In testimony today at a USDA public consultation on climate-smart agriculture (CSA) and biofuel feedstocks, RFA President and CEO Geoff Cooper endorsed the “extraordinary opportunity” for CSA to help decarbonize renewable fuels and urged federal agencies, including the Treasury Department, to embrace book-and-claim supply chain management approaches.
“If 45Z and other regulations require that physical commodities grown using CSA practices be rigidly tracked through the supply chain and delivered to biofuel production facilities, this could severely limit the adoption of such practices, and it could cause significant distortions in grain flows and pricing,” he said. “The existing agricultural supply chain is massive and complex, yet highly efficient. It encompasses hundreds of thousands of participants, including farmers, grain elevators, processors, livestock feeders, shippers, and others. If the potential benefits of CSA practices are to be fully realized in the 45Z program, innovative supply chain management solutions will be needed.”
Cooper continued, “Decoupling CSA attributes from the physical feedstock and allowing the biofuel producer to use book-and-claim accounting would encourage widespread adoption of CSA practices by growers and broad incorporation of CSA emissions improvements into biofuel lifecycle CI values. At the same time, book-and-claim accounting will allow the grain market to continue operating rationally and efficiently for all participants.”
Source : ethanolrfa.org