracy of the GREET model, and we look forward to partnering with Argonne scientists and USDA, particularly in how climate-smart agriculture crops are calculated under GREET and USDA’s new feedstock carbon intensity tool, to ensure farmers and ethanol producers can maximize on 45Z and future programs,” Jennings added. 

Clean Fuels Alliance America also commended the release of the interim rule. “USDA’s rule could enable American farmers and biofuel producers to calculate the carbon benefits of conservation practices,” said Kurt Kovarik, vice president of federal affairs at Clean Fuels. “We look forward to continued work with USDA, Treasury and the Department of Energy to ensure that farmers can financially benefit by adopting these practices and cooperate with clean fuel producers to increase the value of domestically produced clean fuels.”

The Iowa Renewable Fuels Association said the rule could help boost farm income and unlock new markets for biofuel producers. “The interim final rule released today by USDA could be a major step forward in unlocking the potential to reduce farm-level carbon and thereby reduce the carbon intensity for biofuels,” said Monte Shaw, executive director of the IRFA. “There are several improvements from the previous CSA program, including more practices and flexibility. Just as importantly, a quick review of the new carbon calculator seems to show farmers would be given full credit for CSA practices instead of an artificially reduced number as in the previous iteration. Secretary Vilsack has once again pushed the envelope forward based on sound science and data. IRFA looks forward to digging into the proposal and providing feedback to help make it ever better.”

“It is important to note that, if finalized, this CSA program could be not only adopted into federal policies like the 45Z Clean Fuel Production Tax Credit, but also into state clean fuel policies and international carbon programs as well,” Shaw continued. “With the reliance on the best data and science and the imprint of the USDA, the onus going forward should not be on why a carbon program should adopt CSA, but rather on how they could possibly justify not recognizing CSA.”

The interim rule is scheduled to be published in the Federal Register on Jan. 17, officially opening a 60-day public comment period. Additional information, including a copy of the interim rule and a link to access the USDA Feedstock Carbon Intensity Calculator, is available on the agency’s website.

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