Mr. William Hohenstein
Director of Office of Energy and Environmental Policy
U.S. Department of Agriculture
1400 Independence Avenue SW
Washington, DC 20250-3810
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Regarding: Comments on USDA’s January 15, 2025 release of BETA FD-CIC and Technical Guidelines for Biofuel Feedstocks
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Dear Mr. Hohenstein,
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Incite.ag, a farmer-founded Carbon Intensity (CI) scoring software company, appreciates the opportunity to provide comments on the USDA’s January 15 release of the BETA FD-CIC and Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks. This guidance represents a significant step toward implementing the 45Z Clean Fuel Production Credit in a way that aligns with both administration objectives and practical agricultural realities. The framework laid out in the BETA FD-CIC provides a roadmap for participation that will allow biofuel producers, aggregators, and growers to engage in a market-driven approach for carbon intensity (CI) scoring and credit generation at scale.
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Our insights are derived from industry-leading experiences in data capture and carbon intensity scoring for biofuel and feedstocks and aim to enhance the development of effective federal policies and strategies. The following points underscore the key elements which we believe will lead to an effective and resilient decarbonization program.
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We commend the USDA for its efforts in structuring a framework that balances rigor with accessibility. This balance is critical to ensuring widespread adoption of CI scoring methodologies while maintaining high standards for verification and compliance. As agriculture and biofuels converge on innovative market-driven decarbonization goals, ensuring that this guidance is both scientifically robust and operationally feasible will be crucial to its long-term success. Below, we outline areas where the January 15 delivery excels and should be carried forward in final guidance frameworks, as well as specific recommendations to refine and improve the final rules before implementation.
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Strengths of the January 15 Guidance

‍Several aspects of the BETA Feedstock Carbon Intensity Calculator (FD-CIC) and USDA Guidelines for Climate-Smart Agriculture Crops Used as Biofuel Feedstocks are well-executed and should be retained in final guidance:

• Alignment with GREET Models:
  ‍The utilization of foundational GREET and FD-CIC modeling as it stands today ensures consistency with existing industry frameworks. This decision allows producers to align their CI scoring efforts with the well-established FD-CIC model rather than requiring them to navigate a new, proprietary methodology. It also ensures that scoring remains in sync with broader lifecycle analysis practices used in the transportation and energy sectors. The BETA USDA FD-CIC should be carried forward and utilized in final guidelines while allowing for minor adjustments and improvements.
  
• SOC Modeling for All Counties:
  We commend the inclusion of Soil Organic Carbon (SOC) modeling for every corn growing county ensuring that regionally specific recognition of conservation practices is available to all growers, rather than limiting participation to a few states with existing datasets. By expanding SOC considerations across all counties, the USDA has ensured that every producer can benefit from their conservation practices. This approach recognizes the significant role soil plays in carbon sequestration and ensures equitable access to carbon intensity scoring nationwide.
• Unbundling of CSA Practices:
  The ability to recognize individual Climate Smart Agriculture (CSA) practices rather than requiring multi-practice “bundles” allows for more accurate representation of farm management broadscale adoption. Many growers have already implemented conservation practices in a phased approach, and this framework acknowledges those efforts without penalizing partial adopters. The ability to account for specific practices such as reduced tillage, cover crops, and nitrogen management as separate components ensures that every increment of conservation improvement is rewarded appropriately.
• Detailed Compliance and Verification Procedures:
  The structured compliance framework, including mass balance tracking for first points of aggregation and intermediate entities, provides clarity and reduces uncertainty in feedstock verification. This ensures that CI scores reflect actual on-farm practices while providing a clear path for aggregators and biofuel producers to track and verify user-defined metrics. By implementing strong compliance procedures upfront, the USDA has taken a proactive step toward preventing fraud and ensuring the long-term credibility of the program.
• Inclusion of STIR Values:
  Recognizing the Soil Tillage Intensity Rating (STIR) ensures tillage management is accurately reflected in the scoring process. This approach provides a quantitative solution to differentiate between various tillage practices, allowing no-till and reduced-till adopters to be rewarded for their soil conservation efforts. By including STIR values in categorization of tillage for CI scoring, the USDA is providing a scientific basis for recognizing the benefits of reduced soil disturbance.
• Ease of Use for Farmers:
  The system’s accessibility and practical approach to data collection and scoring encourage broad participation among growers. Simplified data entry requirements and automated calculations lower the barrier to entry and ensure that the program is not limited to only the most technologically advanced operations. This inclusivity is key to driving adoption across diverse farm operations and regions.

Recommended Areas for Improvement

‍While the guidance provides a solid foundation, several key areas require further refinement to maximize both feasibility and impact.

