When determining how climate-smart farming practices affect greenhouse gas (GHG) emissions from cropland, policymakers should consider the merits of individual practices, not whether farmers adhere to a prescriptive, one-size-fits-all conservation program.
That was among the key messages delivered by Minnesota Corn Growers Association (MCGA) President Dana Allen-Tully to USDA in comments submitted last week.
USDA should develop tools that allow for the efficient calculation of a crop’s carbon intensity (CI) and accurately account for the impacts of individual climate-smart practices, Allen-Tully wrote. Furthermore, the agency should verify CI scores by using qualified third parties, Allen-Tully said.
Allen-Tully’s letter was in response to a USDA request for public input issued in June. The request sought input on procedures for quantifying GHG emissions reductions from climate-smart farming practices associated with the production of crops used as biofuel feedstocks. Read the comments here.
USDA’s request came several months after the U.S. Department of the Treasury announced its guidelines for the 40B Sustainable Aviation Fuel (SAF) Tax Credit. Passed as part of the 2022 Inflation Reduction Act, the credit is available to SAF produced in 2023 and 2024 with a CI reduction at least 50% below that of petroleum-based jet fuel. The public input request also comes prior to Treasury issuing a draft rule for the 45Z Clean Fuel Tax Credit, which is available beginning January 1, 2025.
For 40B, the Treasury Department will use a modified version of the Argonne National Laboratory Greenhouse Gases, Regulated Emissions, and Energy use in Transportation (GREET) model to determine the CI score of SAF. Unfortunately, the model doesn’t allow for nuance in calculating the impact of a broader array of climate-smart agriculture practices on a fuel’s CI score. It says that the only way for corn-based SAF to receive credit for the use of climate-smart agriculture practices is for farmers to adopt a specific set of practices—a bundle of cover crops, conservation tillage, and enhanced efficiency nitrogen fertilizer. Minnesota Corn Senior Public Policy Director Amanda Bilek detailed the impracticalities of that approach here.
In her letter, Allen-Tully thanked the federal government for including climate-smart agriculture practices in the 40B guidance but reiterated that a one-size-fits-all approach isn’t the best path. She said the approach would limit the ability of Minnesota corn farmers to participate in the SAF market and could hinder the ability of participation in other low-carbon fuel market opportunities. She also said the practices selected for 40B do not recognize the tremendous uncertainty that agricultural producers face in any given growing season.
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