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Agriculture, Biofuels Groups Await Biden Administration Release of GREET Model on SAF

Todd Neeley
By  Todd Neeley , DTN Environmental Editor
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Biofuels and agriculture groups called on the Biden administration to release the long-awaited update to a key climate model at the center of tax credits for sustainable aviation fuel production. (DTN file photo by Todd Neeley)

LINCOLN, Neb. (DTN) -- A continued delay in releasing a modified GREET model to determine eligibility for sustainable aviation fuel tax credits, has raised the ire of agriculture and biofuels groups alike who asked the Biden administration on Thursday to act.

The U.S. Treasury Department was to release a modified GREET, or Greenhouse gases, Regulated Emissions, and Energy use in Technologies, model by March 1 and instead delayed that release. The climate model is considered the gold standard and produces what the agriculture and biofuels industries believe is the most accurate accounting of their greenhouse gas emissions profiles.

The 26 groups said in the letter to Treasury Secretary Janet Yellen they are concerned the delay will result in a change to GREET that is unfavorable.

They said there is concern the administration will adjust GREET to penalize the industries for so-called indirect land use change.

The groups cautioned Yellen not to make "contradictory changes" to GREET that would harm the industries' future in the budding sustainable aviation fuel industry.

"It is our understanding that the delay was caused by questions about both indirect land use change and climate smart agriculture," the letter said.

"While there is uncertainty around measuring climate impacts for all types of energy practices, we are concerned about the potential for a double standard as it relates to accounting for ILUC and CSA. The administration is reportedly ready to move forward on '40B ILUC' notwithstanding the fact that ILUC is unverifiable and extraordinarily uncertain, and according to peer-reviewed analysis of empirical data, may not have any causal correlation to biofuel production."

The groups said in "stark contrast to ILUC," the "causal relationship" between on-farm practices and carbon is "clear."

"CSA practices are observable and verifiable, and uncertainty will resolve over time," the letter said.

"Fully crediting CSA practices under 40B is imperative, particularly if speculative and unverifiable penalties against agricultural feedstocks are maintained. The practice of accounting for on-farm and other upstream practices is evolving quickly with the global advance of climate policy, and offering credit under 40B for climate smart land practices is highly defensible."

The letter is signed by Clean Fuels Alliance America, Growth Energy, National Corn Growers Association, National Farmers Union, National Oilseed Processors Association, Renewable Fuels Association, Illinois Corn Growers Association, Illinois Renewable Fuels Association, Indiana Corn Growers Association, Iowa Corn, Iowa Renewable Fuels Association, Kansas Corn Growers Association, Michigan Corn, Minnesota Bio-Fuels Association, Minnesota Corn, Missouri Corn, Missouri Renewable Fuels Association, Nebraska Corn Growers Association, North Dakota Corn Growers Association, North Dakota Ethanol Producers Association, Ohio Corn and Wheat, Renewable Fuels Nebraska, South Dakota Corn, Texas Corn Producers Association, Wisconsin Corn and Wisconsin Biofuels Association.

"We appreciate the administration's commitment to enlisting America's farmers and biorefiners in the effort ramp up SAF production," the letter said.

"If done right, the program could unleash a new wave of innovation and prosperity across America's heartland. Failing to value regenerative and CSA advancements, as well as the full suite of biorefining innovations cited in guidance to date, would leave substantial carbon emissions reductions on the table and represent a missed opportunity to energize these promising sectors."

The groups call for a consistent approach to indirect land use change and climate-smart agriculture, saying it is a "vital part of giving farmers and SAF producers a credible, durable, and predictable framework" for investing in SAF.

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