BLOOMINGTON - IL Corn Growers Association (ICGA) welcomes the U.S. Department of Agriculture’s (USDA)
release of an interim rule on Technical Guidelines for Climate-Smart Agriculture (CSA) Crops Used as Biofuel Feedstocks.
The interim rule includes long-awaited guidelines from USDA on how fuel producers can assess, value, and integrate the carbon reduction benefits of certain farming practices into the lifecycle analysis of the fuel they produce. Once finalized, the USDA guidelines could help the U.S. Treasury Department adopt these practices in clean fuel regulations and tax credit programs, like the 45Z clean fuel production credit.
“We have been waiting a long time for more information on how farmers can participate in a new sustainable aviation fuel marketplace,” said Garrett Hawkins, President of ICGA and farmer from Waterloo, IL. “The guidance released today is an important acknowledgment of the role farmers can play in decarbonizing the U.S. transportation sector.”
ICGA is encouraged that important updates were incorporated into this interim rule, including the decoupling of practices – an element that concerned many farmers who called bundling practices unworkable – and the recognition of additional practices and additional crops. The USDA added flexibility in their guidance which will be valuable for farmers seeking to participate.
However, ICGA is concerned that today’s rule doesn’t outline systems that will allow all farmers to participate.
“The piece of today’s guidance that feels the most challenging to accept is the mass balance approach to tracking the flow of low-carbon corn. We will suggest alternate systems to track this in our comments, as we believe the mass balance system prevents all farmers from participating in this new market opportunity,” said Hawkins.
ICGA predicts that the mass balance approach will extend this new market opportunity only to farmers who sell to an ethanol plant. Additionally, ICGA fears that mass balance tracking will encourage vertical integration, with ethanol plants driven to tell farmers what conservation practices to use to achieve the desired low carbon feedstock score.
“ICGA’s mission is to create a future for Illinois farmers in which they can operate freely, responsibly, and successfully. We are concerned that the interim rule’s record-keeping proposal could jeopardize our member’s opportunity to ‘operate freely’ in the future,” Hawkins said.
The USDA’s Interim Rule on Technical Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks will be published in the Federal Register on January 16, which will begin a 60-day comment period for the public to weigh in on the proposed rule.
In the meantime, the delay in finalizing guidance has rendered the opportunity for Illinois farmers to participate in a low-carbon feedstock opportunity ineffective for the 2025 crop year, as cropping decisions have already been made.
We remain hopeful that final guidance can impact growing decisions for 2026 and 2027 and are grateful to the USDA for publishing an interim rule that Illinois farmers can respond to.
“This published interim rule is a really important step in the right direction. I know my neighbors and I have a role to play in a low-carbon future and ICGA is excited to participate in crafting landmark guidance that clarifies and defines that role,” said Hawkins.
Learn more about the 45Z tax credit here.
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About the Illinois Corn Growers Association
Illinois 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.
