Under the Growing Climate Solutions Act, USDA was tasked with creating a technical assistance provider and third-party verifier program to support and facilitate farmer, rancher and private forest landowner participation in voluntary carbon markets. As part of this directive, USDA published a Request for Information including how to define criteria and evaluate voluntary carbon market protocols. Many of these protocol systems deal with additionality which can constrain farmers’ ability to benefit from newly created systems for crediting climate smart agricultural practices in carbon intensity-based clean fuel programs. As a result, Clean Fuels Alliance America submitted this letter highlighting that voluntary carbon markets supported by the USDA should be complementary to clean fuels markets and not overly constrain farmer participation in both voluntary carbon and clean fuels markets.