Mr. William Hohenstein
Director of Office of Energy and Environmental Policy
U.S. Department of Agriculture
Room 112-A, Whitten Federal Building
1400 Independence Avenue SW
Washington, DC 20250-3810
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Regarding: Procedures for Quantification, Reporting, and Verification of Greenhouse Gas Emissions Associated with the Production of Domestic Agricultural Commodities Used as Biofuel Feedstocks
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Dear Mr. Hohenstein,
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Incite.ag, a farmer-founded Carbon Intensity (CI) scoring software company, is pleased to respond to the USDA's Request for Information regarding the procedures for quantification, reporting, and verification of GHG emissions associated with climate-smart farming practices for biofuel feedstocks. 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 four points underscore the key elements which we believe will lead to an effective and resilient
decarbonization program.
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Utilization of the Full GREET Model

We strongly recommend the utilization of the complete Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) model and Feedstock Carbon Intensity Calculator (FD-CIC), in assessing eligibility for IRA 45Z. The full GREET model has been established and recognized as the national and industry gold standard. Its comprehensive analysis is crucial for accurately crediting the diverse suite of emissions reduction efforts being deployed by fuel and feedstock producers.
Recognition of Granular Management Practices

Midwestern corn producers are leading the way and currently deploying a wide range of commercially proven climate smart agricultural (CSA) practices. Implementation of these practices is coupled with cost-effective and widely adopted data capture solutions to support validation of these granular farm management practices. These practices, recognized through the GREET model, have demonstrated significant carbon intensity (CI) reductions. It is imperative that any low carbon tax credit guidance related to agricultural feedstocks recognizes and incorporates these comprehensive, individual, and granular management practices and does not limit corn producers to only deploying and validating a narrow group of management practices to qualify for CI reductions. Current, ongoing corn production data capture and CI scoring efforts within the incite.ag scoring network have shown that a granular and complete recognition of CSA practices is leading to a +30% reduction in on-farm emissions.

Adherence to Scientific Rigor
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We emphasize the importance of adhering to rigorous scientific standards in the development and implementation of any modifications to the GREET model. Such modifications should be subject to normal scientific, agency, and public processes, ensuring that the latest science at the DOE's Argonne National Lab guides the decision-making process.
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Inclusion of Climate Smart Agriculture in Modifications
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Any ongoing modifications must ensure that the GREET model continues to accurately credit efficient and sustainable farm management practices and emissions reductions. Excluding these factors would disregard critical efforts by domestic feedstock producers to reduce emissions and miss an opportunity to include rural America in the sustainable production of biofuels.

When considering the questions addressed in this requeseeeeet for information, the following reflect incite.ag’s additional recommendations towards ensuring successful implementation of Procedures for Quantification, Reporting, and Verification of Greenhouse Gas Emissions Associated with the Production of Domestic Agricultural Commodities Used as Biofuel Feedstocks

• Qualifying Practices and Feedstocks:
  ‍Sort your physical documents into categories such as fertilizer use, yield records, fuel consumption, and crop management practices. Label each category clearly.
  
• Quantification and Modeling:
  USDA should use comprehensive and current scientific data, emphasizing models like GREET for lifecycle analysis. Quantification should occur at multiple scales (farm-level, county-level, regional) to capture local variations. Baseline GHG emissions and soil organic carbon fluxes should be modeled using historical data and current practices, serving as benchmarks for assessing the impact of climate-smart practices. All corn growing counties in the US must include a SOC metric. Models like GREET and the FD-CIC are adequate for quantifying GHG effects with limited refinement and inclusion of additional SOC county metrics. These models can enhance accuracy and provide detailed carbon assessments.
• Mass Balance:
  Commercial grain aggregators are a critical link in the agricultural supply chain. As a result, many feedstock producers don’t maintain a direct relationship with the biofuel producer ultimately receiving their grain. Significant challenges will be put on individuals and entities seeking to score CI and deliver grain through pre-established commercial networks, while also maintaining verified traceability. As such, we would strongly recommend a mass balance approach for bushels sourced through commercial aggregators which ultimately end up in the grind of a biofuel producer.
• Book & Claim:
  As an additional element of this mass balance approach would be a tangential book-and-claim approach which would decouple carbon intensity attributes from a physical bushel’s delivery. We encourage the recognition of feedstock producers who chose to get certified under independent mass-balance processes to additionally receive recognition of certification and auditing requirements under this book and claim. This reciprocity reduces the burden on feedstock
  producers to meet additional certification requirements and it provides feedstock producers with freedom and choice in a wider array of decarbonization incentive programs. Ultimately, this approach would encourage fuel and feedstock producers in regions or situations where achieving critical mass to reduce ethanol CI below 50 kg/mmbtu is not feasible to still participate in these policies to adopt climate smart practices and reduce emissions.
• Verification & Record Keeping:
  Verification should rely on detailed records, including farm management logs from Farm Management Information Systems (FMIS), satellite imagery, and remote sensing data. Leveraging existing reporting structures can streamline processes and reduce administrative burdens. On-site audits should be conducted periodically on <5% of participating feedstock producers within a draw territory, using a statistically robust sampling methodology to ensure accurate verification.
• Verifier Qualifications and Oversight:
  USDA should utilize independent third-party verifiers to enhance credibility, ensuring they adhere to strict standards to prevent conflicts of interest. Vendors should retain a Certified Crop Advisor (CCA) on staff to ensure agronomic consistency in services. Existing verification systems, such as those used in organic certification, ISCC, or participation in USDA conservation programs can be adapted for climate-smart verification. Oversight procedures should include regular audits and a process for addressing non-compliance.
• Preventing Inaccurate Claims and Ensuring Integrity:
  USDA should establish robust monitoring and penalty systems to prevent and address inaccurate or fraudulent claims. Preemptive measures like comprehensive data validation and stringent verification protocols are essential for maintaining program integrity.

By addressing these points, USDA can develop a robust framework that accurately quantifies the GHG benefits of climate-smart practices, incentivizes their adoption, and supports the long-term sustainability of U.S. agriculture and biofuels sectors.

I urge your office to consider these recommendations and work towards the timely completion and implementation of the updated GREET model and US Treasury Rulemaking. The recognition of granular on-farm data capture and emissions reductions is vital for the long-term stability and growth of the agriculture and biofuels sectors, contributing to the overall goals of the current Administration. Furthermore, it will provide the public with confidence that the review, analysis, and assessment of sustainable practices are transparent and trustworthy. They deserve nothing less.

Thank you for your attention to this matter, and consideration of these recommendations. I look forward to your continued efforts in supporting the efficient and sustainable practices of our agricultural community.

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.