• Recognition of A New Marginal Split-Applied Pre-Planting Nitrogen Category:
  ‍The current guidance disqualifies fields that received any fall or early spring nitrogen from being recognized as split-applied. This approach fails to reflect real-world agronomic practices that optimizes economics, nitrogen efficiency, and environmental benefits. Applying a portion of nitrogen in the fall or early spring, followed by an application of at least 25% at planting or later, has been shown to reduce overall nitrogen losses while supporting stable crop uptake. Recognizing this as a newly classified, marginally split-applied system would better align with conservation-minded fertility strategies while still incentivizing best management practices.
  
• Grandfathering and Reducing Photographic Evidence Requirements for 2024:
  Given the delayed guidance release, many growers could not have anticipated the need for photographic evidence of cover crops and potentially tillage from the 2023-24 crop year. Since it is nearly impossible for a standard producer to retroactively capture such evidence with currently available, on-farm technologies, alternative verification methods should be accepted. Declarations, affidavits, and other substantial supporting documentation should be deemed acceptable to ensure fair treatment of growers who implemented sustainable practices in good faith but lack photo records for the 2024 corn crop and 2025 management practices which are being implemented today under the uncertainty of preliminary guidelines.
• Expansion of Agricultural Expert Definition:
  The current guidance limits agricultural expertise to land-grant universities, cooperative extension employees, and similar roles. However, many agronomic professionals operate outside these institutions, including Certified Crop Advisers (CCAs), Certified Professional Agronomists, Technical Service Providers, and individuals holding a master’s degree in agronomy or a related crop science field. Expanding the definition of agricultural experts will ensure that the most qualified individuals can contribute to verification and technical support in CI scoring.
• Emphasizing Grower Declaration and Attestation:
  Some farm management practices do not generate digital records or records of any kind, particularly on smaller diversified operations. The guidance should allow for grower declarations and attestations to serve as valid forms of source documentation where digital records are unavailable. By incorporating a structured attestation system with reasonable verification checks, the USDA can maintain compliance integrity while ensuring fairness for all growers.
• Inclusion of a Climate Consideration in “Dry” Regions:
  Western and fringe regions of the Corn Belt experience significantly lower precipitation levels, leading to different denitrification, runoff, and nitrogen leaching dynamics than in wetter regions. The current model does not account for these regional differences, potentially penalizing growers in drier climates who inherently experience reduced nutrient losses. A dry climate designation from previous FD-CIC modeling (2022-23) should be incorporated to reflect the reality that water availability significantly impacts nitrogen movement and conservation efficacy.
• Inclusion of Manure Applications in CSA Practice Options:
  Current guidance does not adequately recognize manure applications within the FD-CIC framework. Manure application should be explicitly classified as a CSA practice, as it replaces synthetic fertilizers, enhances soil organic matter, and contributes to significant life cycle emissions reductions. Verifying manure applications should require a practical but rigorous approach, placing the burden of documentation on growers through rate reporting, application timing, and verification evidence such as manure delivery records and attestations. Properly recognizing manure application within CI scoring would reward farmers for using regenerative nutrient management strategies while incentivizing a transition away from synthetic inputs.
• Expanding Cover Crop Adoption by Allowing for Livestock Grazing:
  To further encourage the adoption of cover crops, the USDA should explicitly allow fields to qualify for CI reductions even if livestock grazing occurs. Grazing animals on cover crops increases biomass decomposition, enhances nutrient cycling, and stimulates root growth, all of which contribute to carbon sequestration. The USDA should clarify that grazed cover crops remain eligible for CI credit recognition as long as cover crops are maintained for the necessary growth period, ensuring that farmers are not penalized for adopting economically sound conservation practices.
• Allowable Margin of Error for STIR Classifications:
  The USDA’s STIR classification thresholds currently leaves no room for minor variances, potentially disqualifying fields that are effectively managed within conservation parameters but fall slightly outside the rigid scoring threshold. A small acceptable margin of error should be introduced to ensure that growers who adhere to the spirit of conservation tillage are not penalized due to minor discrepancies in scoring calculations.
• Inclusion of Winter and Spring Canola as a Qualified Feedstock:
  Canola is an important oilseed crop with a growing role in low-carbon fuel markets. Excluding canola from the list of qualified feedstocks ignores its potential contributions to renewable diesel and other biofuel pathways. Canola should be explicitly recognized as a qualified feedstock to expand participation opportunities and further support sustainable fuel production.

We appreciate the USDA’s commitment to stakeholder engagement and look forward to ongoing collaboration to ensure the final FD-CIC guidelines enable robust participation from feedstock producers while maintaining environmental integrity. The agricultural sector is uniquely positioned to lead in climate-smart initiatives, and we urge USDA to take an approach that both rewards innovation and ensures that CI scoring remains practical for widespread adoption.Thank you for considering our recommendations.

Sincerely,

Preston Brown
President | Founder
Incite.ag
preston@incite.ag
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Incite.ag guides producers across the agricultural supply chain to Turn Emissions into Income. Incite.ag’s CI scoring system unlocks novel revenue streams and empowers producers to take control of their unique CI Scores. Learn more by hitting the link below or reach out to the team directly at success@incite.ag or 815.373.0177.