The 45Z Clean Fuel Production Credit has the potential to drive more soil health practice adoption than even the Farm Bill—but only if implemented correctly. To ensure success, Continuum Ag recommends three key changes to the USDA’s proposed technical guidelines. You can review our full comments in the link below and also post your own comments. We are focused on the following points:
1. Use a Book and Claim Approach to Feedstock CI Tracking Rather Than Mass Balance
Book and Claim decouples the CI Certificates from the physical bushels. Farmers can sell their crops as they wish, and sell their CI Certificates into open, transparent, fair trading marketplaces. All farmers can participate, not just those who happen to be near the ethanol plant. Mass Balance tracking limits farmer participation, increases carbon emissions, and creates a tremendous amount of financial hardship for some farms. If you are like me, I sell my crops to the local livestock feeders. Mass Balance would require that I truck my crop further, earn less, and leave the local livestock feeders having to pay more to bring crops from further away to overcome the crop gap.
2. Adopt the GREET FD-CIC Model Rather than the USDA FD-CIC
The Department of Energy’s GREET model has been around for 30 years and its associated Feedstock Calculator (GREET FD-CIC) is the most robust tool on the market. Using the GREET FD-CIC accounts for farmer yield, fertilizer, cover crop, tillage, pesticide, energy, and manure management practices. Farmers must collect agronomic evidence to pass audits, they may as well get compensated for it and at best be as scientifically sound as possible in this program. Alternatively, the USDA’s proposed Feedstock Carbon Intensity Calculator (USDA FD-CIC) oversimplifies the CI scoring process, failing to account for yield, fertilizer application rates, and soil organic carbon at a local level. This results in artificially high CI scores, discouraging farmer participation. Many of your good efforts would not be accounted for using the USDA FD-CIC. If you would like to know your GREET score, visit TopSoil.ag. If you would like your USDA score, contact us and we would be happy to run it for you.
3. Utilize ISO 14065 Standards for Audits
Continuum Ag’s core value to farmers is to help with data management and ensure the audit process is as smooth as possible. Of course, we are also fighting for an equitable share of the finances associated with any sustainability program, including 45Z. The USDA’s proposed MRV (Measurement, Reporting, and Verification) protocol contains unrealistic mandates that could block farmer participation. For example, requiring no-till for four out of five years and implementing a rigid nutrient budget would exclude most farmers. We are encouraging a system in which farmers document their agronomic practices using a data log like TopSoil, then they supply evidence, such as shapefiles and receipts, to prove that the practices occur. Private sector companies should be utilized to facilitate data management, scoring, and verification. This should not be tasked to the county USDA Field Office.
Submit your Comments to the USDA
We’re excited about the future of low-carbon agriculture and we are committed to ensuring that farmers play a central role in shaping what’s next. Now is the time to act—farmers can submit their comments to the USDA before the deadline to help ensure that 45Z is implemented in a way that benefits agriculture. If you’d like to submit feedback, visit the USDA website and consider telling your story. Be specific and share as much as you would like. Detailed farmer stories will go far in this comment period. Click here to submit your comments.
What Can Farmers Do Now?
While the USDA is going through the public comment period and the 45Z rules are still yet to be finalized, there are steps farmers can take today to prepare for what’s coming:
- Get your CI Score – Continuum Ag offers FREE CI Scores through our TopSoil tool, allowing farmers to understand where they stand and what changes could lower their CI.
- Document your practices – Keeping good records of field operations, fertilizer use, and soil health practices will be critical for future verification processes.
- Stay engaged – The policy landscape is evolving quickly, and being informed will help farmers stay ahead of new opportunities.
- Join us every Tuesday morning on the CI Chit Chat
- Read Continuum Ag’s full comments: https://continuum.ag/wp-content/uploads/2025/03/USDA-Technical-Guidelines-Comments-from-Continuum-Ag.docx-1.pdf
- Submit your feedback to the USDA: https://www.regulations.gov/document/USDA-2024-0003-0262
The Bottom Line
For 45Z to succeed, it must be designed with farmers in mind. By adopting Book and Claim, using the GREET FD-CIC model, and aligning audits with ISO 14065 standards, the USDA can unlock the full potential of this program—empowering farmers, lowering carbon emissions, and driving real change in sustainable agriculture.
Mitchell Hora
Founder/CEO – Continuum Ag