Today, Mitchell Hora, CEO & Founder of Continuum Ag and a seventh-generation Iowa farmer, testified during the IRS Public Hearing regarding the Section 45Z Clean Fuel Production Credit.
Representing both farmers and the broader agricultural industry, Hora shared practical recommendations focused on ensuring farmers are fully included in the future of low-carbon fuel markets through Carbon Intensity (CI) scoring, feedstock verification, and scalable implementation of 45Z.
“45Z has the potential to make a massive impact on family farms,” Hora shared during his testimony. “If this program is done right, 45Z will provide the first opportunity at scale to reward American farmers not just for how much they grow, but for how they grow.”
Over the last several years, Continuum Ag has worked alongside thousands of farmers to prepare for emerging CI opportunities by helping operations organize field data, understand their Carbon Intensity, and complete verification processes. Through the TopSoil® platform, Continuum Ag has now CI-scored more than 400 million bushels of U.S. corn and soybeans across nearly every state.
During the hearing, Hora focused his comments specifically on the feedstock component of 45Z and outlined three key recommendations for the final rule:
1. The Final CI Calculator Must Adequately Reward Farming Practices
Hora emphasized the importance of ensuring the final USDA or DOE feedstock calculator properly rewards practices farmers are already implementing, including:
- Cover crops
- Reduced tillage or no-till
- Manure utilization
- Improved fertilizer management, including rate and product specifications
- Field-level productivity
“The final calculator is the single most important component that will determine the success of 45Z,” Hora explained.
He noted that if the calculator fails to accurately reflect the value of these practices, farmer participation in 45Z could be significantly reduced.
A major focus of Hora’s testimony centered around the need for a Book and Claim system instead of Mass Balance accounting.
2. 45Z Must Utilize Book and Claim Accounting
Hora explained that requiring physical grain tracking from farms to ethanol plants would increase costs, create inefficiencies, and unintentionally exclude many farmers and livestock producers from participating in the program.
“Mass balance is counterproductive to the entire point of 45Z,” Hora stated.
Instead, he advocated for a verified Book and Claim system that allows CI attributes to move independently from the physical grain — similar to systems already used elsewhere within low-carbon fuel markets.
3. Maintain ISO 14065 Verification Standards
Hora also encouraged the IRS and USDA to maintain the ISO 14065 audit and verification framework already outlined in preliminary guidance.
Continuum Ag completed a full ISO 14065 audit process on 30 million bushels spanning 12 states, demonstrating that field-level verification and CI auditing can be done accurately, efficiently, and at scale.
“The Infrastructure Is Already Built”
Throughout the testimony, Hora reinforced that farmers and private industry are prepared to participate immediately once final guidance is released.
“Continuum Ag and many other players have been working in the private sector to ready the ag industry to serve as a CI lowering solution,” Hora said.
He closed his testimony with a message directed toward the future of American agriculture and farmer participation in 45Z:
“We have our data in hand, and are waiting at the 45Z starting line, ready to rock.”
And finally:
“If you build 45Z right, you will see farmers participate and change their practices as you’d never believe.”