Today, American Coalition for Ethanol (ACE) CEO Brian Jennings submitted feedback to the U.S. Department of Agriculture (USDA) request for information on procedures for quantifying, reporting and verifying the effect of climate-smart farming practices on the greenhouse gas (GHG) emissions associated with U.S.-grown biofuel feedstock crops.
“We strongly support USDA requesting information which can lay the foundation for policies to bring economic benefits to rural and farm communities while also combating climate change, and we are grateful to Secretary Vilsack for his leadership in working to create opportunities for biofuel policies to reward biofuel producers and farmers for so-called climate-smart agriculture (CSA) practices,” Jennings stated in the comments.
ACE’s comments begin by documenting the progress ACE has been making to monetize CSA practices and ensure corn ethanol is part of the climate solution through its USDA-funded Regional Conservation Partnership Programs (RCPPs), followed by responding to five topical areas addressed in the request for information, with an emphasis on not re-inventing the wheel in developing procedures for quantifying GHG reductions from biofuel feedstocks.
Selected priorities from ACE’s overall comments are summarized below:
- USDA and other federal agencies should rely on the Department of Energy’s Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) model to quantify emissions and greenhouse gas (GHG) credits associated with the production of agricultural commodities used as biofuel feedstocks. While no model can fully replicate real-world activities, GREET is considered the global gold standard and represents the best available science.
- GHG credit values for climate-smart agriculture (CSA) practices should routinely be updated by incorporating the best available science and results from real-world activities such as the two USDA-Natural Resource Conservation Service (NRCS) Regional Conservation Partnership Program (RCPPs) currently being led by ACE. These projects are specifically designed to address the perceived need for more empirical data on the GHG benefits of CSA practices and help improve the accuracy of the GREET model.
- USDA has a long track record of stewarding federal taxpayer funds for commodity and conservation programs, ensuring that participating farmers meet necessary requirements to receive federal funds. If existing USDA protocols are sufficient for verifying distribution of billions of taxpayer dollars for commodity and conservation programs, USDA protocols are equally sufficient for verifying the same practices for federal tax incentives such as 45Z. The Treasury Department should rely on existing USDA assets in the reporting and verification for the 45Z tax credit, and we encourage USDA to directly engage Treasury with respect to its expertise and experience in this area.
ACE additionally submitted soil organic carbon studies and a carbon intensity calculator tool to further expand upon and demonstrate points made in the comments.