Yesterday, American Coalition for Ethanol (ACE) CEO Brian Jennings sent a letter to members of the Sustainable Aviation Fuels (SAF) Interagency Working Group (IWG) regarding the Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) Model for SAF Lifecycle Greenhouse Gas (GHG) Emissions under Section 40B of the Inflation Reduction Act. Accompanying ACE’s letter was an analysis prepared by Ron Alverson of the ACE board of directors comparing modeled estimates of land use change (LUC) to what has occurred in the real world.
ACE’s letter was sent to United States Department of Agriculture Secretary Tom Vilsack, Department of Energy Secretary Jennifer Granholm, Environmental Protection Agency Administrator Michael Regan, Federal Aviation Administration Administrator Michael Whitaker, and Department of Treasury Secretary Janet Yellen. These officials compromise the SAF Interagency Working Group.
With the Interagency Working Group’s stated deadline of March 1st for the modified GREET model for fast approaching, ACE’s letter cautions President Biden’s pledge that farmers would be providing 95 percent of SAF in the next 20 years could go unfulfilled if 40B GREET artificially inflates LUC and fails to properly value climate-smart agriculture practices.
“As the much-anticipated deadline nears for 40B GREET for SAF, I stress the importance of GHG credits for climate-smart agriculture practices and a final methodology based on real-world observations of land use change instead of inflated assumptions generated from unreliable economic models,” Jennings wrote.
“ACE believes carbon credits for climate-smart agriculture are essential because they incentivize on-farm practices which can reduce or even prevent land use change-related emissions, Jennings states in the letter. The ACE letter also references a recent United States Department of Agriculture (USDA) decision to provide $25 million for a Regional Conservation Partnership Program (RCPP) led by ACE. The funding will help farmers adopt reduced tillage, nutrient management and cover crops on nearly 100,000 acres across 167 counties surrounding 13 ethanol facilities partnering with ACE in a 10-state region of Illinois, Indiana, Iowa, Kansas, Minnesota, Missouri, Nebraska, Ohio, South Dakota and Wisconsin. The sites were strategically chosen to provide statistically significant data regarding the GHG effect of conservation practices in different soil types and climates.
“Our USDA-RCPP project can help members of the Interagency Working Group minimize or even control land use change if you ensure GREET is used to provide carbon credits for climate-smart ag practices, not only for 40B, but also for the 45Z clean fuel production credit.”