ICGA Praises USDA Rule, Continues Advocating for Book & Claim Approach


By Lindsay Croke • June 26, 2026

BLOOMINGTON, Ill. – The IL Corn Growers Association (ICGA) and our farmer leaders feel overwhelmingly positive after their review of the USDA Regenerative Feedstock Rule today. We thank the administration for their obvious consideration of the comments provided during the rulemaking process and for a rule that reflects most of the realities of farming today. 

 

“This rule is a clear framework that Illinois corn farmers have been waiting for, containing the important information that is critical for us to be empowered to make informed management and investment decisions. We are happy to have certainty as we plan for the 2027 crop year,” said Mark Bunselmeyer, ICGA President and Maroa, IL farmer. 

 

There are several positive and important elements to the rule released today. 

  • Field-level scoring is important, as farmers manage their fields independently and deserve to be recognized for the management decisions and conservation practices implemented on each acre. 
  • Evaluating nitrogen use using NUE – nitrogen use efficiency – is a valuable change that rewards farmers for practices that lower carbon intensity per bushel. 
  • Allowing grazing of cover crops and inclusion of manure are important elements that allow the integration of livestock and grain farming to continue and recognize the importance of the cycle. 
  • Evaluating soil health practices will transition from a focus on soil erosion to a focus on soil carbon loss. The change provides more flexibility for farmers who are lowering carbon intensity, while making decisions that improve efficiency and resilience. 

 

Notably, the only concerning part of the rule is the mass-balance approach that ICGA believes may limit farmer participation in 45Z and leave significant value on the table for farmers. USDA acknowledges a willingness to explore a transition to book & claim processes in the future. 

 

“Mass balance may provide a practical implementation pathway, but it does limit farmer participation to those farming in certain regions,” said Bunselmeyer. “Many farmers who adopt practices that lower carbon intensity might not live near an ethanol plant. This process also leaves out livestock farmers who contribute emissions reductions that are within the scope of these goals. A book & claim approach is the right approach if our goal is to allow as many farmers as possible to participate.” 

 

Two steps in this rulemaking process remain: the USDA guidance must be considered by the U.S. Department of Energy and the U.S. Department of the Treasury. ICGA encourages all parties to move forward as quickly as possible, thinking all the while of the goal of empowering all corn farmers to adopt new conservation practices that come with new market opportunities, regardless of geography, marketing channel, or production system. The flexibility provided in the USDA’s rule today is an excellent first step to accomplishing this goal. 

 

 

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About the IL Corn Growers Association 

IL Corn Growers Association is a state-based organization that represents the interests of corn farmers in Illinois, maintaining a high profile on issues in Washington, DC, and Springfield, IL. Through grassroots advocacy, ICGA creates a future for Illinois farmers in which they can operate freely, responsibly, and successfully. In order to fulfill this mission, the organization conducts governmental affairs activities at all levels, market development projects, and educational and member service programs. For further information regarding their work and involvement, visit their website www.ilcorn.org.


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