Press Release
NOPA to USDA: Feedstocks from U.S. Oilseeds Offer Significant Decarbonization Opportunities and Should Not Be Left Behind
National Oilseed Processors Association urges the U.S. Department of Agriculture to expand eligible climate-smart agriculture practices and diversification of feedstocks for biofuels in 45Z rulemaking.
WASHINGTON, July 25, 2024 – The National Oilseed Processors Association (NOPA) is emphasizing the benefits of renewable fuels produced with feedstocks from U.S. oilseeds and encouraging the U.S. Department of Agriculture (USDA) to further recognize the climate-smart agricultural (CSA) practices that could expand decarbonization opportunities in clean transportation fuel programs, notably the Section 45Z Clean Fuel Production Tax Credit.
“Agricultural feedstocks naturally play a pivotal role in the oilseed processing industry, serving as the backbone for sustainable biofuel production. As the world seeks to transition to cleaner energy sources, the importance of these feedstocks in decarbonizing both biofuel and vegetable oil production cannot be overstated. By adopting climate-smart farming practices, we can significantly reduce GHG emissions associated with the cultivation and processing of these commodities, thereby enhancing the environmental benefits of biofuels,” NOPA President and CEO Kailee Tkacz Buller wrote in comments to USDA.
NOPA’s comments were delivered in response to the department’s Request for Information (RFI) on “Procedures for Quantification, Reporting, and Verification of Greenhouse Gas Emissions Associated With the Production of Domestic Agricultural Commodities Used as Biofuel Feedstocks.”
While NOPA praised the Biden Administration’s recent release of the Greenhouse Gases, Regulated Emissions and Energy Use in Technologies (GREET) model which acknowledged, for the first time, the carbon benefits that climate-smart agriculture (CSA) practices can deliver, the organization expressed a number of improvements necessary for 45Z to be viable to U.S. crushers, farmers, and taxpayers alike:
- A domestic feedstock requirement for 45Z should be implemented. While 45Z does not go into effect until Jan. 1, 2025, imported low Carbon intensity (CI) feedstocks have flooded the market to satisfy state program demands. From Jan. 1, 2023-May 31, 2024 alone, the United States imported a total of 7.4 billion pounds of UCO and tallow, displacing the soybean oil crushed from an equivalent of over 600 million bushels of soybeans. NOPA members crush approximately 2 billion bushels of U.S. soybean annually. This market dynamic is unsustainable which is why NOPA joins the American Soybean Association, American Farm Bureau Federation, National Corn Growers Association, and the National Farmers Union to support a domestic feedstock requirement for 45Z.
- Apply heightened scrutiny to imported feedstocks to ensure integrity in state and federal low carbon/clean fuel tax incentives.
- Issue and finalize the 45Z rulemaking as soon as possible. With over 5 billion gallons of biomass-based diesel being produced today, uncertainty in the marketplace is already hindering the ability of stakeholders to plan and implement CSA practices effectively.
- Allow for decarbonization pathways for oilseed processing under the GREET model.
- Modeling used in the rulemaking should be the GREET model for non-aviation fuels, and should not include the additional indirect effects such as those included in the 40B GREET model.
- Unbundle CSA practices to enable farmers to adopt practices that are most suitable for their specific geographies, weather conditions, and operations.
- Include additional oilseed crop pathways beyond soybeans and canola such as corn, sorghum, spring canola, winter canola, brassica carinata, camelina, and pennycress which will support the diversification of biofuel feedstocks providing significant environmental, economic, and technological benefits.
- Eliminate requirement that farmers must contract directly with fuel producers as this does not reflect the real-world conditions of the agricultural supply chain where oilseed processors serve as the point of sale between farmers and fuel producers.
NOPA members’ oilseed processing operations yield protein-rich meal for human and animal nutrition, as well as vegetable oil used as an ingredient in food manufacturing and as a feedstock for renewable fuels such as biodiesel, renewable diesel and Sustainable Aviation Fuel (SAF).
A recent study commissioned by NOPA and conducted by S&P Global Commodity Insights found that with planned expansions to U.S. oilseed processing capabilities, domestic feedstocks alone can support the production of an additional 1.4 billion gallons of renewable diesel and biodiesel, also known as biomass-based diesel (BBD) by 2030. These sustainably-produced biofuels help reduce greenhouse gas emissions and lower the carbon intensity of transportation fuels in use today.
About National Oilseed Processors Association (NOPA):
Organized in 1930, NOPA represents the U.S. soybean, canola, flaxseed, safflower seed, and sunflower seed-crushing industries. NOPA’s membership includes 16 members that are engaged in the processing of oilseeds for meal and oil that are utilized in the manufacturing of food, feed, renewable fuels, and industrial products. NOPA member companies operate a total of five softseed and 62 solvent extraction plants across 21 states. NOPA members crush approximately 95% of all soybeans processed in the U.S. which equates to over 2 billion bushels annually. NOPA members have invested $6 billion to expand U.S. crushing capacity by nearly 30% relative to 2023 installed capacity.
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