During the last days of the Biden administration, the U.S. Department of Agriculture (USDA) released a proposed interim rule, “Technical Guidelines for Climate-Smart Agriculture Crops Used in Biofuel Feedstocks.” According to the proposed interim rule, “…feedstock emissions account for 56% and 55% of the direct emissions from producing corn ethanol and soybean biodiesel.” 

In response, the USDA made these guidelines available for consideration in international, national or state clean transportation fuel policies. As part of the guidelines, the USDA worked with Argonne National Laboratory to develop a USDA calculator. The USDA Feedstock Carbon Intensity Calculator (FD-CIC), quantifies the carbon intensity (CI) in greenhouse gas emissions per bushel of domestic feedstocks (i.e., corn, soybeans, sorghum) produced using one or more climate-smart agriculture (CSA) practice. 

CSA practices include no-tillage, reduced tillage or cover crops, and/or the following nutrient management practices: use of nitrification inhibitors, split in-season nitrogen application or no fall nitrogen application. 

In the FD-CIC calculator, farmers must enter their farm location (i.e., county and state), crop produced, total field or management acres and which CSA practices they used. The FD-CIC then outputs a field-level CI score. The calculator can also output a weighted, farm-level average across fields growing the same crop.  

A huge component of participating in the CI score space is record keeping. Every entity in the supply chain producing or taking ownership of reduced-CI crops or reduced-CI processed products must have a system for maintaining records and for auditing purposes. Farmers specifically are required to prepare a Biofuel Feedstock Report with a Farmer Producer Attestation for each crop sold as a reduced-CI crop. In addition, farmers must maintain records demonstrating the location and acreage of any field or management unit where the CSA practice was implemented, as well as the total bushels of crop harvested from those fields.  

Producers may be wondering how the CI -score crop will be accounted for throughout the supply chain. The proposed guidance outlines a mass balance accounting system, which tracks the weight or volume of products moving through an entity without product segregation. This means CI-scored crops and non-CI-scored crops will be mixed together.  

Keep in mind, the CSA guidelines apply to crops used for biofuels. Clean Fuel Production Credits are a tax credit given to biofuel producers. At this time, there is no guaranteed revenue for farmers who are participating in the CSA space and getting CI scores for their crops. Some believe fuel producers will incentivize farmers by paying a higher premium for low CI-score crops, but there is currently no system in place for that. While the Clean Fuel Production tax credit, commonly known as 45Z, went into effect January 1, 2025, fuel producers are likewise operating under a proposed interim rule put out at the end of the Biden administration.  

The state of climate-smart agriculture, CI scores and the 45Z tax credit remain to be seen until further guidance from the Trump administration is released.