In response to the USDA’s Request for Information on Procedures for Quantification, Reporting, and Verification of Greenhouse Gas Emissions Associated with the Production of Domestic Agricultural Commodities Used as Biofuel Feedstocks, Clean Fuels Alliance America proposed adopting regional, practice-based Carbon Intensity (CI) credits for various climate-smart practices to reduce the CI of agricultural feedstocks.
In its response, Clean Fuels recommended that the USDA:
- Include all feedstocks approved or soon to be approved under the RFS, including winter oilseeds, to have the option to be credited for being grown using climate smart practices.
- Credit roughly a dozen NRCS-defined conservation practice standards immediately but set up a process by which to expand the list of practices and add flexibility to avoid overly stringent rules.
- Create regional, practice-based CI credit tables using Farm Resource Regions.
- Develop credits considering modeled environmental outcomes, barriers to practice adoption, risk and cost.
- Take composite scores for the above factors and normalize credit across regions to ensure equitable treatment, maximizing crediting for the most certain and beneficial outcomes.
- Ensure credits are assigned annually and are additive with no bundling.
- Use mass balance chains-of-custody to trace lower-CI feedstock through the supply chain.
- Employ CPA and ISO accredited verifiers to verify and audit practices on a simple and typical risk management approach with a presumption of compliance.
Clean Fuels’ comments sought to maximize the opportunities available to farmers to improve the CI of their feedstocks, while setting up a simplified system for crediting that would streamline processes and develop alongside scientific advances in agricultural GHG emissions and carbon sequestration quantification.