By David Fairfield, Senior Vice President, Feed
NGFA submitted recommendations on July 25 to the U.S. Department of Agriculture (USDA) in response to its request for information concerning the effect of “climate-smart agriculture” practices on greenhouse gas (GHG) emission estimates associated with the production of agricultural commodities used as biofuel feedstocks.
When announcing the request for information on June 27, USDA said feedback received would be considered as the Department works to establish voluntary standards for biofuel feedstocks grown with practices that mitigate GHG emissions and/or sequester soil carbon. These standards, authorized by the Food, Conservation, and Energy Act of 2008, would be available for consideration in clean transportation fuel policies, including the 45Z tax credit currently under development, to incentivize climate-smart biofuel feedstock crops.
In its comments, NGFA indicated support for USDA standards that encourage the voluntary adoption of climate-smart agricultural practices on working lands and that facilitate additional revenue opportunities for farmers and agribusinesses.
“USDA voluntary standards for quantifying, reporting, and verifying GHG outcomes would be valuable to entities that establish and administer international, national, or state clean transportation fuel policies, as well as voluntary private-sector initiatives that promote adoption of climate-smart agricultural practices,” NGFA noted. “Further, U.S. leadership in global sustainable transportation fuel markets is crucial so that related standards and policies provide meaningful benefits and support the economic viability of U.S. agriculture.”
In its comments, NGFA answered several questions posed by USDA. Among the recommendations made by NGFA were:
- USDA’s consideration of climate-smart practices should be broad and appropriately incentivize all types of science-based carbon reductions.
- USDA standards need to avoid the arbitrary bundling of climate-smart practices when quantifying GHG emission outcomes because such bundling is counterproductive to the adoption of practices.
- Farmer data collection requirements should be limited to only the information required to verify the practice happened and support modeling input.
- USDA standards should allow farmers to market climate smart commodities to all entities within the value chain.
- Traceability standards for commodities need to provide for a mass balance system because the vast majority of commodities at both farms and commercial value-chain entities is handled on a commingled basis due to physical infrastructures and distribution methods.