NOPA Urges USDA to Strengthen CSA Rule to Support U.S. Oilseed Farmers & Biofuel Growth

NOPA Comments Call for Expanded Feedstock Eligibility, Stronger Protections for U.S. Agriculture and Increased Scrutiny of Imported Feedstocks

WASHINGTON, March 18, 2025 – The National Oilseed Processors Association (NOPA) today submitted comments in response the U.S. Department of Agriculture’s (USDA) Interim Rule on Technical Guidelines for Climate-Smart Agriculture (CSA) Crops Used as Biofuel Feedstocks, urging USDA to refine key provisions in the final rule to ensure a workable framework that benefits U.S. oilseed farmers and processors.

“As we adapt to new and evolving biofuel programs with potential incentives for on-farm practices, it is critical we support our farmer partners in achieving their conservation goals. This rule is a step in the right direction, but we must ensure these standards are workable for all crops and the entire agriculture value chain, and that they reflect the best science and latest technology available,” said Devin Mogler, President & CEO of NOPA.

NOPA strongly supports several provisions in the interim rule, including:

• Elimination of the Bundling Requirement – Removing the mandate for simultaneous adoption of multiple conservation practices increases flexibility for farmers and enhances adoption rates.
• USDA Management of FD-CIC Data – Ensuring that USDA maintains and updates the Field Data Collection and Integrity Criteria (FD-CIC) database strengthens accuracy of assessing impacts of farm practices.
• Commingling of CSA and Non-CSA Crops – Recognizing the realities of supply chain logistics by allowing blended storage of climate-smart and conventional crops is essential for efficient processing.

While NOPA welcomes these steps, the association is urging USDA to incorporate the following critical improvements in the final rule:

1. Expand Eligible Oilseed Crop Pathways – Including spring and winter canola, carinata, camelina, and pennycress will expand biofuel feedstock availability and strengthen U.S. energy security.
2. Evaluate Impacts on Planting Decisions – Ensuring the valuation of on-farm practices does not disproportionately favor certain biofuel feedstocks, as it could unintentionally influence planting decisions and disrupt market dynamics.
3. Broaden the List of Eligible Conservation Practices – Adding measures such as conservation crop rotation, conservation tillage, and managed grazing will encourage wider adoption of sustainability efforts.
4. Align Crop Rotation Standards with NRCS Guidelines – Adopting USDA Natural Resources Conservation Service (NRCS) standards will provide clarity and consistency for farmers.
5. Ensure Biofuel Policies Support U.S. Agriculture – Prioritizing domestic feedstocks will support U.S. commodities impacted by a surge in imported feedstocks and strengthen the economic security of America’s farmers.
6. Protect U.S. Agriculture from Displacement by Imported Feedstocks – Strengthening oversight and verification of foreign feedstocks, ensuring transparency in trade practices, and preventing policies that favor imports over U.S.-grown commodities.
7. Exclude Indirect Land Use Change (ILUC) Penalties from Modeling – Ensuring that U.S. farmers are not unfairly penalized for implied international agricultural practices beyond their control.

Read NOPA’s comments here

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Organized in 1930, the National Oilseed Processors Association (NOPA) represents the U.S. soybean, canola, flaxseed, safflower seed, and sunflower seed-crushing industries. NOPA’s membership is 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’s 17 member companies operate over 70 softseed and soybean solvent extraction plants across 21 states, crushing over 95% of all soybeans processed in the United States, the equivalent to more than 2 billion bushels annually. More information at www.NOPA.org